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Corporate Responsibility Report 2008

Ethical conduct

We are committed to creating a strong ethical culture at GSK.

We do this by putting the appropriate policies in place, recruiting the right people and equipping them with tools to make ethical decisions. Putting patients first is the core principle of being an ethical pharmaceutical company. Profit without principle is short lived.

Failure to uphold high standards of ethical conduct carries significant business risk:

  • Erosion of trust in GSK and our products including among regulators, doctors and patients
  • Fines and litigation resulting in serious financial or legal consequences
  • Damage to GSK’s reputation

Our Code of Conduct sets out fundamental standards for all employees. The Employee Guide to Business Conduct builds on the Code and explains what employees must do to meet its requirements. It provides guidance, including specific examples, on what constitutes unethical behaviour. Strong policies, codes of practice and good training are essential elements of our approach. However, on their own they cannot guarantee that our employees will meet our standards. Our internal compliance systems are designed to identify and address breaches of our codes. We fully investigate suspected breaches and take appropriate disciplinary action, including dismissal where appropriate.

We have clear policies and procedures to prevent corrupt and anti-competitive behaviour. Maintaining high ethical standards in our marketing is also vital and is relevant to patient safety. It is essential that our marketing practices help doctors to prescribe medicines that are in the patient’s best interests. Our policies prohibit kickbacks, bribery or other inducements to doctors, and any promotion for unapproved uses of our medicines. Maintaining high ethical standards during all stages of R&D and once a product is approved for marketing is a key part of our commitment to put the patient first.

Your ethical compass

Our Employee Guide to Business Conduct includes an ‘ethical compass’ that helps employees deal with ethical issues that are difficult to resolve. When faced with such a situation, we encourage our people to ask themselves these questions:

  • Is it legal and ethical?
  • Is it consistent with GSK policy and the Code of Conduct?
  • Is it consistent with GSK’s Mission and Spirit?
  • Can I explain it to my family and friends?
  • Would I be comfortable if it appeared in a newspaper?

We encourage employees to seek additional guidance and to keep asking questions until they are certain that they are making the right choice.