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Ethics and values

Find out how we ensure we act ethically and with integrity throughout our businesses.

Ethical conduct is a priority for GSK and we are committed to performance with integrity. We have robust policies and compliance processes covering all our operations, including the way we reward our sales representatives, how we market our medicines and vaccines, and how we work with stakeholders.

Our compliance programmes embed the same standards across our business units in different countries. These include our Code of Conduct which outlines how all employees should apply our Values and Behaviours, and our Code of Practice for Promotion and Scientific Engagement (PDF), which applies to all employees involved in sales and marketing as well as third parties acting on our behalf.

We expect all our employees and suppliers to live our values. Mandatory annual training ensures our people know our Code of Conduct, and we measure their performance not just by what they deliver, but how they deliver them in line with our values.

Catrina, employee, in an office at GSK China, in Shanghai
Catrina, GSK China

All GSK employees have access to whistleblowing mechanisms that they can use to get advice and to report suspected cases of misconduct – anonymously if required.

Anti-bribery and Corruption

We have zero tolerance for bribery or corruption in any form. Our Anti-Bribery and Corruption (ABAC) programme includes risk assessments, standards and additional training for people working in high risk areas. Since 2016, we also carry out anti-bribery and corruption training for third parties, seeking to ensure that the third parties we work with have the appropriate risk awareness and therefore ability to manage it. For more detailed information on our approach to ethical conduct and our performance, see our Annual Report (PDF-5.43MB).

Working with third parties

Our suppliers and other third parties – including agents, distributors and affiliate companies (where we have an equity stake) – help us research, develop, manufacture and distribute the medicines, vaccines and other products that patients and consumers need. GSK’s supply chains are complex and have significant scale – we spend billions of pounds with tens of thousands of suppliers on a wide range of goods and services. It is essential that we have strong relationships with suppliers and third parties that are critical to our business and work with those that share our values and operate in a responsible and ethical manner.

gsk environment
Maintenance engineers, Ware UK

Selecting suppliers which can ensure a continuous supply of materials of the appropriate quality is critical, as is controlling the conditions in which products are transported. Maintaining resilient supply chains is particularly important because changing suppliers, especially those that are part of a regulatory dossier, can be complex, slow and expensive.

The standards we expect of suppliers are set out as Principles in our Working with Third Parties policy (PDF). All third parties must meet our anti-bribery and corruption and labour rights standards and, where relevant, we expect them to comply with our standards on quality, health and safety, and the environment.

Bob Lea in a warehouse
Bob Lea, supply chain leader, Ware UK

We have implemented a comprehensive third party oversight programme to strengthen our management of risk in the supply chain. The aim is to ensure that all third parties are risk assessed against the Principles, and contracts amended as necessary. With a large supplier base, we need to focus our effort on working with those at highest risk of non-compliance with our standards on responsible business. Read more in the Annual Report (PDF-5.43MB) and our Modern Slavery Act statement 2021 (PDF-210KB).

Our supply chain team continues to manage and regularly assess the performance of the suppliers that support our manufacturing, specifically on quality and ethical, environmental, health and safety (EHS) management systems. On completion of all audits, we identify areas for improvement, work with suppliers to develop improvement plans and check the plan is implemented within an agreed time frame. If a significant concern is identified, we may suspend or terminate our work with an existing supplier, or decide not to work with a potential new supplier. 

Supporting suppliers  

We have a responsibility to support our suppliers by paying on time. We have put in place an exception to our standard payment terms for small and medium-sized companies in the UK, and small diverse suppliers in the USA. You can find out more about this initiative on the getting paid section of our supplier website. We also have a number of other initiatives underway to continuously improve the experience of suppliers who work with us. As part of our commitment to diversity and inclusion, we support suppliers run by groups that are under-represented in the supply chain such as those owned by women, minorities and disabled veterans. Through our supplier diversity programmes, we engage with and mentor small and diverse businesses in our supply chain, and help them identify potential areas for growth.  

Our engagement with HCPs

We understand that our role in providing HCPs with new data and information about our medicines, must be done clearly and without any perception of conflict of interest. We believe that transparent scientific dialogue and engagement with experts is in the interests of all those working to develop new medicines, improve clinical practice and care for patients. These are the principles that underpin our policy of engagement with HCPs and we remain fully committed to them.

Find out more about how we engage with healthcare professionals.

Sales and marketing practices

Our Pharmaceutical and Vaccines sales representatives around the world are incentivised based on a range of measures that allow us to attract and retain the best sales force talent, so as to ensure that we have high-quality dialogue with HCPs to help them better serve patients. Our sales and marketing practices uphold our ethical and values-led approach to HCP engagement, in full compliance with laws and policies, whilst supporting delivery of strong performance.

Our sales and marketing employees, along with relevant third parties, must follow our Code of Practice for Promotion and Customer Interactions.

Find out more about our incentive programme for sales representatives.

Meet Adriana - Primary Care Sales Rep, Brazil

Adriana works in our Brazil commercial business as a sales manager and describes how her role at GSK ensures that patients remain at the heart of everything we do. Adriana also explains her career progression with the company through a leadership development programme in Brazil that she was selected for.