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Corporate Responsibility Report 2008

Q&As

Here we respond to questions raised by our stakeholders.

Can one company on its own establish high standards of ethical conduct, or is an industry approach required?
We set our own high standards of ethical conduct which we hope will establish a benchmark by which all companies are judged. We also work with other companies through trade associations to develop high ethical standards. We believe that it is in the best interest of patients if the pharmaceutical industry adopts common high standards of ethical conduct. This will also help to improve trust in the industry among all our stakeholders.

A lot of GSK employees were dismissed for unethical conduct. Are your policies working?
In 2008, 266 employees were dismissed or agreed to leave the company voluntarily as a result of policy violations. Unethical conduct occurs in all companies. We believe these figures demonstrate the effectiveness of our monitoring and compliance programmes.

Furthering our ethical culture, recruiting the right people, providing the right training and tools, improving our checks and encouraging people to speak up enable us to identify and address unethical conduct in a consistent and responsive manner.

Is GSK unduly influencing doctors?
We take several approaches to protect against inappropriate influence of doctors, including regional marketing codes of practice, regular training and monitoring. Our policies apply to all employees and agents and commit us to promotional practices that are ethical, responsible, principled and patient centred. They prohibit kickbacks, bribery or other inducements to doctors and any promotion for unapproved uses of our medicines. Our sales force is regularly trained and supervised by managers who monitor educational events, visits to doctors and expenses.

How do you prevent off-label promotion?
All GSK employees dealing with healthcare professionals undergo extensive training and monitoring. They are instructed that only full and accurate information may be provided on approved uses for a medicine. It must be based on valid scientific evidence, and must be accurate, balanced, fair, objective, unambiguous and up to date.

Questions from doctors on off-label uses for our products must be referred to our medical information department. In the US, additional processes are in place for monitoring these referrals to help us ensure that representatives are not promoting off-label uses. We now monitor both the volume of letters responding to questions and the types of referrals made by our individual representatives, for example the number of referrals relating to a particular product or a particular off-label use.

Additionally, our internal audit department regularly audits our sales and marketing practices globally.

The Advertising Standards Authority ruled that health claims in a Horlicks advert shown in the UK were unsubstantiated. Is GSK involved in false advertising?
No, GSK was not involved in false advertising. In 2008, Nepali TV, a Bengali-language satellite channel aimed at viewers on the Indian sub-continent, briefly aired an advert into homes in the UK. However, the advert is intended and approved for use only in India. This was done without our knowledge. The health claims in the advert are not appropriate for the UK as the claims in the advert relate specifically to the Indian market and the Indian diet.

The Advertising Standards Authority in the UK upheld the complaint against Nepali TV for broadcasting the advert in the UK and did not reprimand GSK.

The UK Office of Fair Trading (OFT) is investigating whether supermarkets and suppliers have been wrongly sharing information on prices. Are GSK consumer products involved?
In 2008 the UK Office of Fair Trading (OFT) began an investigation into potential breaches of competition law by more than 20 companies, including GSK. The OFT is looking into claims that data on pricing was passed to rival companies through suppliers. It has asked GSK for our cooperation, but we have not been accused of breaking the law.

We do not tolerate unethical behaviour. Corrupt and anti-competitive behaviour undermines fair competition, inhibits economic development and is bad for economies, business and people. Our code of conduct sets out our expectations for employees and we conduct training to ensure that we operate within the letter and spirit of the law and maintain high standards of ethical business behaviour.

We are cooperating fully with the OFT and we will take disciplinary action, up to dismissal, if a GSK employee is found to have breached our policies or the law.

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