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Codes and standards

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 GSK Code of Conduct

Equal and Inclusive Treatment of Employees

As detailed in our Code of Conduct, we do not tolerate harassment, unwelcome, unreasonable or offensive behaviour or discrimination of any kind. Our Equal and Inclusive Treatment policy is designed to help our employees and complementary workers understand their role in ensuring GSK is a company where all employees are treated equally.

Anti-Bribery and Corruption (ABAC) Programme

The Anti-Bribery and Corruption (ABAC) Programme is part of GSK’s response to the threat and risk of bribery and corruption. The programme includes an ABAC Policy and Standard, which have been designed to help staff and external parties understand bribery and corruption risk, and their responsibilities to actively combat it.

Binding Corporate Rules

Our human resources and research and development activities involve the processing of “personal information”, including the transfer of that personal information internationally.  We have adopted Binding Corporate Rules (BCRs) to enable us to make international transfers of personal information within our group of companies in compliance with data protection laws of the European Union, in particular the General Data Protection Regulation (Regulation 2016/679) (GDPR).

Find out more about GSK’s Binding Corporate Rules

Third Party Oversight Programme

Our Third Party Oversight Programme helps control risks from third party business engagements with suppliers, distributors and other business partners. We want to work with business partners who share our commitment of high ethical standards and operating in a responsible way.

GSK’s public policy statement on Working with Third Parties sets out our expectation that Third Parties will:

  • Share our commitment to high ethical standards
  • Comply with all applicable laws and regulations and adopt, at a minimum, GSK’s Anti-Bribery & Corruption and Labour Rights Principles
  • Where relevant, comply with our standards on quality, patient safety, health and safety and the environment
  • Create a culture which supports staff reporting of suspected violations of law, rules and regulations, as well as of unethical conduct, without fear of reprisal or retaliation.

Promotion and Scientific Engagement


GlaxoSmithKline plc - Specialised Disclosure Report

GlaxoSmithKline plc and GlaxoSmithKline Capital plc Euro Medium Term Note Programme

GlaxoSmithKline Capital plc Annual Reports

UK Pension Schemes Statements of Investment Principles (SIP)

The links below will allow you to download the Statements of Investment Principles for the main UK pension schemes.

The contents of these documents are set out under UK law and cover the investment policies of the schemes in the following broad areas:  Risk Measurement and Management, Implementation and Governance. The documents also provide details of the asset allocation of the investments.

The Statements have been agreed by the Trustee Boards on the basis of written advice from their appointed external investment advisers and lawyers.  There is a consultation process on the SIP with the participating employers as required by law.

The Statements are reviewed by the Trustees annually and also if there are any significant changes to the investment policies.

The Trustees monitor compliance with this statement at least annually.  Fund manager activity is reviewed quarterly through reports prepared by investment consultants. Additionally, meetings are held with fund managers at least annually to review the activities and compliance with their contractual terms and with the Statements of Investment Principles.

Socially Responsible Investing

Socially Responsible Investing (SRI) is most commonly understood to mean investing in a manner that takes into account the impact of investments on wider society and the natural environment, both today and in the future. The Trustee of the GSK Pension Plans annually reviews its SRI policies as part of the Trustee business planning process, and the GSK Pension Plans publish ‘Statements of Investment Principles’ which provide a high level overview of the SRI policies.

The Trustee aims to be an engaged and responsible long-term investor in the assets and markets in which it invests. The Trustee believes that the integration of environmental, social and governance (ESG) factors within investment managers’ investment processes is not detrimental to the risk and the sustainable long-term expected returns from pension schemes’ investments.

The Trustee does not wish to interfere with the day to day investment decisions of its investment managers. However, the Trustee does encourage its investment managers to comply with the principles outlined in the UN Principles for Responsible Investment and the UK Stewardship Code where this is appropriate for their mandate, as well as to take into account ESG considerations in the selection, retention and realisation of investments in so far as this is consistent with their overall objectives.  

The Trustee regularly reviews the voting strategy of its investment managers. The Trustee also supports the principle of shareholder activism and, for relevant mandates, prefers its investment managers to have an explicit strategy, outlining the circumstances in which they will engage with a company on ESG matters and how they will measure the effectiveness of this strategy.

For GSK Pension Plans, the majority of the assets are managed by Legal and General Investment Management (LGIM). In particular, a portion of the Plans’ equity portfolio follows a low carbon investment philosophy by re-weighting away from carbon intensive assets. Companies with significant carbon emissions as well as those with large fossil fuel reserves are underweighted which, in turn, reduces the Plans’ carbon footprint as well as stranded asset risk. Overall, the mandate’s carbon footprint is around three-quarters lower than that of the parent index (MSCI World). Additionally, LGIM complies with the principles set out in the UK Stewardship Code and LGIM are also a signatory to the UN Principles for Responsible Investment. In addition, LGIM maintain a large, dedicated team which is responsible for ESG monitoring and which is actively engaged in encouraging companies to improve their ESG standards.

A detailed review of LGIM’s ESG activities, including examples of LGIM’s engagement activities with companies, can be found in the Corporate Governance Report below.






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