Global Ethics and Compliance
The Global Ethics and Compliance function is responsible for supporting the development and implementation of practices that facilitate compliance with laws and Group policy.
The Global Ethics and Compliance function (GEC) delivers clear and integrated compliance solutions that embed GSK's values (Patient focus, Respect, Integrity, Transparency) and expectations (Courage, Accountability, Development, Teamwork) in order to build trust.
As well as promoting ethical behaviour, GEC prevents and detects misconduct or non-compliance with laws, regulations and our code of conduct, through effective compliance systems.
To deliver its mandate, GEC provides oversight, written guidance, subject matter expertise, strategic advice and other ad hoc support. GEC does this through two organisational routes:
- Global Ethics and Compliance Business Partners work alongside each business and function. Their role is to help protect and enable GSK to deliver competitive performance in the right way – through our values and expectations.
- Global Ethics and Compliance Centres of Excellence that deliver specialist expertise, efficiency, consistency and continuous improvement within the areas of Corporate Security, Risk Management & Operations, Independent Business Monitoring and Investigations.
- Our code of conduct
- GSK speak up
- Contact information
- Complying with the UK Corporate Governance Code
- New York Stock Exchange rules
- California compliance law
Our code of conduct is the foundation of our company policies. It sets out fundamental principles and our values and expectations that staff should apply in their daily work. Underpinning the code of conduct is a range of corporate policies providing specific guidance in areas such as competition law, marketing practices, non-discrimination, share dealing and conflicts of interest. It is the responsibility of everybody who works for or on behalf of GSK to follow the code to sustain the trust and confidence of our stakeholders.
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Ask questions, raise concerns, speak up. We will listen and support you. Go to www.gsk.com/speakup
Our GSK Speak up integrity lines are available to report alleged breaches of legal or regulatory obligations, financial fraud (including accounting internal controls and auditing), or any other alleged contravention of GSK's code of conduct and company policies.
Issues and concerns can be reported using different communication channels and concerns may be reported anonymously if desired.
A secure, offsite post office box may also be used:
“Speak up,” Mailstop 5.5A
PO Box 13398
Please do not use the Speak up integrity lines or post office box for product enquiries or to report adverse events. Visit the contact us page for instructions on where to submit questions on these matters.
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Nick Hirons – SVP, Global Ethics & Compliance
Email: Nick.J.Hirons@gsk.com
UK Phone: +44 (0) 208 047 4501
Veronique Roedolf – VP, Ethics & Compliance – GSK Vaccines
Email: veronique.r.roedolf@gsk.com
Belgium Phone: + 32 10 85 9947
Guy Wingate – VP, Ethics & Compliance – Global Manufacturing & Supply
Email: Guy.AS.Wingate@gsk.com
UK Phone: + 44 183 369 3330
Neil Falkingham – VP, Ethics & Compliance - Global Pharma
Email: neil.e.falkingham@gsk.com
UK Phone: +44 (0) 208 047 4435
Rob MacRae – SVP, Ethics & Compliance - Research and Development, and Legal
Email: Rob.R.MacRae@gsk.com
US Phone: + 1 215 751 7375
Dominique Giulini – VP, Ethics & Compliance - Consumer Healthcare
Email: dominique.x.giulini@gsk.com
US Phone: + 33 (1) 391 76099
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Throughout 2017, GSK complied with the provisions of the 2016 edition of the UK Corporate Governance Code that is maintained by the Financial Reporting Council (FRC). We reported our compliance against the 2016 edition of the UK Corporate Governance code in our Annual Report 2017.
UK Corporate Governance Code – find out more on the Financial Reporting Council website
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The New York Stock Exchange rules permit GSK to follow UK corporate governance practices instead of those that apply to the US, provided we disclose any significant ways in which our practices differ from those applying to US domestic issuers.
A table disclosing differences between GSK's domestic corporate governance practices and those applying to US domestic issuers is included in our Annual Report on Form 20-F (PDF).
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Section 119402 of the California Health and Safety Code requires a pharmaceutical company to adopt a Comprehensive Compliance Program that is in accordance with the US Department of Health and Human Services, Office of Inspector General's "Compliance Program Guidance for Pharmaceutical Manufacturers". We must also comply with the Pharmaceutical Research and Manufacturers of America Code.
Further, the law requires that the Comprehensive Compliance Program includes an annual limit for certain items and activities given to healthcare professionals covered by this California law.
Finally, the law requires that each manufacturer make its Comprehensive Compliance Program and an annual declaration of compliance publicly available.