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Responding department: Communications and Government Affairs (also with input from other departments listed below)

Stock exchange symbol: (GSK:LN)

Additional departments that provided input into the response: Corporate responsibility; Manufacturing compliance; Public policy; Supply chain audit and assurance; Access to medicines; Inclusion and diversity; Employee relations; Sustainability; Medical policy.

Does your company have a publicly available commitment to respect human rights?

GSK has a stand-alone Human Rights policy which is published on gsk.com.  We have also made a public commitment to address the UN Guiding Principles on Business and Human Rights across our own operations and our supplier relationships.

Human Rights policy - http://www.gsk.com/media/280848/human-rights-statement-policy.pdf 

Human rights are also covered in the following policies:

Code of Conduct – http://www.gsk.com/media/325203/code-of-conduct-policy-english.pdf 

This includes the following areas:

  • reporting concerns without fear of reprisal
  • medical governance, conduct of clinical research, and safety evaluation to protect patients
  • anti-counterfeiting measures
  • security procedures
  • safeguarding personally identifiable information
  • equal and inclusive treatment
  • environment, health, safety and sustainability
  • management of complementary workforce
  • humanitarian donations

Third Party Code of Conduct –

http://www.gsk.com/media/279797/gsk-third-party-code-of-conduct.pdf

This sets out GSK’s expectations of suppliers, including:

  • ethical conduct
  • anti-bribery
  • fair labour including
  • protection of human rights
  • environment, health and safety management
  • quality control

Additionally, detailed policies are published on a wide range of issues related to human rights such as public health, access to medicines, pricing of products and research and development activities.

Policies - http://www.gsk.com/en-gb/about-us/policies-codes-and-standards/#public-policies

GSK’s approach to human rights is also covered extensively in various sections of the Responsible Business Supplement 2014 - http://www.gsk.com/media/618264/gsk-responsible-business-supplement-2014.pdf

 

Update 2016:

GSK has a stand-alone Human Rights policy which is published on gsk.com.  We have also made a public commitment to address the UN Guiding Principles on Business and Human Rights across our own operations and our supplier relationships.

Human Rights policy - http://gsk.com/media/890484/human-rights-statement.pdf

Human rights are also covered in the following policies:

Code of Conduct – http://www.gsk.com/media/1042340/our-code-of-conduct.pdf

This includes the following areas:

  • reporting concerns without fear of reprisal
  • medical governance, conduct of clinical research, and safety evaluation to protect patients
  • anti-counterfeiting measures
  • security procedures
  • safeguarding personally identifiable information
  • equal and inclusive treatment
  • environment, health, safety and sustainability
  • management of complementary workforce
  • humanitarian donations 

Working with Third Parties policy–

http://www.gsk.com/media/1351707/external-use-working-with-third-parties-june16.pdf

This sets out GSK’s expectations of suppliers, including:

  • ethical conduct
  • anti-bribery and corruption
  • labour rights
  • health and safety in the workplace
  • patient safety and care
  • marketing and promotional practices
  • environmental protection 

Additionally, detailed codes, policies and standards are published on a wide range of issues related to human rights such as public health, access to medicines, pricing of products and research and development activities. 

Codes, policies and standards - http://www.gsk.com/en-gb/about-us/policies-codes-and-standards/

GSK’s approach to human rights is also covered extensively in various sections of the Responsible Business Supplement 2015 - http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf

How are human rights governed in your company?

Lead responsibility for ensuring GSK considers its human rights impacts sits with the head of Global Ethics and Compliance, who is a member of the Executive Team reporting to the CEO. The head of Global Ethics and Compliance is supported in this through a Human Rights Steering Group comprised of experts from relevant areas of the business such as Corporate responsibility, Manufacturing compliance, Public policy, Supply chain audit and assurance, Access to medicines, Inclusion and diversity, Employee relations, Sustainability, Medical policy. Oversight of human rights performance is the responsibility of the Corporate Responsibility Committee of the Board, chaired by the Company Chairman. The head of Global Ethics and Compliance reports annually to the CR Committee on how GSK is meeting its human rights commitments. Additionally, reports to the CR Committee from other Executive Team members will address a range of human rights issues, for example matters relating to access to medicines; standards, working practices and diversity in the supply chain; employee relations; inclusion and diversity; employee health, safety and wellbeing.

Update 2016:

Lead responsibility for ensuring GSK considers its human rights impacts sits with the head of Global Ethics and Compliance, who is a member of the Executive Team reporting to the CEO. 

The head of Global Ethics and Compliance is supported in this through a Human Rights Steering Group comprised of experts from relevant areas of the business such as Corporate responsibility, Manufacturing compliance, Public policy, Supply chain audit and assurance, Access to medicines, Inclusion and diversity, Employee relations, Sustainability, Medical policy.

Oversight of human rights performance is the responsibility of the Corporate Responsibility Committee of the Board, chaired by a non-executive director. The head of Global Ethics and Compliance reports annually to the CR Committee on how GSK is meeting its human rights commitments.  Additionally, reports to the CR Committee from other Executive Team members will address a range of human rights issues, for example matters relating to access to medicines; standards, working practices and diversity in the supply chain; employee relations; inclusion and diversity; employee health, safety and wellbeing.

How are human rights managed within your company?

GSK established a Human Rights Steering Group in 2012 to identify and assess actual and potential human rights impacts and to oversee work to prevent or manage negative impacts. The Steering Group provides direction and oversight of the policies, processes and performance required to meet the company’s human rights commitments.  The Steering Group is chaired by the head of Global Ethics and Compliance and the Group’s members have cross-functional roles or expertise in the areas of potential human rights impacts – for example Corporate responsibility, Manufacturing compliance, Public policy, Supply chain audit and assurance, Access to medicines, Inclusion and diversity, Employee relations, Sustainability, Medical policy.

All employees are required to undertake annual training and to operate in line with the GSK Code of Conduct - http://www.gsk.com/media/325203/code-of-conduct-policy-english.pdf

Suppliers and business partners are expected to operate in line with the Third Party Code of Conduct - http://www.gsk.com/media/279797/gsk-third-party-code-of-conduct.pdf. 

Both these Codes cover human rights (see response to Question 1). 

Effectiveness of actions relating to human rights is continually tracked as a part of routine business monitoring.  Progress on agreed actions is reported to the Human Rights Steering Group and the head of Global Ethics and Compliance. This progress is then reported annually to the Board Corporate Responsibility Committee. The progress against our public commitments is also reported annually through the Corporate Responsibility Report (known as the Responsible Business Supplement from 2014). 

Update 2016:

GSK established a Human Rights Steering Group in 2012 to identify and assess actual and potential human rights impacts and to oversee work to prevent or manage negative impacts. The Steering Group provides direction and oversight of the policies, processes and performance required to meet the company’s human rights commitments.  The Steering Group is chaired by the head of Global Ethics and Compliance and the Group’s members have cross-functional roles or expertise in the areas of potential human rights impacts – for example Corporate responsibility, Manufacturing compliance, Public policy, Supply chain audit and assurance, Access to medicines, Inclusion and diversity, Employee relations, Sustainability, Medical policy.

All employees are required to undertake annual training and to operate in line with the GSK Code of Conduct - http://www.gsk.com/media/1042340/our-code-of-conduct.pdf

Suppliers and business partners are expected to operate in line with the Working with Third Parties policy - http://www.gsk.com/media/1351707/external-use-working-with-third-parties-june16.pdf

Both these Codes cover human rights (see response to Question 1). 

Effectiveness of actions relating to human rights is continually tracked as a part of routine business monitoring.  Progress on agreed actions is reported to the Human Rights Steering Group and the head of Global Ethics and Compliance. This progress is then reported annually to the Board Corporate Responsibility Committee. The progress against our public commitments is also reported annually through the Corporate Responsibility Report (known as the Responsible Business Supplement from 2014). 

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

GSK has regular dialogue with stakeholders to enable the company to understand how our business may affect them, or be affected by them. Their feedback helps us to identify and prioritise important issues and develop responses that are in the best interests of society. 

Within the company, we engage with people formally and informally to understand their views and how we can improve their experience of working at GSK. This is described in our Responsible Business Supplement 2014 (page 35) - http://www.gsk.com/media/618264/gsk-responsible-business-supplement-2014.pdf

For GSK, the most important human rights issues include areas such as access to medicines, patient safety and management of the supply chain. We engage with a wide range of stakeholders on these issues through forums specifically set up for this purpose, and also through day-to-day interactions with customers, engagement with governments and patient advocacy groups, and regular dialogue with suppliers and business partners. Further description is referenced in our Responsible Business Supplement (pages 17-19, 29 and 33)  http://www.gsk.com/media/618264/gsk-responsible-business-supplement-2014.pdf

Update 2016:

GSK has regular dialogue with stakeholders to enable the company to understand how our business may affect them, or be affected by them. Their feedback helps us to identify and prioritise important issues and develop responses that are in the best interests of society.

Within the company, we engage with people formally and informally to understand their views and how we can improve their experience of working at GSK. This is described in our Responsible Business Supplement 2015 (page 42) - http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf 

For GSK, the most important human rights issues include areas such as access to medicines, patient safety and management of the supply chain. We engage with a wide range of stakeholders on these issues through forums specifically set up for this purpose, and also through day-to-day interactions with customers, engagement with governments and patient advocacy groups, and regular dialogue with suppliers and business partners. Further description is referenced in our Responsible Business Supplement (pages 20-22, 33 and 36) - http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf  

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Freedom of association and trade union rights
  • Transparency in payments to governments / responsible tax practices
  • Product Misuse
  • Children (including child labour)

Update 2016:

Other issues:  To understand our human rights impacts we worked with BSR, a non-profit external consultancy with expertise in business and human rights, to undertake a systematic assessment to identify GSK’s human rights impacts. Based on this assessment, we prioritised seven areas to further examine GSK’s policies and processes, and their potential to positively or negatively impact human rights. These are: access to healthcare; global warming impact of propellants used in some inhalers; clinical trial standards; employment practices; patient safety; product counterfeiting; and use of third party suppliers.

For one or more of the issues indicated above, please give examples of steps your company has taken.

GSK’s greatest impact on human rights is in expanding access to medicines. Our innovative business models improve affordability of our medicines and vaccines, including price caps for the poorest countries, flexible and tiered pricing in middle-income countries, and support for governments and low income patients in high-income countries. We are committed to improving access to our products – irrespective of where people live or their ability to pay – by focusing on the affordability and availability of our products, and investing in strengthening health systems.  In 2014 GSK was ranked first in the Access to Medicines Index for the fourth consecutive time. http://www.accesstomedicineindex.org/ranking

Work in this area is summarised in our Responsible Business Supplement 2015 (pages 9-10 and 13-25) - http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf

Actions on 'other' issues

Other issues:  To understand our human rights impacts we worked with BSR, a non-profit external consultancy with expertise in business and human rights, to undertake a systematic assessment to identify GSK’s human rights impacts. Based on this assessment, we prioritised seven areas to further examine GSK’s policies and processes, and their potential to positively or negatively impact human rights. These are: access to healthcare; global warming impact of propellants used in some inhalers; clinical trial standards; employment practices; patient safety; product counterfeiting; and use of third party suppliers. 

GSK’s greatest impact on human rights is in expanding access to medicines. Our innovative business models improve affordability of our medicines and vaccines, including price caps for the poorest countries, flexible and tiered pricing in middle-income countries, and support for governments and low income patients in high-income countries. We are committed to improving access to our products – irrespective of where people live or their ability to pay – by focusing on the affordability and availability of our products, and investing in strengthening health systems.  In 2014 GSK was ranked first in the Access to Medicines Index for the fourth consecutive time. http://www.accesstomedicineindex.org/ranking

Work in this area is summarised in our Responsible Business Supplement 2014 (pages 6-7 and 10-22) - http://www.gsk.com/media/618264/gsk-responsible-business-supplement-2014.pdf

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

GSK publishes a Corporate Responsibility Report every year.  The 2014 report is called the Responsible Business Supplement.

http://www.gsk.com/media/618264/gsk-responsible-business-supplement-2014.pdf

This reports progress on managing human rights in general, and provides detailed information on specific areas which are particularly relevant for the company.  These are referenced in responses to other questions.  Responsible business is also covered in our Annual Report.

http://www.gsk.com/media/603031/annual-report-2014.pdf

As a signatory to the UN Global Compact, we publish a Communication on Progress to demonstrate how we uphold its ten principles.  Also, our index against the Global Reporting Initiative shows which elements of the guidelines are covered in our Responsible Business Supplement.

http://www.gsk.com/en-gb/responsibility/responsibility-reports-and-data/reporting-archive-and-resources/

Internally, commitments are communicated through the requirement for all employees to undertake training on the Code of Conduct which encompasses a number of aspects of human rights.  Further information and training is provided on specific areas of human rights depending on an employee’s role, for example training on inclusion and diversity, health and safety, conduct of clinical trials, patient safety. 

Update 2016:

GSK publishes a Corporate Responsibility Report every year.  The 2015 report is called the Responsible Business Supplement.

http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf

This reports progress on managing human rights in general, and provides detailed information on specific areas which are particularly relevant for the company.  These are referenced in responses to other questions.  Responsible business is also covered in our Annual Report.

http://annualreport.gsk.com/ 

As a signatory to the UN Global Compact, we publish a Communication on Progress to demonstrate how we uphold its ten principles.  Also, our index against the Global Reporting Initiative shows which elements of the guidelines are covered in our Responsible Business Supplement.

http://www.gsk.com/en-gb/responsibility/responsibility-reports-and-data/reporting-archive-and-resources/

Internally, commitments are communicated through the requirement for all employees to undertake training on the Code of Conduct which encompasses a number of aspects of human rights.  Further information and training is provided on specific areas of human rights depending on an employee’s role, for example training on inclusion and diversity, health and safety, conduct of clinical trials, patient safety. 

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

GSK has a ‘Speak Up’ programme which enables employees and third parties to report any concerns or policy violations anonymously. https://www.tnwgrc.com/gsk/main.htm This is clearly signposted on the Contact Us page of our website. http://www.gsk.com/en-gb/contact-us/

GSK has procedures in place to protect and safeguard employees from harassment or reprisal when they report concerns in good faith, which are genuine concerns of misconduct, and are not falsely raised. 

Update 2016:

GSK has a ‘Speak Up’ programme which enables employees and third parties to report any concerns or policy violations anonymously. https://www.tnwgrc.com/gsk/main.htm This is clearly signposted on the Contact Us page of our website. http://www.gsk.com/en-gb/contact-us/

GSK has procedures in place to protect and safeguard employees from harassment or reprisal when they report concerns in good faith, which are genuine concerns of misconduct, and are not falsely raised. 

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

GSK is a signatory to the UN Global Compact, supports the UN Guiding Principles on Business and Human Rights, and is committed to upholding the UN Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises and the core labour standards set out by the International Labour Organization. 

We work with external groups across all areas of our business in ways that support upholding human rights. 

One of the most significant areas in which GSK can impact human rights is in improving access to medicines.  Our work in this area is summarised in the Responsible Business Supplement 2014 (pages 6-7 and 10-22) - http://www.gsk.com/media/618264/gsk-responsible-business-supplement-2014.pdf and the Access to Medicines Index 2014. http://www.accesstomedicineindex.org/glaxosmithkline-plc 

Examples of specific collaborative initiatives relating to access to medicines, include:

We are part of the Accelerating Medicines Partnership which aims to transform the current model for developing new diagnostics and treatments in challenging disease areas by jointly identifying and validating promising biological targets. http://nih.gov/science/amp/index.htm

We are a leading partner of the London Declaration working with the Bill and Melinda Gates Foundation, WHO, other pharmaceutical companies, donors and national governments to help control or eliminate 10 out of 17 neglected tropical diseases that affect over 1 billion people by 2020. http://unitingtocombatntds.org/resource/london-declaration

In the area of supply chain management, we are members of the Pharmaceutical Supply Chain Initiative. http://www.pharmaceuticalsupplychain.org/about/.  This supports suppliers to operate in a way which is consistent with industry expectations for ethics, labour rights, health and safety, and environmental practices, with a view to improving conditions for workers, economic development and a cleaner environment for local communities.

Update 2016:

GSK is a signatory to the UN Global Compact, supports the UN Guiding Principles on Business and Human Rights, and is committed to upholding the UN Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises and the core labour standards set out by the International Labour Organization. 

We work with external groups across all areas of our business in ways that support upholding human rights. 

One of the most significant areas in which GSK can impact human rights is in improving access to medicines.  Our work in this area is summarised in the Responsible Business Supplement 2015 (pages 9-10 and 13-25) - http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf and the Access to Medicines Index 2014. http://www.accesstomedicineindex.org/glaxosmithkline-plc 

Examples of specific collaborative initiatives relating to access to medicines, include:

We are part of the Accelerating Medicines Partnership which aims to transform the current model for developing new diagnostics and treatments in challenging disease areas by jointly identifying and validating promising biological targets. http://nih.gov/science/amp/index.htm

We are a leading partner of the London Declaration working with the Bill and Melinda Gates Foundation, WHO, other pharmaceutical companies, donors and national governments to help control or eliminate 10 out of 17 neglected tropical diseases that affect over 1 billion people by 2020. http://unitingtocombatntds.org/resource/london-declaration

In the area of supply chain management, we are members of the Pharmaceutical Supply Chain Initiative. http://www.pharmaceuticalsupplychain.org/about/.  This supports suppliers to operate in a way which is consistent with industry expectations for ethics, labour rights, health and safety, and environmental practices, with a view to improving conditions for workers, economic development and a cleaner environment for local communities.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

As part of our support for the Principles, we worked with BSR, a non- profit external consultancy with expertise in business and human rights, to undertake a systematic assessment to identify GSK’s human rights impacts. Based on this assessment, we prioritised seven areas to further examine the potential for GSK’s policies and processes to positively or negatively impact human rights. These areas are: access to healthcare; global warming impact of propellants used in some inhalers; clinical trial standards; employment practices; patient safety; product counterfeiting; and use of third party suppliers. As a result of this examination, we are focusing on better understanding human rights risks in GSK’s supply chain and how we can address these, including standardising our approach to procurement across geographies and business units, and simplifying our existing controls. We are also working to further embed GSK’s global standards on diversity, equality and inclusion at a country level.

Update 2016:

In 2013 GSK published its commitment to address the UN Guiding Principles on Business and Human Rights across its own operations and its supplier relationships. As part of our support for the Principles, we worked with BSR, a non-profit external consultancy with expertise in business and human rights, to undertake a systematic assessment to identify GSK’s human rights impacts. Based on this assessment, we prioritised seven areas to further examine the potential for GSK’s policies and processes to positively or negatively impact human rights. These areas are: access to healthcare; global warming impact of propellants used in some inhalers; clinical trial standards; employment practices; patient safety; product counterfeiting; and use of third party suppliers.

As a result of this examination, we are focusing on better understanding human rights risks in GSK’s supply chain and how we can address these, including standardising our approach to procurement across geographies and business units, and simplifying our existing controls. During 2015 we introduced a comprehensive new programme to strengthen our mamandement of risk in the supply chain, including labour rights, described in the Responsible Business Supplement 2015 (page 38) - http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf.

We are also working to further embed GSK’s global standards on diversity, equality and inclusion at a country level, described in the Responsible Business Supplement 2015 (page 44) - http://annualreport.gsk.com/downloads/GSK_Responsible_Business_Supplement_2015.pdf

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

Obstacles and challenges stem primarily from the enormity and complexity of the areas being tackled.  For example, we are committed to playing our part in addressing access to medicines however the barriers, which are outlined in our Corporate Responsibility Report 2013 (page 14), are substantial. http://www.gsk.com/media/325170/cr-report-2013.pdf

These can include a lack of effective treatments for many diseases, the affordability of medicines when they are available, limited healthcare infrastructure to deliver the care required, and poverty which has a huge effect on people’s health and well-being.

In managing our supply chain we are dealing with a vast number of suppliers and complex supply chains.  Each year we produce four billion packs of medicine and consumer healthcare products and 900 million doses of vaccines. We spend around £9 billion on goods and services and the ingredients and materials we buy feed into our network of 86 GSK manufacturing sites in 36 countries. We are moving to an ‘end-to-end’ supply chain model for our products that will standardise and improve our controls across our entire supply chain and manufacturing operations – from procuring raw materials, through quality controls, to packaging, and the transport and logistics involved in delivering products to our customers in 170 countries.  However the sheer scale and complexity of the operations present challenges as we seek to ensure human rights are upheld in our supply chains.

Update 2016:

Obstacles and challenges stem primarily from the enormity and complexity of the areas being tackled.  For example, we are committed to playing our part in addressing access to medicines however the barriers, which are outlined in our Corporate Responsibility Report 2013 (page 14), are substantial. http://www.gsk.com/media/325170/cr-report-2013.pdf

These can include a lack of effective treatments for many diseases, the affordability of medicines when they are available, limited healthcare infrastructure to deliver the care required, and poverty which has a huge effect on people’s health and well-being.

In managing our supply chain we are dealing with a vast number of suppliers and complex supply chains.  Each year we produce four billion packs of medicine and consumer healthcare products and 900 million doses of vaccines. We spend around £13 billion on goods and services and the ingredients and materials we buy feed into our network of 86 GSK manufacturing sites in 36 countries. We are moving to an ‘end-to-end’ supply chain model for our products that will standardise and improve our controls across our entire supply chain and manufacturing operations – from procuring raw materials, through quality controls, to packaging, and the transport and logistics involved in delivering products to our customers in over 150 countries.  However the sheer scale and complexity of the operations present challenges as we seek to ensure human rights are upheld in our supply chains.