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Corporate Responsibility Report 2008

Our approach to external affairs

Employees involved in public policy work must abide by our Employee Guide to Business Conduct which is based on three principles:

• Partnership: we are committed to working with governments and regulatory authorities in a constructive way
• Communication: as well as giving our views, we take on board any concerns from external audiences. This enables us to assess and improve our business practices
• Integrity: we base our public policy work on research, analysis and facts. We respect other opinions and look for constructive solutions. All of our external affairs work must be in line with our Code of Conduct and other relevant policies including those related to competition law, preventing corrupt practices and political contributions

We have external affairs teams in our major regions who monitor proposed legislative reforms and policy developments. They meet regularly with government officials and other stakeholders, for example multilateral organisations and NGOs, to explain our views on a range of public policy issues. We tailor our approach to suit different cultures and political traditions in the countries where we engage in the public policy process, while ensuring that our position in these discussions is fully consistent with our public policy statements. We ensure that the standards set out in our Guide to Business Conduct are applied globally.

Lobbying on issues affecting the whole pharmaceutical industry is sometimes conducted through trade associations. We may also hire professional lobbyists to support our public policy work.

We have a Political Contributions Policy governing our contributions to political candidates and parties.

Trade associations

GSK is a member of many trade and industry organisations, including:

• Association of the British Pharmaceutical Industry (ABPI)
• BioIndustry Association (BIA)
• Biotechnology Industry Organization (BIO)
• British Pharma Group (BPG)
• Confederation of British Industry (CBI)
• European Federation of Pharmaceutical Industries (EFPIA)
• International Chamber of Commerce (ICC)
• Intellectual Property Owners Association (IPO)
• International Federation of Pharmaceutical Manufacturers and Associations (IFPMA)
• Japan Pharmaceutical Manufacturers Association (JPMA)
• Organisation of Pharmaceutical Producers of India (OPPI)
• Organization For International Investment (OFII)
• Pharmaceutical Research and Manufacturers of America (PhRMA)

It is important that any lobbying conducted through trade associations reflects our policies and values. We work with other members to help set policies and may also attend lobbying meetings with governments and other stakeholders.

Sometimes we do not share the same views on a particular issue as other members of a trade association. If a trade association adopts a public policy position that we do not agree with, we will not participate in advocacy activity related to that subject. Senior GSK managers sit on the boards of the majority of industry trade associations of which we are members and raise any concerns we may have about a particular advocacy position.

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