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Our behaviour reflects our culture and is focused on realising our purpose

Operating responsibly

We expect our employees and the third parties we work with to act per our values – patient focus, integrity, respect for people and transparency. We want to understand and, where possible, exceed society’s expectations of us. We have changed the way we do business, often going beyond industry norms, to further embed our values.

Ethics and values

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 global Code of Conduct which outlines how all employees should apply our Values and Behaviours, and our global Code of Practice for Promotion and Scientific Engagement, 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.

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. For more detailed information on our approach to ethical conduct and our performance, see our global Annual Report.

Working with third parties

The standards we expect of suppliers are set out as Principles in our global Working with Third Parties policy. 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.

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 our global Annual Report  and our global Modern Slavery Act statement.

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. 

Our engagement with HCPs

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 - PDF (214 KB) about how we engage with healthcare professionals.

Our sales and marketing practices

Creating a sales force that puts patient needs first

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.

Sales and marketing practices of GSK

Code of Practice for Promotional and Nonpromotional External Interactions

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

Changing the way we engage 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.

Research practices

We make sure we carry out our research to high ethical and quality standards.

Investment in R&D is at the core of our business and we make sure we carry out our research to high ethical and quality standards. We aim to address any concerns by being open about our research and regularly engaging with academic scientists, regulators, policymakers and other stakeholders.

Research practices of GSK

Transparency of our research

The safety and effectiveness of new medicines must be demonstrated through clinical trials. Providing greater access to data from these trials - regardless of whether the results might be considered positive or negative - allows others to conduct further research. This also helps us ensure we maximise the contribution made by the thousands of volunteers and patients participating in our studies.

Since 2004, we have had an online clinical study register where we make available information on our trials, including summaries of results. For the past number of years, we have led the industry in sharing information and data about trials to advance medical science and patient care. We were the first company to make Clinical Study Reports publicly available. These formal reports are the basis of submissions to regulatory agencies and include detailed information on the design, methods and results of our trials. We post them on our clinical study register with patients’ personal information removed.

We were also the first pharmaceutical company to sign up to the AllTrials campaign for trials to be registered and results reported.

Ethical conduct

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.

Ethical conduct of GSK

Our compliance programmes embed the same standards across all our business units in different countries. These include our Code of Conduct - PDF (3.2 MB) which outlines how all employees should apply our Values and Behaviours, and our Code of Practice for Promotion and Scientific Engagement - PDF (214 KB), 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.

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.

Anti-Bribery and Corruption Policy

For more detailed information on our approach to ethical conduct and our performance, see our GSK Policy on Preventing Corrupt Practices and Maintaining Standards of Documentation.