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Corporate Responsibility Report 2008

Marketing ethics

We market our prescription medicines and vaccines to doctors, hospitals and governments.

In some countries, such as the US, we also advertise medicines directly to consumers. Our specialist sales representatives meet regularly with doctors and pharmacists to inform them about our medicines and their approved uses.

We believe that sales representatives play an important role in providing up-to-date information to doctors on our products and their benefits and risks to patients. However, we recognise that the marketing of pharmaceutical products raises some challenging issues.

In particular, some people are concerned that marketing by pharmaceutical companies exerts undue influence on doctors, that sales representatives do not always give doctors full information about potential side-effects, or that promotion of unapproved uses of medicines may be occurring. Our regional marketing codes forbid these practices and other unethical conduct. We provide regular training so that our sales teams understand these codes and we conduct monitoring to assess compliance.

Marketing Codes of Practice

The sale and promotion of pharmaceutical products is highly regulated by governments and medical agencies. We have developed marketing codes and policies and provide training for sales representatives to ensure that they understand how to behave ethically and comply with the law. In many countries our codes and policies go beyond legal requirements.

Our products are sold in more than 150 countries around the world. The first priority with any product in any country is patient safety. We have systems and processes to collect, analyse and report safety concerns about our products.

Our marketing codes of practice apply to all employees and agents. They 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.

These company policies are supported by regional marketing practices codes which apply the same standards but reflect differences in market structures, national healthcare systems and regulations.

A new US PhRMA Code on interactions with healthcare professionals (HCPs) came into effect in January 2009 and we have fully aligned our sales and marketing practices to the requirements of the Code. In some cases, GSK has gone beyond the requirements of the Code, including phasing in a prohibition on giving non-educational items in the US, and reinforcing a $150,000 cap on payments made to an individual US-based HCP working as a consultant to the company, for example by participating in an advisory board or speaking at GSK-sponsored meetings. Our updated Commercial Practice Policies (CPPs) will be available in the first quarter of 2009.

GSK is initiating a review of all internal, regional codes relating to the sales and promotion of our pharmaceutical products. Through this review, we intend to align, where legally and culturally appropriate, GSK’s regional codes. This alignment will lead GSK to develop more detailed global principles guiding the sales and marketing of GSK pharmaceutical products all over the world.

Helping to strengthen industry codes

GSK supports efforts to strengthen marketing standards across the pharmaceutical industry.

This benefits us by creating a ‘level playing field’ in the countries in which we operate and helps to improve the reputation of the pharmaceutical industry as a whole.

In 2008, we took an active role in working with the US pharmaceutical industry association, PhRMA, to develop the changes to its Code on Interactions with Healthcare Professionals. GSK will certify compliance to the Code during the first quarter of 2009. The Code will guide the sale and marketing of GSK pharmaceutical products in the US.

Our Marketing Codes of Practice in summary

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