GSK Standard Title: Reporting of Misconduct Procedure

Operating Procedure
Official Short Title:

Key Points
 GSK employees are required to promptly raise concerns of possible misconduct, potential
conflicts, or known breaches with the GSK Code of Conduct, and other company policies
and procedures. Suspected violations of country laws and regulations where we operate
must also be reported.
 Non-GSK personnel working on behalf of the company are also required to report
misconduct concerns, with ‘Speak Up’ integrity line information provided in the GSK Third
Party Code of Conduct.
 GSK will take disciplinary action up to and including termination, in accordance with local
labour laws, against anyone who threatens, or engages in retaliation or harassment of any
person who has reported, or is considering reporting a concern in good faith.
 Countries with reporting limitations should follow local labour law requirements.
Why do we have this SOP?
To deter and detect business misconduct at GSK, and ensure concerns of unethical or
illegal conduct are raised at an early stage in a responsible and confidential manner
without fear of retaliation.
Who in GSK has general
What does this SOP say? obligations under this SOP?
1. Purpose All GSK Staff
2. Scope
What functions in GSK have
specific obligations under this
SOP?
3. Responsibilities Audit, Compliance, & Quality
4. Staff Conduct Requirements Communications
5. Reporting of Misconduct Govt. & External Affairs
6. Reporting Channels Finance
Global Procurement
7. Fraud Reporting
HR
8. Safeguarding Personnel that IT
Report Misconduct Legal
9. Misconduct Investigation Manufacturing & Supply
Process Marketing, Sales & Support
10. Communication of Issues Medical
Research/Development
Supervisors & Management
Senior Management
Corporate Security & Invest.

Glossary Administration
Contacts:
Waivers Appendices Corporate Ethics & Compliance
1-866-GSK Ethics
Related Documents

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The Basics
1. Purpose
This Standard Operating Procedure (SOP) supports GSK’s Code of Conduct and all
policies requiring the reporting of unethical or illegal conduct, and is designed to
encourage internal reporting of misconduct related to GSK’s business so that it can be
investigated and, if appropriate, have corrective action taken.
It also supports GSK’s Values and “Speak Up” culture by taking proactive steps to ensure
that employees who raise concerns in good faith are safeguarded and supported in the
workplace by prohibiting retaliation against employees who raise their concerns.

2. Scope
The intended audience for this SOP are all GlaxoSmithKline (GSK) employees and
complementary workers (contingent/contracted staff) working for, or on behalf of the
company.
Mandatory requirements contained in this procedure must be implemented at all GSK
Business Units and Functions covered by the document scope.

The Specifics
3. Responsibilities

3.1. Staff Responsibilities

All GSK employees and contingent staff must comply with the requirements of this SOP
in conducting Company business.
If a decision about a particular action is not covered within this procedure, personnel
must seek guidance from their supervisor, Human Resources, GSK Legal or a
Compliance Officer.
Failure by any Staff, including managers or supervisors who ignore prohibited conduct,
or have knowledge of misconduct and fail to correct it, or to comply with this or any
GSK policy will be subjected to disciplinary action up to and including separation from
the Company in accordance with local labour laws.

3.2. Management Responsibility

Senior management should be a role-model for these requirements by visibly
demonstrating support for, and regularly encouraging adherence of reporting by staff.
Managers should ensure all their employees receive guidance, training and
communication on ethical behavior and legal compliance relevant to their duties for the
Company.

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4. Staff Conduct Requirements
As GSK employees, we must hold ourselves, our teams, and any GSK associates we
work with accountable for abiding by our Code of Conduct, company policies and
legal/regulatory requirements. We are empowered, and required, to promptly raise
concerns of possible misconduct, potential conflicts, or known breaches with company
policies, procedures, and suspected violations of country laws and regulations. This
includes the potential misconduct of fellow employees, complementary workers,
consultants, vendors, and partners with whom we jointly do business (including co-
promote entities).
Ideally, concerns should be raised before problems develop. By stepping forward and
raising concerns, we fulfil our responsibilities as employees to do the right thing. Non-
GSK personnel working on behalf of the company are also encouraged to report
misconduct concerns.
Accordingly, All GSK staff must:
 Become familiar with, and comply with legal and regulatory requirements and
Company policy and procedures;
 Promptly report to the Company any violations of law, ethical principles or
Company policies that come to staff’s attention, and cooperate fully in any audit,
enquiry, review or investigation by the Company; and
 Provide the Company’s External Auditor with access at all times to the
Company’s records and accounts (in whatever form they are held) and provide
additional information as requested by the External Auditor. If such requested
information is legally privileged Staff must contact the Legal Department before
responding to the request.

5. Reporting of Misconduct
As a requirement of our GSK Code of Conduct (POL-GSK-001), GSK seeks to deter and
detect unethical or illegal conduct which an individual believes are taking place to ensure
issues are raised at an early stage in a responsible and confidential manner. Examples of
such concerns may include, but are not limited to:
 Corruption, bribery or blackmail;
 Fraud;
 Other criminal offences;
 Discrimination or harassment;
 Conflicts of interest;
 Failure to comply with legal or regulatory obligations;
 Failure to comply with GSK policies or procedures;
 Endangering the health and safety of any individual;
 Damage to the environment; and
 Attempted concealment of information relating to the above.
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Any genuine misconduct concerns raised in good faith will be thoroughly investigated
with appropriate actions taken based on the outcome. GSK will provide feedback to the
person who has raised the concern to the extent that it is appropriate and can be done
without violating legal requirements or other duties of confidentiality.

We are all responsible for, and required to promptly report unethical and illegal conduct
through the appropriate reporting channels.

GSK will protect Staff who report, or consider reporting unethical and illegal conduct
from retaliation, retribution and any form of harassment directed against them.

6. Reporting Channels
All personnel must promptly raise concerns about unethical or illegal conduct which they
believe may be taking place. All such concerns should be raised through the appropriate
reporting channels listed below, in accordance with local privacy laws.
6.1. In the first instance, a concern should be reported to Staff’s immediate supervisor
or line manager or any executive directly senior to the person making the report.
A supervisor or manager who receives the report should take necessary and
appropriate follow-up action or seek action from one of the groups listed below.
6.2. If it is inappropriate to report the concern to line management because they are
part of the perceived misconduct, or if the concern persists after reporting to line
management, the concern should then be raised to someone in a suitable function,
such as the following:
 Corporate Ethics & Compliance
 Audit and Assurance
 Human Resources
 Corporate Security & Investigations
 Sustainability & Environment
 Health, Safety and Performance
 Legal, or
 Finance Directors
6.3. Staff may also report a concern anonymously if preferred, through the following
methods:
Online: www.gsk.com/integrity
Phone: US 1-866-GSK-ETHICS (1-866-475-3844)
Phone: Global Speak Up Integrity Line Numbers
Mail: PO Box 58572, Philadelphia, Pennsylvania 19102

Reporting details are available on the GSK Code of Conduct Resource Centre or
externally on gsk.com.

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 Local Policies and Procedures may contain details of locally customised reporting
channels as appropriate, in accordance with local privacy laws.
All instances of reported unethical or illegal conduct, violation of company
policy, or breach of legal and regulatory requirements must be documented
within a controlled case management environment (GSK systems used for
tracking and reporting allegations and investigations).

7. Fraud Reporting
Specifically with regard to reporting fraud, personnel are required to report any suspected
or actual fraud, regardless of materiality to the following:
 Corporate Security & Investigations (contact details and an electronic fraud
reporting tool are available through the Corporate Security & Investigations
intranet site and
 the local Finance Director or equivalent (unless suspected of involvement).
You may also report fraud through the reporting channels listed above (anonymously if
preferred).

8. Safeguarding Personnel that Report Misconduct

GSK encourages internal reporting of concerns to support GSK’s Values and policies and
will take proactive steps to ensure that employees who raise good faith concerns are
safeguarded, supported in the workplace, [and recognized, as appropriate].
GSK has standard procedures for investigating and managing cases of unethical and
illegal conduct which must be followed. These standard procedures include GSK’s
commitment to taking active steps to safeguard, support, [and recognize as appropriate]
employees who have reported a concern. Managers or other staff involved in the
investigation or management of these cases should contact their business area HR,
Compliance, Corporate Security & Investigations, or Legal representatives for more
information.
9. Non-Retaliation
GSK managers, supervisors and pesonnel must NOT engage in retaliation, retribution or
any form of harassment directed against staff who have reported, or are considering
reporting, a concern. Any manager, supervisor or employee who engages in such
retribution, retaliation or harassment is subject to discipline, up to and including
termination from the company. For contractors, such actions may lead to the termination
of the contract under which their services are provided to GSK in accordance with local
labour laws.
Reporting a concern will not provide immunity for misconduct engaged in by the
individual making the report, but prompt and forthright disclosure and cooperation will

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generally be considered a mitigating factor in determining any consequences to the
reporting individual in accordance with local legal standards.

10. Communication of Issues

Questions or concerns around this procedure should be raised to Global Ethics &
Compliance Operations, your business area Compliance Officer, Human Resources or
Legal.

Glossary & Administration

Glossary
Fraud: The legal definition of fraud varies from country to country but in most cases the
key elements are: dishonesty, deception, and the intention of obtaining an undue benefit;
avoiding an obligation; causing loss to another party; removal of funds; or
misrepresenting the financial position or affairs of the entity. Some types of fraudulent
activity include: Fraudulent financial reporting; Misappropriation of assets;
Bribery/corruption; Conflict of Interest; Inflated or false expense claims; fraudulently
avoiding costs and expenses.
Administration

Approval: Risk Oversight and Compliance Council (ROCC)

Owner: Simon Bicknell – SVP, Governance, Ethics & Assurance

Author: Laurie Snow – Compliance Policy Manager, Global Ethics & Compliance
Operations

Approval
20-NOV-2012
Date:

Effective
01-MAR-2013
Date

History: 01-MAR-2013: SOP-GSK-003 v01: This SOP supersedes the Internal

Reporting of Unethical & Illegal Conduct section of the Code of Conduct
POL-GSK-001 v07 and the Standards of Conduct STD-GSK-001 v02
retired in August 2012.

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Waivers
Any requirement of this Corporate SOP may be waived conditionally on a case-by-case
basis in very exceptional circumstances with written indication from the Corporate
Compliance Officer as approved by the SOP sponsor and ROCC. All requests for
exceptions/exemptions should be directed to Corporate Ethics & Compliance (CEC).
Once approved, these exceptions will be recorded by CEC and posted on the Corporate
Ethics & Compliance web community for visibility. The approved exception
author/sponsor is required to notify all relevant GSK employees, contractors and third
parties of the granted exception.
Related Documents
GSK Code of Conduct (POL-GSK-001)
Preventing Corrupt Practices & Maintaining Standards of Documentation (POL-GSK-
007)
Safeguarding People Who Report Unethical or Illegal Conduct (SOP-GSK-015)
Procedure for the Conduct of Internal Investigations (SOP-GSKF-522)
Appendices
None

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