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• Monitoring and compliance

Corporate Responsibility Report 2008

Monitoring and compliance

• Approach
• Performance and plans

All our managers are accountable for managing risks of non-compliance with our policies in their areas of responsibility. They are overseen by and can seek advice from our corporate ethics and compliance department that promotes effective compliance programmes, addresses compliance issues, and reports problems and progress to senior management and the Board.

We have a dedicated compliance officer for each of our business units: R&D, Manufacturing, Vaccines, Pharma Europe, Pharmaceuticals Emerging Markets, Pharmaceuticals Asia Pacific and Japan, Consumer Healthcare, Corporate, US Pharmaceuticals, and additional compliance representatives in some markets.

Compliance officers are senior managers with direct access to the leadership teams of GSK functions. They are a source of expertise for anyone with a question on ethics or GSK policies. Our corporate compliance officer reports directly to the CEO.

To further develop GSK’s internal infrastructure, new full-time compliance director positions were also established during 2008 in Latin America, Middle East-North Africa, Asia Pacific and China. This further demonstrates our ongoing commitment to provide dedicated and focused support to our senior management teams globally. Previously such support was via 'champion' roles which were fulfilled by individuals who had additional functional responsibilities beyond ethics and compliance.

Risk management

Our Risk Oversight and Compliance Council (ROCC), which includes several Corporate Executive Team (CET) members, oversees risk management and internal control activities. The ROCC is supported by GSK’s corporate assurance department and corporate ethics and compliance department. GSK’s corporate compliance officer, who chairs the ROCC, regularly reports on significant risks to the CET and the Audit Committee of the Board.

For more information on risk management see the corporate governance section of our Annual Report.

Monitoring for sales and marketing
Sales representatives are supervised by their managers who regularly monitor educational events, visits to doctors and expenses. We use a risk-based approach to determine the frequency of our checks on different districts and individual sales representatives.

In the US, sales representatives that receive inquiries from physicians about off-label uses of GSK products must notify our medical information department, which responds to the inquiry via a medical information letter. Sales representatives must not solicit off-label questions from physicians. Frequent medical information letter requests by a sales representative can indicate that the employee is prompting questions and promoting off-label uses of GSK products. We monitor requests for medical information letters. Our internal audit department regularly audits our sales and marketing practices globally.

Monitoring for payments to healthcare professionals and organisations
Payments are recorded and monitored in different ways in different countries. For example, in the US we have introduced a state reporting system for expenditure with healthcare professionals, in line with legislation in several US states. In Japan, payments to individual healthcare professionals and medical institutions are monitored on a quarterly basis and the results are reported to promotion compliance officers and our internal audit department

These systems help us to identify situations where excessive meals and gifts may have been provided by GSK.

Reporting channels
Employees are encouraged to seek help on ethical issues and to report any concerns or suspected cases of misconduct. They can do this through their line manager, the Corporate Ethics & Compliance department, a compliance officer or compliance champion, GSK’s Human Resources and Legal departments, or through our Global Confidential Reporting Line or the Integrity Helpline in the US. In the US, employees can also report concerns through an offsite post office box or via email.

Reporting channels are promoted through the Employee Guide to Business Conduct, on the GSK intranet and during training.

Addressing misconduct
Our Corporate Ethics & Compliance department monitors and tracks allegations and suspected legal, ethical or policy infractions. It ensures that all such allegations are appropriately investigated. Disciplinary action, up to and including dismissal, is taken where necessary. Serious violations of our policies are reported to the Audit Committee of the Board.

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