Living Our Values And - GSK
Living ourvalues andexpectationsOur code of conduct
ContentsOverviewOverview3 Introduction4 O ur code of conduct –overview1.Our patients,our consumers,our industry2.Our company1.Our patients,our consumers,our industry4 L iving our values andexpectations11 P rotecting our patientsand consumers5 Our values and expectations12 Conducting research ethically6 H ow can our values andexpectations help us make theright choices?12 M anaging the quality of ourproducts effectively7 I ndustry regulations andlaws are vital to our work3.Our colleagues4.Our worldMoreinformationGlossary2.Our company3.Our colleagues4.Our world14 Gifts or hospitality18 A cting with individual integrityand courage22 O ur commitmentto human rights19 A healthy and safeworkplace22 M eeting our challengingsustainability targets20 Our colleagues22 W orking with widercommunities14 F ollowing the right financialprocedures14 Treating suppliers fairly15 M anaging records properlyMore information23 W here to findmore informationGlossary24 Glossary16 Safeguarding GSK assets16 W e are all stewards of ourreputation7 I mplications of not followingthis code of conduct8 U sing your voice: How tospeak up8 Zero tolerance for retaliationLiving our values and expectationsOur code of conduct2
ContentsOverviewIntroduction1.Our patients,our consumers,our industry2.Our company3.Our colleagues4.Our worldMoreinformationGlossary“ Our values and expectations are at the heartof everything we do. They define our codeof conduct and guide all who work for or onbehalf of GSK.“ Our values and expectations are more than just words. Together they help guide us toour goal to be one of the world’s most innovative, best performing and trusted healthcarecompanies. They shape our culture and guide our actions and decision making, so wecan maintain the trust of the people who rely on us each and every day – our patients andconsumers. It’s up to all of us, every day, to keep GSK the kind of company we can all beproud of.”Emma Walmsley,CEOLiving our values and expectationsOur code of conduct3
ContentsOverview1.Our patients,our consumers,our industryOur code ofconduct – overview2.Our company3.Our colleagues4.Our worldMoreinformationGlossaryAt GSK, we believe it’s not just whatwe achieve that counts, it’s also howwe achieve it.We believe in making good choices andtaking responsibility and accountability forthem, so that we can become one of theworld’s most innovative, best performingand trusted healthcare organisations, andpositively impact the lives of our patientsand consumers. It goes beyond simplyfollowing laws and rules.Living our values and expectationsEveryone who works for or on behalf ofGSK must abide by the law, but our codeof conduct goes beyond that. It alsoestablishes the standards and policiesthat help us meet the commitments of ourheavily regulated industry and work asa high performing team. Our values andexpectations help define us, build trustwith society and direct us to do the rightthing every day.This guide will help you to:If you can connect to the GSKinternal network, you can usekeywords to help find policieswithin the Our written standardsresource centre on Connect GSK.1. Understand our valuesand expectations2. Use them to guide our everydayactions and decision making3. Understand our core standardsthat uphold ethical behavioursLook for this icon for furtherinformation.Living our values and expectationsOur code of conduct4
ContentsOverview1.Our patients,our consumers,our industry2.Our company3.Our colleagues4.Our worldMoreinformationGlossaryOur valuesand expectationsOur values andexpectations work handin hand to guide ouractions and decisionmaking, so we canbecome one of theworld’s most innovative,best performing andtrusted healthcarecompanies.Our values:Our expectations:We are proud of our values. They are non-negotiableand inform everything we do.To thrive in an ever-changing world and achieve ourpurpose, we need to adapt some of our behavioursto keep us competitive, all while staying true to ourvalues. That’s why we have our four expectations.Patient focus is about always doing the right thingfor patients and consumers and striving for thehighest quality.Transparency helps us build trust with each other andwith society by being honest and open about how andwhat we do.Respect means supporting colleagues and thecommunities around us, and embracing diversity andindividuality, so we can all achieve great things.Integrity is about how we expect the highest ethicalbehaviours of ourselves and others.Courage means setting high ambitions, setting anaccelerated pace, making decisions even when it’s difficultand speaking up when we see an opportunity to improve.Accountability is about taking ownership, prioritisingwork that supports our strategy and delivering whatwe promise.Development encourages us to bring the outsidein and learn from others, and to ask for and givefeedback, so we can continually grow as individuals,teams and as an organisation.Teamwork is about all of us working better togetheron aligned objectives, understanding how our workcontributes to our Innovation, Performance and Trustpriorities, encouraging diversity of thinking and inspiringeach other.Living our values and expectationsOur code of conduct5
ContentsOverview1.Our patients,our consumers,our industry2.Our company3.Our colleaguesHow can our valuesand expectations helpus make the rightchoices?4.Our worldMoreinformationGlossaryWhen faced with a choice or dilemma, ask these questions:While GSK’s written standards help all of usaddress the significant risks we face, it’s notpossible to cover every eventuality.What to keep in mind when taking actionor making a decision:Is it aligned withour values andexpectations?Does it meetregulationsand laws?Is it consistentwith our policies?Have I assessedall the risksinvolved? Our values and expectationsWill this beclearly understoodby a colleague?Would I behappy with thisif I were a patientor consumer? Appropriate regulations, standardsand laws Tools to help us assess, treat, monitorand manage risk The possible impact on our patients andconsumers, our company and ourselvesYesYes: It looks like a good decision but if you have anydoubts, talk to your manager.NoNo: I f the answer to any of these questions is ‘no’, thenthink again about what to say or do, talk to your manager,or use the reporting channels to speak up.Living our values and expectationsOur code of conduct6
ContentsOverview1.Our patients,our consumers,our industryIndustry regulationsand laws are vitalto our work2.Our company3.Our colleagues4.Our worldWe are committed toabiding by country lawsand regulations thatapply to our companyacross the world.MoreinformationGlossaryWhen local laws, regulations, applicableindustry codes or other business specificGSK standards are stricter than our globalwritten standards, we work to comply withthe strictest requirements. For example, wefollow the UK Bribery Act (2010) and the USForeign Corrupt Practices Act (1977) acrossour global company, as well as individualcountries’ competition laws, wherever weoperate. Complying with these regulationsensures we compete on equal terms withno unfair advantages.If you are unsure about the impact ofdifferent countries’ laws on your localactivities, check with your aligned GlobalEthics and Compliance (GEC) and/orLegal representative(s). For moreinformation on Our written standardsvisit Our written standards resourcecentre on Connect GSK.Implications of not followingthis code of conductOur corporate standards and policies applyto everyone who works for or on behalf ofGSK. Failure to comply with them or anyapplicable legal and regulatory requirementsmay result in disciplinary action, up to andincluding dismissal or termination of contractor assignment. For senior managers, thiscould include financial recoupment forsignificant misconduct. Managers also havethe responsibility to ensure their teamsunderstand and follow this code of conductand applicable written standards.Subject to local requirements, violations ofthis code of conduct by agency workers willbe reported to their respective agencies.Violations of the code of conduct by allother complementary workers may resultin termination of contract (subject to localrequirements).Living our values and expectationsOur code of conduct7
ContentsOverview1.Our patients,our consumers,our industry2.Our company3.Our colleagues4.Our worldMoreinformationGlossaryUsing your voice:How to speak upZero tolerance for retaliationWhen we all do the right thing and live ourvalues and expectations, we build trust inGSK and protect our licence to operate.We are each accountable for speaking up ifwe have a concern, or see something that’snot in line with our values and expectations.The first step is to speak with a line manager,or if that’s not possible, contact your HumanResources, Global Ethics and Complianceor Legal representative.GSK treats all questions and issuesconfidentially, where possible, whileinvestigating fairly, cooperating withgovernments and complying with legalobligations. When someone reports aconcern in good faith, GSK will supportthat individual.If you feel unable or uncomfortablediscussing an issue with a manager or analigned representative, you can use thetelephone, internet or postal reportingchannels. These channels are managedindependently of GSK, are available globallyand allow for reports to be kept anonymousif the local laws and regulations permit it.Managers also have a duty to raise anyconcerns brought to their attention. Thosewho ignore violations, or who fail to detect orcorrect them, could face disciplinary action.Remember, by speaking up and raisingconcerns, you are living our values andexpectations and doing the right thing.www.gsk.com/speakupOption 1Speak to your managerOption 2At GSK, you can report concerns withoutfear of reprisal. GSK prohibits retaliationagainst anyone who raises or reportsconcerns and will take disciplinaryaction up to and including dismissal(in accordance with local labour laws)against any employee who threatensor engages in retaliation or harassmentof someone who has reported, or isconsidering reporting, a concern ingood faith.Similarly, we will report an agency workerwho retaliates against anyone raisinga report or concern to the worker’semployment agency and terminatetheir assignment with GSK.Raise a concern with local management,Human Resources, Global Ethics andCompliance or LegalOption 3Report confidentially online, by telephoneor by email, or submit a report by postLiving our values and expectationsOur code of conduct8
ContentsOverview1.Our patients,our consumers,our industry2.Our company3.Our colleagues4.Our worldMoreinformationGlossaryIn the followingsection, you’ll findsome principlesthat help us to liveour values andexpectations1. Our patients, our consumers,our industryHow we protect patients and consumers andlead our industry.2. Our companyWhat we do to safeguard our companyand its assets.3. O ur colleagues4. Our worldHow we maintain our personal integrityand work with others.How we engage with governments and groups,protect the environment and engage with thecommunities we work in.Living our values and expectationsOur code of conduct9
ContentsOverview1.Our patients,our consumers,our industry2.Our company3.Our colleaguesProtecting our patients and consumers11Conducting research ethically12Managing the quality of our products effectively124.Our worldMoreinformationGlossary1.Our patients,our consumers,our industryMusaid AbdulLatif Al-Ghamdi,ConsumerLiving our values and expectationsOur code of conduct10
ContentsOverview1.Our patients,our consumers,our industry2.Our company3.Our colleagues4.Our worldOur patients, our consumers,our industryWe do the right thing for ourpatients and consumers andstrive for the highest quality. Wework with our partners to improvehealthcare and find new medicinesand vaccines. Regardless of ourrole, we understand how our workaffects patients and consumers.Keywords to search for onConnect GSK Medical governance Adverse event reporting Human safety information (HSI) Code of practice Scientific engagementCode of practice documentsWe have two code of practicedocuments – it’s important to usethe right one: Our code of practice for promotionof prescription medicines and forscientific engagement Consumer Healthcare code forpromotion and scientific engagementMoreinformationGlossaryProtecting our patients and consumersWe gain our patients’ and consumers’ trustby focusing on their needs. That meansalways thinking from their perspective. Weput their safety first, provide them with clear,up-to-date information and promote ourproducts appropriately and ethically.Promotional activities that meet industryand GSK standardsOur promotional activities and materialsconform to high ethical, medical andscientific standards. They are legal,industry‑compliant and evidence based.If local laws, industry codes or GSK policiesset higher standards, we comply with thestrictest requirement.Following the principles ofscientific engagementWe make sure our scientific engagementis clearly distinct from the promotion ofour products, never disguising or misusingour research to influence healthcareprofessionals and others inappropriately.Reporting a concern abouta GSK productAnyone hearing of any information regardinga side effect, adverse reaction or any otherhuman safety concern on a GSK product,including possible lack of effectiveness, mustreport it to the Central Safety Department,or the local operating company medicaldepartment within 24 hours. Human safetyinformation from clinicaltrials is reported as described in thestudy protocol.Preventing counterfeitingCounterfeit medicines and healthcareproducts pose a serious threat to the healthand safety of our patients and consumers.They often lack the active ingredients tocombat the illnesses they claim to treat andcontain impurities that can actively causeharm. We are committed to protecting ourpatients and consumers from counterfeitproducts. That means we are all responsiblefor reporting any suspected counterfeitingof a GSK product.Ensuring product information is accurateWe provide complete, up-to-date andevidence based product information tohealthcare professionals and consumers,wherever they are in the world.Living our values and expectationsOur code of conduct11
ContentsOverview1.Our patients,our consumers,our industryConducting research ethicallyFrom safeguarding patients’ personalinformation to sharing research data, wework to protect our patients and consumersand care for their well being while advancingscience.Keywords to search for onConnect GSK Ethical research Human samples Animal welfare Reporting counterfeiting Clinical trial disclosure2.Our company3.Our colleagues4.Our worldMoreinformationGlossaryFollowing all research protocolsand standardsManaging the quality of ourproducts effectivelyThe safety and well being of patients whovolunteer to participate in our clinical trialsis essential. Following research protocolsand ethical, medical and scientific standardsmeans we protect those who participate inour research to the best of our ability.We strive to assure the safety, quality andefficacy of our products for our patients andconsumers by ensuring that our procedurescomply with Good Practice regulations.Our Good Practice Procedures for ProductQuality are documented in our QualityManagement System and apply everywherewe make, pack and distribute products.Understanding why we provide accessto our research dataWe share expertise, resources, intellectualproperty and know-how with externalresearchers and the scientific communityto help advance science. This includesanonymised trial data, so the valuablecontribution made by volunteers whoparticipate in our research can be usedin other studies. We protect patientconfidentiality and ensure information isused only for valid scientific enquiry.Following Good PracticesProtecting patients means using a rangeof Good Practice quality guidelines andstandards throughout our business, on site,in the lab, in the clinic or in the office. Wemonitor and document our work thoroughly toensure our records are correct and complete.We also monitor our computerised systemssupporting these regulated processes.Following these steps with precisionensures that each element of the processis traceable, accountable and ready forinspection. Adhering to these guidelineshelps us meet regulatory requirements. Moreimportantly, it means our products are of theright quality and that any potential risks topatients and consumers are minimised.We also have a long standing commitment todata transparency. In 2004, we launched aStudy Register which is available to the publiconline. We were also the first pharmaceuticalcompany to sign up to the AllTrials campaignfor clinical trial transparency in 2013.Living our values and expectationsOur code of conduct12
ContentsOverviewTok Lay Mui,Quality Manager1.Our patients,our consumers,our industry2.Our company3.Our colleagues4.Our worldMoreinformationGifts or hospitality14Following the right financial procedures14Treating suppliers fairly14Managing records properly15Safeguarding GSK assets16We are all stewards of our reputation162.Our companyGlossaryLiving our values and expectationsOur code of conduct13
ContentsOverview1.Our patients,our consumers,our industry2.Our companyOur companyIn this section, we look at how weprotect our company, assets anddata when we interact with ourpartners and suppliers.3.Our colleagues4.Our worldMoreinformationGlossaryGifts or hospitalityFollowing the right financial proceduresLike any business, we sometimes give andaccept gifts, hospitality or entertainment.In every case, we must consider if it isappropriate. Think about whether the gift orhospitality could be misunderstood or seenas a bribe. Before offering or acceptinganything make sure it fits our policy, is normalin business relationships and is unlikely toinfluence the other person’s or your owndecision making.GSK’s financial, accounting and procurementcontrols are designed to ensure that we donot mislead investors, legislators, authoritiesand the public about financial aspects ofour company.If it is linked to a sale, seen as excessive,or seen as a bribe then do not offer or accepta gift or hospitality.When buying goods and services, we followthe correct procurement procedures and wehave the appropriate approvals accordingto the Grant of Authority policy beforecommitting to the purchase.Treating suppliers fairlyWe rely on suppliers to enable us to dobusiness. Working with Procurement andfollowing set processes helps ensurethat we use preferred suppliers and thenecessary purchase orders are raisedin advance.Keywords to search for onConnect GSK Conflicts of interest Meetings and catering Buying goods and services Grant of Authority Gifts, hospitality and entertainmentLiving our values and expectationsOur code of conduct14
ContentsOverview1.Our patients,our consumers,our industryManaging records properlyThe way we manage records could affectour business, our patients and consumersand our reputation. That means we shouldsafeguard personal information, keep recordsup to date and gather market and competitorinformation in the right way.Safeguarding personal informationWe have a duty to protect the personalinformation (PI) that we collect and retainabout people to ensure it is not misused,from clinical trial patient data to employeepayroll information.2.Our company3.Our colleagues4.Our worldGood record keeping helps us protectpersonal information and intellectual property,comply with legal, financial and regulatoryrequirements, and avoid unnecessary costs.However, we should not keep records andinformation longer than necessary to meetregulatory and business requirements.Collecting competitiveintelligence ethicallyKeywords to search for onConnect GSK
Living our values and expectations 3 Our code of conduct Introduction “Our values and expectations are at the heart of everything we do. They define our code of conduct and guide all who work for or on behalf of GSK. “Our values and expectations are more than just words. Together they help guide us to
Our values and expectations . In 2017, close to 2,000 of our GSK employees dedicated their time to 137 charity projects. Future Leaders . indicated for malaria prevention is finally available for children living in Sub-Saharan Africa. GSK will distribute this vaccine at access pricing and has committed
operate in a responsible and ethical manner. GSK is committed to full compliance with the laws, rules, regulations, and GSK principles and policies governing our activities. To reinforce the standards to which we are committed, GSK developed this Third Party Code of Conduct and expects our Third Parties to:
a rigorous workshop of embedding the GSK values named “Living our Values”, whereby the GSK Values of Integrity, Respect Peoplefor , Patient/Consumer Focus and Transparency were assessed by top management and then revisited by all managers through examples and activities. fellowship program, TFB are preparing participants to become lifelong 16.
At GSK our mission acts as an underlying principle to whatever we do. We follow a legacy of great science and innovative healthcare that provides people around the world with healthier and fulfilled lives, every single day. Our Core Values At GSK Consumer Healthcare, we are committed to delivering results underpinned by our values. These values
in babies and children living with HIV. Our Culture Respect Patient focus Integrity Transparency Our values Our expectations Accountability Development Teamwork Courage GSK at a glance August 2020 Everyone at GSK is focused on our three long-term priorities. How we do it To help millions of people around the world to do more, feel better, live .
to life. Just as importantly, it shows us how living our values helps us fulfil our mission of helping people do more, feel better, and live longer. At GSK, we put our values at the heart of every decision we make. Our values guide our day-to-day actions – no matter what. Because we believe that
maximise the long term sustainability of our business and the communities in which we operate. . rules, regulations, and GSK principles and policies governing our activities. To reinforce the standards to which we are committed, GSK developed this Third Party Code of Conduct and expects our Third Parties to: . values and cultural .
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