- Complying with the UK Corporate Governance Code
- New York Stock Exchange rules
- California compliance law
The Global Compliance function is responsible for supporting the development and implementation of practices that facilitate employees’ compliance with laws and Group policy.
The thrust of our compliance efforts is the promotion of ethical behaviour and corporate responsibility in accordance with our values and due diligence in preventing and detecting misconduct or non-compliance with laws or regulations, supported by effective compliance systems.
Our employees are encouraged to seek help and to report concerns or suspected cases of misconduct without the fear of retaliation. Employees can do this through line management or confidentially through our Speak Up Integrity reporting channels. All concerns and allegations are fairly and independently investigated and disciplinary action, if applicable, is commensurate with the issues presented.
The Global Compliance organisation comprises three groups:
- Global Compliance Business Partners, who are aligned to each business unit. Their role is to proactively partner with senior leaders to drive a values and compliance-based culture and improve risk identification and management practices;
- Global Compliance Operations centrally manages our compliance activities (e.g. analytics, reporting, communications, policy administration, project management and training), with a focus on efficiency, consistency and continuous improvement;
- Global Compliance Investigations co-ordinates all compliance-related investigations, ensuring consistency and efficiency of investigations across geographies and business units.
Global Compliance contact information
|Global Compliance Business Partners||Contact Details|
|Simon Bicknell - SVP, Governance, Ethics & Assurance||
|James Ford - SVP Legal Ops & Compliance Officer - Consumer Healthcare||
|Angela Rodin – VP Compliance Officer, Global Support Functions, Finance & HR||
|Sabina Sudan – VP Compliance Officer – Emerging Markets, Asia Pacific, Japan and Europe||
|Sigrid Willame – VP Compliance Officer – GSK Vaccines||
|Guy Wingate – VP Compliance Officer – Global Manufacturing & Supply||
|Minha Mehta – VP Compliance Officer – Research & Development||
|Michael Shaw – VP Compliance Officer - North America Pharmaceuticals||
Speak Up Integrity lines
Global Ethics & Compliance oversees the GSK Speak Up Integrity Lines through which 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 (PDF) and company policies can be reported using different communication channels. Concerns may be reported anonymously if desired.
A secure, offsite post office box may also be used:
Please do not use the Speak Up Integrity Lines or post office box above for product enquiries or to report adverse events. Visit the contact us page for instructions on where to submit questions on these matters.
GSK's Code of Conduct
GSK's Code of Conduct (PDF) is the foundation for all the company policies. It sets out the fundamental principles that the company values and that employees should apply in their daily work. Supporting the Code of Conduct policy 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. GSK's employee guide to business conduct highlights the Code of Conduct, core compliance policies and provides guidance to employees. It is the responsibility of each employee to implement the code and follow the employee guide to sustain the trust and confidence of all GSK stakeholders.
GSK Code of Conduct translations (PDFs)
|French (European)||Malay||Traditional Chinese|
GSK's Third Party Code of Conduct
GlaxoSmithKline is dedicated to operating in a way that reflects the highest ethical standards, within a framework of principles, guidelines and policies aligned to ethical, social and environmental responsibilities.
To maximise the long term sustainability of our business and the communities in which we operate, GSK strives to conduct business with third parties who share this commitment to high ethical standards and operations, in full compliance with the laws, rules, and regulations that govern our business activities.
As such, GSK’s Third Party Code of Conduct expects Third Parties to:
- Integrate, communicate and apply our company principles
- Operate in full compliance with all applicable laws, rules, regulations, and GSK policies
- Be aware of cultural differences and the challenges associated with interpreting and applying these Principles globally, consistent with the laws, values and cultural expectations of the different societies of the world
- Integrate these Principles into a continual improvement approach that advances Third Party performance over time, and:
- Inform all Third Party employees that they are required to report suspected violations of law, rules, regulations, and GSK policies through appropriate reporting channels such as GSK’s ‘Speak Up’ Integrity Lines as noted above
Third Parties should also reference our general terms and conditions on this website’s Procurement page.
Complying with the UK Corporate Governance Code
Throughout 2013, GSK complied with the provisions of the 2012 edition of the UK Corporate Governance Code (the current Code) that is maintained by the Financial Reporting Council (FRC). We will report our continued compliance in 2014 against the current Code in our 2014 Annual Report and Accounts.
The latest edition of the UK Corporate Governance Code (the new Code) was published by the FRC in September 2014 and applies to UK listed companies with financial years beginning on or after 1 October 2014. We will report compliance against the provisions of the new Code in our 2015 Annual Report and Accounts.
New York Stock Exchange rules
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.
California compliance law
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.