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Checking Up on GSK in China

Tom Fox | December 1, 2015

When thinking through a risk assessment around the Foreign Corrupt Practices Act or other anti-bribery law, one thing usually not considered adequately is a company’s sales culture.

Most risk assessments focus on the mechanics and structure of a compliance program, consisting of policies and procedures or whether top managements “gets it.” Yet in many ways the culture around a company’s sales force is one of the key harbingers of potential FCPA risk. A recent article in the Nicosia Business Review considered the sales culture at GlaxoSmithKline PLC under its former (and now convicted) China business unit manager Mark Reilly.

According to the current head of GSK operations in China, Hervé Gisserot, the “mindset was more, more, more” for GSK’s sales in China. This led to a culture that allowed payments of bribes alleged to total nearly $500 million. Gisserot said this...

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