Glaxo Exec Wants To Know ‘What Went Wrong?’

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diedre-connellyFor those of you who like to play connect the dots, consider that shortly before US Health & Human Services Secretary Kathleen Sebelius crowed yesterday about her department recovering billions from healthcare fraud last year (watch this), the head of GlaxoSmithKline’s US pharma business addressed this trend before a crowd of pharma execs and attorneys by rhetorically asking: “What’s going on? Why is this happening?”

The timing was precious. The HHS, which is looking to score points on Capitol Hill for its healthcare fraud initiative, could hardly have overlooked that a two-day pharma industry conference devoted to compliance is being held nearby. Of course, Glaxo’s Deidre Connelly had her own agenda - she used her speech as a carefully calibrated opportunity to try to deflect the intense criticism that has been heaped on Glaxo for months over several major transgressions that were probed by the feds.

In a bit of understatement, Connelly couldn’t avoid noting that “my own company has borne its share of allegations and has been in the news lately for settlements and legal charges.” Indeed, Glaxo has generated much more than its share of bad press for bad behavior. The US Department of Justice issued a subpoena over allegations of improper marketing and clinical trial data not properly disclosed concerning the Avandia diabetes pill, and several state attorneys general offices issued Civil Investigative Demands (see this). Meanwhile, nearly $6 billion in charges were set aside to cover Avandia product-liability lawsuits and investigations, as well as the cost of settling lawsuits over the Paxil antidepressant and accusations that risks were hidden (see this and this).

Then, there was the sizeable $750 million fine that was paid to settle charges over numerous production problems - contaminated meds, mislabeled packaging and incorrect dosages - at a facility in Cidra, Puerto Rico; the feds say the investigation is ongoing (read more here and here). And a former Glaxo attorney was recently indicted for obstructing an FDA probe into off-label marketing of Wellbutrin SR (look here), although privately many say she is a fall gal.

Not surprisingly, Connelly did not go into such detail. But she did ask the right question: “So what went wrong?” Actually, she was referring to the overall lack of public trust in pharma, but then attempted to offer a mea culpa, of sorts. The bad reputation “has to do with long‐running government investigations, litigation over past practices, and the resulting news coverage that makes it look like we still take doctors on trips to exotic locations - which we don’t. Some of it is because we haven’t done enough to communicate what we do and don’t do. Some of it is because industry bashing is good politics. Some of it is because we still make mistakes.”

Such as? She excoriated a “competitive selling model” that “may still be okay for other industries, but we do not sell chocolate or cars.” Notice, though, that Connelly attempted to distance Glaxo from its infractions by emphasizing “long running” and “past practices.” In other words, she is trying to make the case that the problems were rooted in years gone by, not the Glaxo of today. “…I’m here precisely because my company and the people I work with are not what are often portrayed publicly,” she continued.

From there, Connelly offered a laundry list of steps being taken to dispel the notion that pharma and, in particular, Glaxo are bad actors. Pharma supporters will likely say this is an overdue move; for months, Glaxo has been lawyering up and offering little, if any comment about its remarkable trail of misdeeds, even if many took place several years ago. Pharma critics may say this is merely window dressing and nothing more than a chance to send a manipulative message to anyone who will listen, given ongoing controversy over its handling of Avandia, such as trying to censure Steve Nissen (see this).

So what exactly is Glaxo doing? In no particular order, Connelly noted that ads for the Levitra impotence pill are no longer running on TV. Erectile dysfunction is “certainly is not a condition parents, aunts, uncles, and grandparents want to explain to children while watching a football game on Thanksgiving.” The move actually occurred in 2009, but Glaxo never disclosed this publicly. Of course, Levitra continues to trail Pfizer’s Viagra, so saving money on an also-ran is a relatively easy move.

And as evidence of a more transparent entity, she cited a decision two years ago to disclose payments to doctors, although Glaxo is not alone and all drugmakers must do so by law starting in 2013 (back story).

Internally, Glaxo last summer announced plans to overhaul compensation for sales reps (see here). The drugmaker will no longer pay bonuses based on achieving sales targets and, instead, will pay them extra based primarily on feedback from customers (docs and hospitals, of course), scientific and business knowledge and whether reps adhere to what the drugmaker called “values of transparency, integrity, respect and patient-focus.”

And Connelly also pointed to various steps to alter behavior across departments, such as implementing mandatory training, embedding deputy compliance officers in each business unit. “By doing these things, we can assure the public that our industry – an industry that has brought so much benefit to so many – is conducting its business with fcus on the patient, with transparency, with integrity and with respect. In this way we will be worthy of trust,” she concluded.

Maybe so. Certainly, the goals she outlined are laudable. And perhaps the moves she described will yield some positive results, which would certainly be a good thing. But like it or not, Glaxo execs remain on the hot seat. The drugmaker has simply stepped in poop too many times in recent years to receive credit very quickly for the sort of actions she described. To truly accomplish the goals she set out, Glaxo is going to have to become a model corporate citizen, which will be more difficult in the current era of generic competition than in the good old days of me-too drugs and blockbuster meds.

What went wrong? What didn’t?

Hat tip to NPR Shots

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  1. Ed, I don’t know if stopping sales volume-based payments to sales reps is new news or not, but it seems like a pretty fundamental step in the right direction.

    To me this seemed like the major news part of the story, so I was surprised your article had such a negative spin. The other items in this article are certainly true, but they aren’t really news.

  2. Hi John,

    Thanks for the note. And no, the change in compensation is not actually new news - as noted, it was announced by Glaxo last summer and I provided a link to a post I ran at the time so further details could be learned.

    For that reason, I chose to include it in the section about the various steps that Connelly outlined as being taken by Glaxo. But I did not offer any view on that particular step, because I do not know for certain if it will achieve the desired outcome. If it helps, well, then good.

    And I was not criticizing Connelly, or trying to give the impression that I was criticizing Connelly, for her speech. There is more than one way to view this effort, as I pointed out. I do think that Glaxo is overdue in publicly addressing its transgressions, and so confronting the past is a good thing.

    That said, Glaxo has racked up a rather serious string of infractions, many of which have surfaced very recently, and so I chose to recount them. One aspect of owning up to mistakes is to look in the mirror; I held one up for the sake of going on record and providing some context.

    In short, I do think acknowleding mistakes and taking corrective action is the right thing. And if Glaxo can make improvements, that would be good, as I noted. But there were a great many issues that were uncovered and so whether these moves will be sufficient remains to be seen.

    Hope this helps,
    ed

  3. Ed — The question is a good one. In essence it is this: “How can companies that save people’s lives and make real magic in a bottle be so hated?”

    And here’s the answer: When pharma executive heard the old Jack Benny joke that start off with a holdup man saying “Your money or your life….?” what they hear was not a joke but a BUSINESS PLAN.

    The BIG LIE that comes with the morning coffee at Big Pharma is that all of their problems are in the past, and they are cleaning up shop. Not true, and I can tell you why — pharma sells commodities and the CORE BUSINESS is not drugs but kickbacks, off-label sales, price-gouging and the like.

    As for corporate compliance programs, they can work to ferret out petty pilfering and embezzlement. They may work to throw a light on sexual harassment. But corporate compliance officers simply do NOT have the throw weight, within a corporation’s hierarchy, to stop large-scale fraud planned within the highest levels of a company. And I ASSURE YOU that is where this stuff is designed and green-lit.

    More often than not, a compliance officer is really a COMPLIANTS officer whose main job is to identify anyone within a company who is unhappy with the way the company is doing business, so they can be scooted out the door as quickly as possible, and before they can gather documents or talk to the Government about the fraud they are seeing.

    Deidre Connelly and other lawyers doing PR can try to paper over the holes and become professional apologists for corporate liars, thieves and cheats, but they are powerless to change corporate bottom lines that DEPEND on fraud to keep stock prices up. And that fraud will continue so long as we simply hit companies financially, while allowing CEOs, CFO, General Counsels, Regional Managers to pocket their annual bonuses for past frauds.

    If fraud is a disease, paliative care is simple fines, but the CURE is sending lawyers to jail and exluding key executives for a decade or more. GSK’s former general counel is one of the very first in the line of fire here; she is looking at over 40 years in jail. If I worked for Glaxo or any other pharam company, I would make sure I was next.

    PBurns

  4. The public would like the red meat of an apology from a corporate exec, in this & many other industries, but there are legal reasons why that isn’t going to happen.

    The change in sales bonuses is a good step, if it sticks. This is the kind of policy a company could change at any moment without communicating about it externally, so it’s fair to be skeptical.

    GSK is in the penalty box now & they’re trying to make the 2 minutes tick down faster than it probably will. Hopefully they will internalize some of these lessons.

  5. What went wrong? Are you kidding me? Now, all of the sudden they’re born again, realize that they’ve been sinners, are willing to repent and do their penance. Cut me a break! The biggest problem pharma faces right now is the widespread corruption at the top executive level. It happens because they are aware that they can get away with it and will never be held accountable for their actions. The company will admit no wrongdoing, pat a fine with shareholder money and do it again. The problem does not rest with the sales reps. What they make pales in comparison to what the top dogs make in bonus money. Until they are evaluated by how they conduct their business, things will never change. All of this is just more talk that they hope the public will buy hook, line and sinker. Worthy of trust? Transperancy? Integrity? Honesty? These are not words that pharma lives by. They are corrpupt, plain and simple. Too many people have gotten too rich for the culture to change. The most crooked have risen to the very top and are used to the big money they get by not following the rules.

  6. a lot of pharma execs and investors made a lot of money during the block buster era

    alot of effort went into creating the regulatory environment that made the era possible

    that run has clearly ended and pharma and investors are dealing with the consequences

    imho it would have been better for all if it had played out a different way

    lesson learned should be for more realistic oversight but $$$ are involved

  7. Is there any more indication that high ranking people within the pharma industry are clueless and out of touch with reality ?The question we should be asking is not “what went wrong?”, it’s “given the organizational environment why doesn’t this happen more often?”

    Change starts within the organization; it is a way of being transparent and rewarding people who raise their hands to guard against patients best interests. All too often these people are seen as “people who rock the boat” and are penalized by demotion or bad reviews. There is no system in place within pharma that rewards people who put patients interests ahead of sales.

    If the drug industry is really interested in finding out what went wrong and changing the environment they need to take a new approach to the way they do business including;

    (1) Ensuring that patients are at the center of everything they do. This has to be reaffirmed by the CEO at every opportunity.

    (2) Embracing transparency.

    (3) Creating a marketing environment where marketers make good marketing decisions that apply to both consumers and business objectives. This means eliminating the requirement that marketing people have to have sales experience. Too many bad decisions are made when sales people formulate marketing programs that are based on sales goals.

    (4) Reward people who speak up and want to change processes and the system for the better. How many drug companies use the 360 degree feedback program for reviews ? This means that you have to “please” everyone rather than do what you feel is best for your customers and creates an atmosphere of people who are afraid to take risks.

    (5) Stop talking at patients and customers and talk with patients and customers.

    Those of us who work in healthcare marketing know that there are a lot of skeletons in the closet and that the drug industry often beats down people who ask “why” or “why not”. It can’t be about “getting along” of “fitting into the system” it has to be more about “who has our customers and patients best interests at heart and who is the Linchpin for change within the organization”. Until pharma is willing to look in the mirror the type of mistakes that caused GSK to put aside $3 billion will continue and consumers will mistrust the industry.

  8. Nice try Glaxo. The entire industry by and large is totally profit driven behind closed doors. I have personal experience in several big pharma companies, including very recent.

    Once the room door is closed and it’s marketing and executive leadership, patient well being is never discussed or considered.

    I personally don’t think the public has even 1/2 of the real picture. The greed and callous behavior is much worse than the public thinks.

    Compliance departments? They are a joke. Last week I had an interaction with the complaince lawyers about actual reported behavior and they rationalized it away as a “misunderstanding”. This is a company still under a CIA with the DOJ.

    If certain people are non-compliant, it is dismissed - if it is someone they deem expendable - they are gone.

    The more things change, the more they stay the same.

  9. Real question:

    What is the alternative to a “competitive selling model” in the context of pharma?

  10. Evenif they now start doing the right actions, it will be a long time before any physician with any brains trusts them. I have alwys thought the bonus structure was a big part of the problem and the total lack of enforcement of their own compliance regulations was another. Embedding lawyers in business teams did not help, HR just kept their harassment up anyway. If the managers can’t get that big bonus, then their are a lot fewer reasons to go off-label to make ones numbers. At Pfizer I heard over and over again, if I don’t make my numbers then I am gone anyway, so the reps were willing to do whatever the manager said even if it was a class `1 felony. They had to make their numbers.Sometimes the numbers had no relation to what one could sell in the territory but the manager still wanted you to make the numbers.

  11. Every manager I ever made contact with at were nothing more but profiteers and accessories to many types of illicit criminal conspiracies.

    I actually read all 14 pages of Deirdra’s speech she gave yesterday at the 8th Annual Pharmaceutical Compliance Congress. She must have read the print from toilet paper, because there was nothing in it but feces!

    Deirdre you are fooling no one, but yourself! The PhRMA code of ‘02, was nothing but the fox guarding the hen house, and the revamped one of ‘09 is nothing but more of the same! Your industry has lost the public’s trust; rightfully so, and you conclude that the public should just forget your past behaviors, because of your new set of “core values”? Your audience was supposed to be impressed that you actually called a Dr. (”thought leader”) in California personally to explain these values? Oh how lucky he was to be graced by your genuine care and concern! I’m sure he kept the line clear of any other calls, because yours was so monumental to his practice! Right!

    Deirdre you have it all wrong! You have lost the trust of the public and health care professionals, simply because you cannot be trusted! Unfortunately for you, history has made it is quite clear that your industry is quite incapable of “doing the right thing” unless you are under constant direct and oppressive supervision from the Department of Justice, and even then your kind will still try to sneak by with whatever you can get away with! Just because you say you’ve changed, doesn’t make it true! What you fail to understand, and it is abundantly clear in your pathetic attempt to spin your problems to a positive outcome; is that Leadership, Ethics and Morals are about doing the “right thing” when no one is watching. Of course now, everyone is watching!

  12. The book Pharmaplasia(TM)goes into considerable detail about the missteps of the pharmaceutical industry over the past several decades and more importantly identifies the root causes for what went wrong and why. The solutions to fixing the industry’s current state of dysfunction are less daunting than most industry executives would lead you to believe.
    mike@pharmareform.com

  13. Ed, with all due respect, the photo in the Fortune article below shows Deedee Connelly more appropriately in her more usual arrogant demeanor rather than that fake smile you have attached to this blog, at least for those who have had the misfortune to know or meet her. Unfortunately that includes my wife, who, as a former Director at Eli Lilly was constantly butting heads with Deedee as HR head. It is generally agreed that during her tenure, Connelly established Lilly as the industry model of how NOT to run HR. She is the living embodiment of The Peter Principle. Should have topped out when she carried the bag.

    http://money.cnn.com/2006/09/29/magazines/fortune/mpw.connelly.fortune/index.htm

  14. The general public (and sadly, possibly our elected officials) have NO idea what is going on behind the doors of most pharma companies. While I will acknowledge that the pharma marketing and sales groups are getting smarter about cleaning/ covering up their past sloppy behaviors, they are still as snarky as ever. Instead of handing out direct payments - they are laundering their large marketing budgets through clinician and patient advocacy groups. The only way to stop these behaviors is to ramp up the penalties.

  15. Remember, this woman came fro Eli Lilly where there was MASSIVE problems with illegal activity in marketing.

  16. I was talking to a local physician recently about the Glaxo issues. He told me that he recently had to order the GSK drug Bactroban for his office. He noticed a significant price increase and we talked about whether or not the cost of GSK’s settlement is being reflected in the price increase. We also talked about the fact that under the ‘Learned Intermediary Doctrine’ he can be held liable for GSK’s adulterated Bactroban dispenses. Given that 1. the brand was adulterated for quite some time and he was never told about it and 2. given the cost savings associated with the generic version of Bactroban, Mupirocin, and 3. the fact that Medicaid and insurers reimburse him the same amount no matter whether he is using a generic that might be produced in a country where the FDA has little to no presence or the brand, which in this case has a past history of quality issues, he ordered the generic and told me that he feels like he can’t win and is liable either way. This really made me think that no one wins in a situation like this.

    A company like GSK has so much - they have enough- but it seems like for some former GSK execs, enough was not enough. I hope that enough is enough to satisfy current GSK executives and board members.

  17. I’m always amused by those who seek praise for doing what they ought to have been doing all along.

    imho, GSK should meditate on the old homily “Virtue is its own reward”

  18. John Edwards is to politics as GSK is to?

  19. Deidre Connelly looks a lot like Carrie Cox and is rumored to be just as ruthless. Could it be that they are long-lost sisters, perhaps even evil twins?

  20. What a numbnuts!!

  21. SP, sisters maybe. Perhaps Deedee will see fit to visit Carrie in prison after she is convicted of securities fraud.

  22. Which will GSK be trying to market the most - its’ innocence or the products they got on the market from inadequate and corrupt research practices. Avandia now Paxil. The worst part is that after 25 years in the industry, I know that GSK is not alone in their bad behavior. I call it the 3 Monkeys syndrome. Who are they kidding?

    GSK fired me in August 2010 for discovering and reporting to my manger fraud and study misconduct at a high-enrolling, high-prescribing research site in November 2009. My manger and the project team told me to ignore it because the FDA would never know. They hid the evidence documented in my monitoring resports. So GSKs new dumb act, or, would you call it victim of greedy whistleblower act, is really beyond farcical. I am happy for those whistleblowers that get financial reimbursement for the ethical grief they endured – they deserve every penny for the feeling of justice. Unfortunately, those of use in research get nothing but the grief in knowing the truth about how drugs and devices are researched. I wish there was a measure of justice but reporting fraud and misconduct to the FDA goes nowhere.

    Since GSK’s clinical research division was placed under the marketing department just last summer, GSK is no longer hiding the fact that it uses clinical research studies as a marketing tool. So now that marketing reps cannot hand out pens and trips, they are changing prescribing habits by promising physicians a chance to profit from conducting a study trial. GSK study monitors are now forced to allow their RMS staff to attend monitoring visits to get into see physicians. It is really apparent the GSK marketing staff rule the research division. They are also forcing the monitors to approve physicians who were promised a study by an RMS but are not qualified to conduct the study. If you don’t give approval of an RMS recommend physician to conduct a study, you get fired or overruled. Clinical research either pre or post-market studies should not be used as a marketing technique– it is a bad mix with deadly results.

  23. Me thinks she doth protesteth too much…

  24. Ethical Monitor is correct, and it isn’t even really a big secret anymore. A number of years ago, the journal Medical Economics (aka 10 easy steps to becoming a rich doctor, more widely read than NEJM) published an article on how any physician can supplement his/her income by getting into doing clinical trials as a side business. The article expained how the ROI on doing clinical trials is much greater than that from seeing patients. I’m sure that’s even more true today, with reimbursements drying up everywhere. As EM indicated, if you’re a high writing doc, you may not get an all expense paid trip to Aruba anymore, but you can more than make up for it in consulting fees or doing trials.

  25. The really scary part about what Ethical says is the incredible influence that marketing departments have over every aspect of pharma today, even R&D and clinical trials.

    My current company allows marketing almost total veto power (and almost total design power) over clinical trial development.

    THAT is scary.

  26. Thank you to those who know and agree. If people don’t discuss the reality, or complain as some people say, how will thinks change for the better.

    GSK is doing an Urkel - “Did I do that”.

    The other misconception is that all the billions that PhRMA claims the industry spent on Research actually includes marketing costs; Especially large Phase IV studies which are studies (often not followed by the FDA) to get patients using their product. A good example of this was the 2004 Aventis GOT trial aimed at getting 6000 new patients using Lantus. This was a purely post-marketing study and the majority of the 1200 investigators were being hand-picked by the sales representatives. There were no 1572s and the FDA was not involved because the captured data was not going to be submitted to them. As a Monitor having to qualify investigators for that trial the majority did not know anything about conducting a clinical research trial or how much work is involved to conduct the study visits, document and record the data. Some investigators were even giving the Lantus with the investigational drug label to non-study patients who had not signed consents as if it were a sample. Even worse, the A1C monitoring instrument that subjects were supposed to be using during the GOT study were not sent to the sites and the staff were expected to start enrolling subjects without this very crucial device to capture the study data.

    Pharmas just place the costs under the research division and hide what is truly marketing. So when PhRMA rolls out their figures on how much they spend on research, remember, it really isn’t all research.

    PS: It will be interesting to see if Lantus gets taken off the market in ten years for its purported (and in many cases documented) risk for increasing cancer.

  27. The pharmaceutical industry spent more than $65 billion last year searching for new medicines to treat diseases including cancer, heart disease and Alzheimer’s. It’s critical for that research to be conducted with integrity and objectivity so that the information and medicines it yields are of the highest quality and help inform good patient care.

    At GlaxoSmithKline (GSK), we have implemented rigorous standards for the conduct of clinical trials and the separation of marketing and R&D. These rules are reviewed regularly to make sure they keep pace with society’s expectations and current ways of working.

    So the public can be assured that our science is conducted to rigorous standards, GSK makes our data publicly available - whether clinical study results are positive or negative - so the public and scientists can evaluate our research practices. We submit manuscripts to medical journals for publication, but even if those are not accepted, we post our results on our online Clinical Study Register (CTR).
    To ensure further transparency, we are committed to voluntarily disclosing online the research payments we make to healthcare professionals and their institutions.

    We encourage employees to report any suspected violations of our policies in a variety of ways, including our compliance hotlines, and all complaints are investigated. We also have a stringent policy against retaliation.

    Dear Ethical Monitor, I would also like to personally encourage you to contact us to discuss your concerns and experiences.

    Joseph Near
    Compliance Officer, GSK R&D

  28. Mr Near, if your statement is to be taken at face value, that would mean there is no influence of Marketing overal investigators

    -selection of clinical investigators
    -clinical trial protocol design
    -selection of primary and secondary enpoints
    -post hoc statistical analyes
    -publication plan
    -writing of scientific papers
    -design of phase IV studies for additional indications.
    -compliance review of DDMAC submissions.
    -selection of presentations at scientific meetings

    In 30 years working with all major companies, including GSK, I must say, with all due respect that I find your assertions preposterous. Better to compare your canned mission statement with reality.

  29. Mr. Near, the policies and procedures at GSK have always had a double standard! Don’t sell off label, wink, wink, we don’t do that! It is simple GSK cannot be trusted and time will do nothing but confirm that statement. Anywhere on the time line going forward or in the rear view mirror, you pick it! Letting go RVP’s because of their involvement in past illegal activity, to then turn around and hire the same RVP’s back as consultants is a bit disingenuous don’t you think? Your job as chief compliance officer is to bury the truth, and obstruct any investigations. Just ask your predecessor Roger! Your statement is nothing but more of the same! We have heard it all before, several times. Why don’t you leave your “public relations” nightmare to the professionals at Bursen-Marsteller? Meanwhile we will all watch your RMS’s run with the illegal football and again time will show just how full of it you are!

  30. The pharmaceutical industry spent more than $65 billion last year searching for new medicines to treat diseases including cancer, heart disease and Alzheimer’s.
    With nothing but new versions of very old drugs already available generically to show for it!

    It’s critical for that research to be conducted with integrity and objectivity so that the information and medicines it yields are of the highest quality and help inform good patient care.
    Nice diversion huh? My other hand was handing over cash, and lots of it to our investigator “partners”. You never even saw that one, I’m good!

    At GlaxoSmithKline (GSK), we have implemented rigorous standards for the conduct of clinical trials and the separation of marketing and R&D. These rules are reviewed regularly to make sure they keep pace with society’s expectations and current ways of working.
    Sure we had the same rules before, but we really really mean it this time! Sucker!

    So the public can be assured that our science is conducted to rigorous standards, GSK makes our data publicly available - whether clinical study results are positive or negative - so the public and scientists can evaluate our research practices. We submit manuscripts to medical journals for publication, but even if those are not accepted, we post our results on our online Clinical Study Register (CTR).
    We had to do this because we got popped for hiding Paxil data, and most recently Avandia data too. So now we have to do this, it isn’t really by choice.

    To ensure further transparency, we are committed to voluntarily disclosing online the research payments we make to healthcare professionals and their institutions.
    Of course we did this before we were forced to by the sunshine laws pending, and according to ProPublica the numbers don’t match up quite right, and we only go back to 2008, because before that it was a free for all baby!

    We encourage (dare) employees (insane and selfish) to report any suspected violations of our policies in a variety of ways (non of them will work, and neither will you again), including our compliance hotlines, and all complaints are investigated (then promptly buried next to the ex-employee).

    We also have a stringent policy against retaliation.
    That we selectively apply only when convenient.

    Dear Ethical Monitor, I would also like to personally encourage you to contact us to discuss your concerns and experiences.
    This is so we can make sure you shut your mouth!
    Joseph Near
    Compliance Officer, GSK R&D

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