GSK has ‘zero tolerance’ for graft: Matching company policy with corporate action (Part 1)

A recent post on FCPA Blog about various ongoing investigations into alleged corrupt practices at GlaxoSmithKline in at least five countries included a quote attributed to GSK that the company has “zero tolerance for unethical or illegal behavior.”

I found this an extraordinary position for GSK to adopt, given the incidents of alleged corruption that may have been around for over a decade.

It got me to thinking, though, that GSK is far from alone in adopting a position that appears contrary to its actual actions.

Indeed, one only had to look at News Corp’s statements on its website in relation to ethics and corporate responsibility to understand that this policy did not match the actions of its journalists at the now defunct News of the World.

Over the last 27 years, I have conducted hundreds of investigations into allegations of fraud and corruption involving public and private sector organisations all around the world. In the main, these organizations had an array of policies, including:

• Code of Conduct
• Fraud Policy
• Gift Policy
• Conflict of Interest Policy, etc.

So, the question is, if organizations have these policies in place, why do management and staff still engage in fraudulent or corrupt behavior? They do so, either against the interests of the organization or, as we are seeing now in many instances, in furtherance of the commercial and other interests of their employers.

Part Two of this blog post will deal with the common pitfalls that organizations face when trying to build an ethical culture, plus tips that can be used to help promote ethical conduct across an entity’s divisions and supply chain.

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