Our code

Xiaodan Ji, Material Product of conduct Development Living our values and expectations Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Overview 1. 2. 3. 4. More information Our patients, Our company Our colleagues Our world 3 Our code of conduct – our consumers, 22 Where to find overview 13 Gifts or hospitality 17 Acting with individual integrity 21 Our commitment more information our industry and courage to human rights 4 Our values and expectations 13 Following the right financial 10 procedures 18 A healthy and safe 21 Meeting our challenging Glossary 5 How can we make the right Protecting our patients workplace sustainability targets decision every time? and consumers 13 Working with suppliers 23 Glossary 11 19 Our colleagues 21 Working with wider 6 Industry regulations and Conducting research safely 14 Managing records properly communities laws are vital to our work 11 Managing the quality 14 of our products effectively Handling personal information 6 Implications of not following with care this code of conduct 14 Relevant, up-to-date records 7 Using your voice: and information How to speak up 14 Collecting competitive 7 Zero tolerance for retaliation intelligence ethically

14 Data integrity

15 Safeguarding GSK assets

15 Using Technology Professionally

15 GSK devices for personal use

15 Returning GSK devices

15 We are all stewards of our reputation

15 Using social media

Living our values and expectations Our code of conduct 2 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Our code of At GSK, we believe it’s not just what Living our values and expectations conduct – overview we achieve that counts, it’s also how Everyone who works for or on behalf of GSK must abide by the law, but our code we achieve it. of conduct goes beyond that. It also establishes the standards and policies that help us meet the commitments of our We are a science-led global healthcare heavily regulated industry and work as company with a purpose to improve the a high performing team. Our values and expectations help define us, build trust You can use keywords to help quality of human life by helping people with society and direct us to do the right find related policies in our written thing every day. standards resource centre on do more, feel better and live longer. This Connect GSK. code guides all our actions and is key Look for this icon for further information. to the delivery of our strategy – to bring high-quality healthcare products to as many people as possible, to prevent and treat disease and to keep people well with our scientific and technical knowledge

and talented people. This code will help you to: 1. Understand our values We do this by making good choices and expectations and taking responsibility and 2. Use them to guide your everyday actions and decision making for them. 3. Understand our core standards that uphold ethical behaviours

Living our values and expectations Our code of conduct 3 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Our values and expectations Our values and expectations work hand in hand to guide our actions and decision making, so we can Our values: Our expectations: become one of the We are proud of our values. They are non-negotiable To thrive in an ever-changing world and achieve and guide everything we do. our purpose, we need behaviours that keep us world’s most innovative, competitive, while staying true to our values. Patient focus is about always doing the right thing That’s why we have our four expectations. best performing and for patients and consumers and striving for the trusted healthcare highest quality. Courage means setting high ambitions, setting an accelerated pace, making decisions even when it’s difficult helps us build trust with each other and speaking up when we see an opportunity to improve. companies. and with society by being honest and open about how and what we do. Accountability is about taking ownership, prioritising work that supports our strategy and delivering what Respect means supporting colleagues and the we promise. communities around us, and embracing diversity and individuality, so we can all achieve great things. Development encourages us to bring the outside in and learn from others, and to ask for and give Integrity is about how we expect the highest ethical feedback, so we can continually grow as individuals, behaviours of ourselves and others. teams and as an organisation. Teamwork is about all of us working better together on aligned objectives, understanding how our work contributes to our Innovation, Performance and Trust priorities, encouraging diversity of thinking and inspiring and doing everything we can to make sure we include each other.

Living our values and expectations Our code of conduct 4 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

How can we make the right decision When faced with a choice or dilemma, ask these questions: every time?

While GSK’s written standards help us address the significant risks we face, it’s not possible to cover every eventuality.

What to keep in mind when making Would I be Is it aligned with Does it meet Have I assessed Will this be a decision or taking action: Is it consistent happy with this our values and regulations all the risks clearly understood with our policies? if I were a patient • Our values and expectations expectations? and laws? involved? by a colleague? or consumer? • Appropriate regulations, standards and laws • Any risks that could arise • The possible impact on our patients and consumers, our company and ourselves

Not Yes No sure

Yes: It looks like a good decision but No: If the answer to any of these Not sure: Speak to your Global if you have any doubts, talk to questions is ‘no’, then think and Compliance your manager. again about what to say or do, (GEC), Legal or Human talk to your manager, or use the Resources (HR) reporting channels to speak up. representative.

Living our values and expectations Our code of conduct 5 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

When local laws, regulations, applicable Implications of not following Industry regulations We are committed to industry codes or other business specific this code of conduct GSK standards are stricter than our global and laws are vital abiding by country laws Our corporate standards and policies apply written standards, we work to comply with to everyone who works for or on behalf to our work and regulations that the strictest requirements. For example, of GSK. Failure to comply with them or we follow the UK Bribery Act (2010) and any other applicable legal and regulatory apply to our company the US Foreign Corrupt Practices Act (1977) requirements may result in disciplinary action, throughout all our businesses globally, as across the world. up to and including dismissal or termination well as individual countries’ anti-corruption of contract or assignment. For senior and competition laws, wherever we operate. managers, this could also include financial Complying with these regulations ensures recoupment for significant misconduct. we conduct our business on equal terms Managers also have the responsibility to with no unfair advantages. ensure their teams understand and follow If you are unsure about the impact of different this code of conduct and applicable countries’ laws on your local activities, check written standards. with your aligned Legal and/or Global Ethics Subject to local requirements, violations of and Compliance (GEC) representative(s). this code of conduct by agency workers will For more information on our written be reported to their respective agencies. standards visit our written standards Violations of the code of conduct by all resource centre on Connect GSK. other complementary workers may result in termination of contract (subject to local requirements).

Living our values and expectations Our code of conduct 6 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Using your voice: Zero tolerance for retaliation How to speak up At GSK, you can report concerns without fear of reprisal. GSK prohibits retaliation against anyone who raises or reports When we all do the right thing and live concerns and will take disciplinary action up to and including dismissal our values and expectations, we build trust Option 1 (in accordance with local labour laws) of any employee who threatens or in GSK and protect our license to operate. Speak to your manager engages in retaliation or harassment of someone who has reported, or is considering reporting, a concern in good faith. Similarly, we will report an agency worker who retaliates against anyone raising a report or concern to the worker’s We are each accountable for speaking up GSK treats all questions and issues employment agency and terminate if we have a concern or see something that’s confidentially, where possible, while their assignment with GSK. not in line with our values and expectations. investigating fairly, cooperating with Option 2 The first step is to speak with a line manager, governments and complying with legal Raise a concern with local management, or if that’s not possible, contact your obligations. When someone reports a HR, GEC or Legal Human Resources (HR), Global Ethics and concern in good faith, GSK will support Compliance (GEC) or Legal representative. that person. You can also use the telephone, internet or Managers also have a duty to raise any postal reporting channels. These channels concerns brought to their attention. Those are managed independently of GSK, are who ignore violations, or who fail to detect available globally and allow for reports to or correct them, could face disciplinary action. be kept anonymous if the local laws and Remember, by speaking up and raising regulations permit it. concerns, you are living our values and expectations and doing the right thing. Option 3 www.gsk.com/speakup Report confidentially online, by telephone or by email, or submit a report by post

Living our values and expectations Our code of conduct 7 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

In the following sections, you’ll find some principles that help each of us make the right choices and do the right thing in different situations. 1. Our patients, our consumers, 2. Our company our industry What we do to safeguard our company How we protect patients and consumers and its assets. and lead our industry.

3. O ur colleagues 4. Our world How we maintain our personal integrity How we engage with governments and groups, and work with others. protect the environment and engage with the communities we work in.

Living our values and expectations Our code of conduct 8 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Protecting our patients and consumers 10 Conducting research ethically 11 Kimberly, Managing the quality of our products effectively 11 Ovarian cancer patient

1. Our patients, our consumers,

our industry Living our values and expectations Our code of conduct 9 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Protecting our patients and consumers Reporting a concern about Our patients, our consumers, a GSK product We gain our patients’ and consumers’ trust our industry by focusing on their needs. That means Anyone hearing of any information regarding always thinking from their perspective. We a side effect, adverse reaction or any other put their safety first, and provide them with human safety concern on a GSK product, clear, up-to-date information. We promote including possible lack of effectiveness, must We do the right thing for our our products ethically and only to permitted report it to the Central Safety Department, patients and consumers and customers. or the local operating company medical department within 24 hours. Human safety Promotional activities that meet industry information from clinical trials is reported strive for the highest quality. We and GSK standards as described in the study protocol. work with our partners to improve Our promotional activities and materials Preventing counterfeiting healthcare and find new medicines conform to high ethical, medical and scientific standards. They are legal, Counterfeit medicines and healthcare and vaccines. Regardless of our industry‑compliant and evidence based. products pose a serious threat to the health and safety of our patients and consumers. If local laws, industry codes or GSK policies role, we understand how our work They often lack the active ingredients to set higher standards, we comply with the combat the illnesses they claim to treat and affects patients and consumers. strictest requirement. contain impurities that can actively cause Following the principles for harm. We are committed to protecting our non-promotional external interactions patients and consumers from counterfeit We make sure our non-promotional activities products. We are all responsible for are clearly distinct from the promotion of reporting any suspected counterfeiting Keywords to search Code of practice documents our products, never disguising or misusing of a GSK product. for on Connect GSK We have two code of practice our activities to influence healthcare • Medical governance documents – it’s important to use professionals and others inappropriately. the right one: • Adverse event reporting Ensuring product information is accurate • Code of practice for promotional and • Human safety information (HSI) We provide complete, up-to-date and non-promotional external interaction evidence-based product information to • Code of practice • C onsumer Healthcare code for healthcare professionals and consumers, • Reporting counterfeiting promotion and scientific engagement wherever they are in the world.

Living our values and expectations Our code of conduct 10 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Conducting research safely Following all research protocols Managing the quality Following Good Practices and standards of our products effectively From product quality to sharing research Protecting patients means using a range data, we work to protect our patients and The safety and wellbeing of patients who We strive to assure the safety, quality and of Good Practice quality guidelines and consumers and care for their wellbeing while volunteer to participate in our research trials efficacy of our products for our patients and standards throughout our business, on site, advancing science. is essential. We follow internal and external consumers by ensuring that our procedures in the lab, in the clinic or in the office. We standards of quality and integrity for all our comply with Good Practice regulations. monitor and document our work thoroughly to research programmes. Our Good Practice Procedures for Product ensure our records are correct and complete. Quality are documented in our Quality We also monitor our computerised systems Understanding transparency Keywords to search Management System and apply everywhere supporting these regulated processes. in our human research data for on Connect GSK we make, pack and distribute products. Following these steps with precision We may share expertise, resources, • Ethical research ensures that each element of the process intellectual property and know-how with is traceable, accountable and ready for • Human samples external researchers and the scientific inspection. Adhering to these guidelines community to help advance science as part • Animal welfare helps us meet regulatory requirements. More of formal research collaborations. We also importantly, it means our products are of the • Reporting counterfeiting publicly disclose a range of information about right quality and that any potential risks to human subject research studies and may • Clinical trial disclosure patients and consumers are minimised. share data with qualified researchers outside of a collaboration when we can protect patient confidentiality and ensure information is used only for valid scientific enquiry.

Living our values and expectations Our code of conduct 11 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Gifts or hospitality 13 Darren Whitworth, Principal Following the right financial procedures 13 Development Scientist with Working with suppliers 13 Shaila Ali, Senior Development Scientist Managing records properly 14 Handling personal information with care 14 Relevant, up-to-date records and information 14 Collecting competitive intelligence ethically 14 Data integrity 14 Safeguarding GSK assets 15 Using Technology Professionally 15 GSK devices for personal use 15 Returning GSK devices 15 We are all stewards of our reputation 15 Using social media 15

2.

Our company Living our values and expectations Our code of conduct 12 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Our company Gifts or hospitality Following the right financial procedures Like any business, we sometimes give and GSK’s financial, and procurement accept gifts, hospitality or entertainment. controls are designed to ensure that we do In every case, we must consider if it not mislead investors, legislators, authorities In this section, we look at how is appropriate. and the public about financial aspects of our company. we protect our company, assets In some situations, gifts or hospitality could be misunderstood or perceived as a bribe. When buying goods and services, we follow and data when we interact with Before we offer or accept anything, we make the correct procurement procedures and sure it fits our policy and local requirements, we have the appropriate approvals according our partners and suppliers. is normal in business relationships and does to the Grant of Authority policy before not influence either party’s decision making. committing to the purchase. We do not offer or accept the gift or Working with suppliers hospitality if it is linked to a sale or could We rely on suppliers to enable us to be perceived as excessive or as a bribe. do business. Working with Procurement, following set processes and using the approved buying channels helps make sure that we work with the suppliers who bring the most value to our organisation and who align with our standards. We are committed to demonstrating inclusion and diversity within our supply base by ensuring we follow fair and non-discriminatory procurement practices, Keywords to search for example: considering and providing for on Connect GSK opportunities to small businesses and/or • Conflicts of interest diverse-owned businesses where possible. • Meetings and catering • Supplier diversity • Grant of Authority • Gifts, hospitality and entertainment

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Managing records properly Relevant, up-to-date records and information The way we manage records could affect our business, our patients and consumers Good record keeping helps us protect PI and our reputation. That means we should and intellectual property, comply with legal, safeguard personal information, keep records financial and regulatory requirements, and up to date and gather market and competitor avoid unnecessary costs. However, we information in the right way. should not keep records and information longer than necessary to meet regulatory Handling personal information with care and business requirements. We’re all responsible for handling personal Collecting competitive information (PI) with special care. GSK built intelligence ethically its privacy foundation on nine Principles applicable globally: we only collect the As a company, we gather competitive minimum information necessary for our intelligence ethically and in a way that meets business goals; we tell the person exactly all laws and regulations. We often use what we are doing with their information, regulated specialist third-party suppliers how long we will keep it, and why we are to do this on our behalf. However, we should collecting it; we destroy PI when we no not seek to obtain or use information about longer need it for our business goals – just our competitors’ formulae, processes, to name a few. We also have a duty to patents, pending deals, or any other protect the personal information we collect competitively sensitive information. and retain about people to ensure it is not Data integrity misused, from research patient data to employee payroll information. We maintain data integrity by making sure Keywords to search that information is accurate and stored for on Connect GSK If you see or suspect unauthorised disclosure correctly. This is essential since much of or misuse of PI, accidental or intentional, • Privacy our work relies on having robust data and you must report it immediately via the Data information. As well as meeting legal and • Data incident or breach Incident Reporting webform. regulatory requirements, this means we have • Competition law All employees, complementary workers and accurate information when making decisions third-party suppliers who work with PI must about our products, our patients and • Data integrity complete relevant training. our people.

Living our values and expectations Our code of conduct 14 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

tools to create and store GSK data. Non- We are all stewards of our reputation approved tools will have reduced access The way we communicate with the outside or can be even blocked from use without world and internally is crucial to building notice to employee. Illegal or inappropriate trust. All communications about our business behaviour always puts GSK and personal interests are timely, accurate and reflect information at risk and will generate GSK’s values and expectations, as well as appropriate disciplinary consequence. following our policies, approval procedures GSK devices for personal use and all applicable laws. GSK Tech devices could be allowed for Using social media personal use, but this must be kept to a As a GSK employee it’s important you take minimum, to manage only urgent needs, care when interacting with content on social must not impact performance at work or media to avoid risk to you and the company. generate unapproved or inappropriate cost We must never react to, comment on, share for the company. Personal use of GSK or post content that mentions or refers resources is subject to additional local to GSK prescription products, R&D assets regulation and should always happen under or competitor products. For all other content managerial oversight or permission. that impacts GSK’s business (like disease External exchange of data will be monitored awareness, consumer products, GSK Safeguarding GSK assets and could be blocked. If you use your GSK receiving an award, third-party collaborations Keywords to search device for personal use, any data held on the etc.) use good judgement when deciding to for on Connect GSK The way we manage company assets, GSK asset is at your own risk as GSK can like, share or comment. If you do choose to both tangible and intangible, is important. • Acceptable use of IT delete this content without your approval. comment on content approved for individual It includes our daily use of our technology use, make it clear the views are your own. Returning GSK devices • Safeguard GSK information (tech) systems and how we protect our Only trained spokespeople can make information and intellectual property. • Competition law When someone leaves GSK they must return comments on behalf of GSK. GSK policies Using Technology Professionally all GSK-owned equipment (including but on confidential information still apply to • Information security not limited to Laptop, iPad, mobile phone personal social media accounts. We are all responsible for using tech and other company-owned assets) to their • Social media guidelines Conversations can escalate quickly on social resources appropriately and professionally local Tech team. It is the Line Manager’s media. Pause and consider our values and • Write right at all times. We need to keep GSK’s responsibility to make sure all equipment write right principles before interacting with information and data secure from increasingly is returned before, or on, the person’s last content. If you see content about GSK that sophisticated cyber-attacks and technology day of work with GSK. mis-use. Therefore, we should always stay you think is inaccurate, report it using our vigilant and use only company approved Speak Up channels.

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Acting with individual integrity and courage 17 Kamil Zahid, Senior Manager, A healthy and safe workplace 18 Category Led Innovation Our colleagues 19

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Our colleagues Living our values and expectations Our code of conduct 16 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Acting with individual integrity Our colleagues and courage Integrity and courage start with individual At GSK, we are driven responsibility. If we always aim to do the right thing, act honestly, ethically and openly, by our purpose to make and speak up if something doesn’t feel right, we are acting with individual integrity and a difference to the lives courage. of people around the Actively preventing fraud, bribery world. We do everything and all forms of corruption Bribery is illegal no matter where in the we can to maintain the world we work. It is up to us to speak up and report any suspected corruption and trust and respect of the have transparent conversations to assess organisations we work situations that could be open to fraud, bribery with and the communities or corruption. Our anti-bribery and corruption (ABAC) Avoiding all conflicts of interest in which we live and foundation principles (legitimacy of intent, Keywords to search transparency, proportionality, conflicts of Conflicts of interest arise when we may have for on Connect GSK operate. This way, we interest or undue influence) help us detect loyalties and interests that compete with protect the interests of and prevent bribery and corruption. our responsibilities at GSK, for example, • Anti-bribery and corruption (ABAC) if a family member works for a competitor It is up to all of us to know what is expected • Conflicts of interest or third party we plan to engage with. We our patients, consumers of us to prevent bribery and corruption by assess all our activities for potential conflicts complying with GSK policies and reporting and our company. and ensure that any actual, potential or any concerns. Leaders have a responsibility perceivable conflicts are declared and to ensure adequate assessment, mitigation resolved before we begin any work. and oversight of risks.

Living our values and expectations Our code of conduct 17 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Dealing in shares A healthy and safe workplace Some of us at GSK may have access Our purpose is to help people do more, feel to information through our work that is not better and live longer, including ourselves. publicly known, and which could affect That means creating healthy working GSK’s share price. To trade in GSK shares environments that help us thrive. when in possession of such knowledge is Each one of us must take responsibility known as insider trading and is illegal. for following safe practices and life-saving Competing in accordance with rules. These rules are simple, standardised competition laws and easy to remember. We have clear expectations. Work cannot start until the Life GSK is committed to free and open Saving Rules are met. Work must be stopped competition. We follow competition laws if any of the Life Saving rules are broken. wherever we operate and compete on the We must all live safely. Together. merits of our products and services. Building quality into everything we do Preparing for a crisis situation Committing to quality means taking GSK prepares for possible events to protect responsibility for improving our working people and help ensure that our company practices, helping our patients and can survive any disruptions, including consumers, and maintaining their trust. man-made or natural disasters. Please keep We are passionate about quality and are your contact information up to date to ensure always ready to learn from our mistakes as you, or a designated contact, can be reached well as our successes. It is about striving in an emergency or crisis situation. to do the right thing, first time, every time Keywords to search and challenging ourselves to be the best for on Connect GSK we can be. • Crisis and continuity • Life saving rules • Share dealing • Competition law

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Treating people equally and think and act ethically with no room for misunderstanding. Global collaboration All employees at GSK must ensure and communication tools, such as Workplace, an equitable and inclusive culture free allow us to share our views and experiences of discrimination. By doing so, we attract with colleagues across the world. and retain the best people. We also aim to reflect the diversity and characteristics of However, when we share our opinions, we the communities in which we operate and must always be professional and respectful. the people we serve. Harassing, bullying, trolling, spamming discriminatory or otherwise inappropriate A culture of respect behaviour that violates GSK policies or local We do not tolerate violence, harassment, laws and regulations is not allowed. unwelcome, unreasonable, offensive or Following our recruitment processes threatening behaviour of any kind. This includes any form of sexual harassment. We hire diverse people who align with our Any such behaviour that affects an individual’s values and have the right qualifications and dignity at work is not acceptable. This includes experience to work for us or on our behalf. inappropriate behaviour using our online tools. That means we undertake pre-employment/ pre-engagement screening for all employees Trusting each other and complementary workers before they are Our colleagues To work effectively, we need to have trust hired or contracted. Keywords to search in each other. That can only happen if Complementary workers We should always show respect for our for on Connect GSK we take extra care to ensure that people colleagues and the communities around working together do so in line with our values Complementary workers are an important • Be you us. Everyone has a part to play in creating and expectations. This also applies to asset to our business, and we benefit greatly a fair and inclusive work environment where • Pre -employment/Pre-engagement engagement of our complementary workforce from working with them. everyone can thrive and be inspired to do and of our third parties, following the GSK screening We also expect those who work for or their best work. Third Party Oversight framework. • Complementary workers on behalf of GSK who are not employees Managers have a responsibility to to comply with the GSK code of conduct • Managing third parties appropriately handle employee concerns, as a term of their engagement or contract • Equal and inclusive treatment reports and allegations, escalating them with GSK, alongside local labour laws or as needed. regulations and the GSK Complementary Workforce Policy. Expressing our opinions Those who manage complementary workers’ We encourage open and honest assignments should follow relevant GSK conversations at GSK. It’s important we’re policies as well as local laws. always guided by our values and expectations Living our values and expectations Our code of conduct 19 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Our commitment to human rights 21 Mangal Maya, Meeting our challenging sustainability targets 21 Lymphatic Filariasis Patient Working with wider communities 21

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Our world Living our values and expectations Our code of conduct 20 Contents Overview 1. 2. 3. 4. More Glossary Our patients, Our company Our colleagues Our world information our consumers, our industry

Our commitment to human rights Making sure our work with governments Our world is ethical We have a responsibility to respect human rights wherever we do business. We work with governments and have a responsibility to abide by our standards We are honest and transparent about what we do That means striving to prevent, mitigate and and all applicable laws. Our anti-bribery and remedy adverse impacts that our business corruption (ABAC) Policy sets out aspects of and how we do it. This improves how we collaborate activities or business relationships have on ethics to follow when dealing with government the human rights of our colleagues, patients with each other and enhances the way we are seen and non-government organisations. and consumers, workers in our supply chain by the communities we work with. It demonstrates and those who live in the communities in No political contributions which we operate. that we are open to challenge and discussion and We do not make political contributions to Meeting our challenging any individual or organisation in any country want to improve the way we operate. sustainability targets in which we operate. This helps us to operate transparently – free from any political If we all consider sustainability in our ties – and stay focused on putting patients everyday decisions and ways of working, We are also mindful of our responsibilities. We care and consumers first. collectively we can make a difference. about our communities and the wider world and Our ambitious targets, to achieve net zero Sanctions and export control laws impact on climate and net positive impact on In some cases, sanctions and export control are committed to human rights and a sustainable nature by 2030, will enable GSK to continue laws may restrict or prohibit us from doing contributing significantly to planetary and approach in all that we do. business with certain countries, governments, human health now and in the future. government officials, entities and individuals. Working with wider communities It is each person’s responsibility to Ensuring grants and donations understand any restrictions that apply to are appropriate them and to the activities they carry out for Keywords to search GSK. This enables the company to follow We support legitimate and worthy causes for on Connect GSK the rules on engagement of third parties, in the communities in which we operate. financial transactions and the movement • Environment, Health, Safety We also actively promote and support public of our products, goods, materials, services, and Sustainability (EHS&S) health. Anyone involved in this area has a equipment, software and technology. responsibility to check whether any grants • Grants and donations and donations made are in line with The GSK Sanctions Policy and associated • Government officials our standards. standards outline the requirements which • Sanctions and export controls enable us to meet our sanctions compliance obligations.

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Where to find more information?

People working for Third parties or on behalf of GSK may obtain more can log onto our information via their written standards on GSK contact. Connect GSK to find all of GSK’s corporate written standards. Individual responsibility, Speak up Use the keywords collective purpose www.gsk.com/speakup throughout this It’s up to all of us, every day, to keep GSK document to help the kind of company we can all be proud of. Thank you for helping to put our values your search. and expectations at the heart of every action you make and decision you take on behalf of GSK.

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More information

Term Definition Term Definition

ABAC ABAC stands for anti-bribery and corruption. Read our ABAC GSK values and expectations Our values and expectations are part of our DNA. They are policy to learn more about the situations that pose the at the heart of everything we do. Together they help guide highest risks. us to our goal to be one of the world’s most innovative, best performing and trusted healthcare companies. Accountability (GSK expectation) Accountability is about taking ownership, prioritising work that supports our strategy and delivering what we promise. Integrity (GSK value) Our value of integrity is about how we expect the highest ethical behaviours of ourselves and others. Adverse event reporting An adverse event is any unexpected result associated with the use of a GSK product, whether or not you think it might be related to Our written standards Found on Connect GSK, this is a central repository of all of our the product. It should be raised with the Central Safety Department resource centre written standards. within 24 hours of initial awareness via an online form. Patient focus (GSK value) Our value of patient focus is about always doing the right thing AllTrials We were the first pharmaceutical company to sign up to the AllTrials for patients and consumers and striving for the highest quality. campaign for clinical trial transparency, supporting the registration Respect (GSK value) of clinical trials and the disclosure of trial results and reports. Our value of respect means supporting colleagues and the communities around us, and embracing diversity and individuality, Code of conduct Our code of conduct applies to employees and anyone who so we can all achieve great things. works for or on behalf of GSK. It helps us understand the values Retaliation and expectations that guide our work. It describes the behaviours Retaliation is when someone takes a negative action against we all need to demonstrate to bring our values and expectations a colleague for exercising their rights under employment to life. Just as importantly, it shows us how living our values and law, e.g. speaking out. GSK has zero tolerance for retaliation. expectations helps us fulfil our purpose of helping people do more, Speaking up Being accountable for concerns and issues that we spot by feel better and live longer. All our written standards and procedures reporting or telling someone. It also includes recognising someone are available on the Our written standards resource centre on when they do something worthy of praise and sharing great ideas Connect GSK. that benefit everyone. Competition Law Competition laws make sure that there is fair competition between Supplier Suppliers are third parties who provide goods or services businesses by making rules to control monopolies. in return for the agreed upon compensation (traditionally Complementary workers People who work for or on behalf of GSK and are not employees. fee for service basis). These include contractors, consultants and agency staff. Teamwork (GSK expectation) Teamwork is about all of us working better together on aligned Conflicts of interest A is a situation in which an individual has objectives, understanding how our work contributes to our competing interests or loyalties; if you think you are, or might Innovation, Performance and Trust and Culture priorities, be, in such a situation, talk to your manager. encouraging diversity of thinking and inspiring and including each other. Data integrity We maintain data integrity by making sure that information Third party is accurate and stored correctly, which is essential, given much A third party is any organisation or person that is not a GSK legal of our work relies on having robust data and information. entity or employee, with which GSK has established a formal business relationship. This includes but is not exhaustive Courage (GSK expectation) Courage means setting high ambitions, setting an accelerated to suppliers, distributors, HCPs, licensors, etc. pace, making decisions even when it’s difficult and speaking Transparency (GSK value) up when we see an opportunity to improve. Our value of transparency helps us build trust with each other and with society by being honest and open about how and what we do. Development (GSK expectation) Development encourages us to bring the outside in and learn Workplace from others, and to ask for and give feedback, so we can continually A Facebook-owned collaboration and communication platform grow as individuals, teams and to ask as an organisation. used at GSK to facilitate business communication and collaboration amongst employees, complementary workers, and select third-party organisations.

Living our values and expectations Our code of conduct 23 Effective date: 16th June 2021