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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
In the Matter of GlaxoSmithKline plc · GlaxoSmithKiline's Involvement in China between 2010 and 2013

Case Information

In the Matter of GlaxoSmithKline plc

Related FCPA Matter:   GlaxoSmithKiline's Involvement in China between 2010 and 2013 Information

Case Information

Initiation Date:    09/30/2016  Information

Prosecuting Agency:    U.S. Securities and Exchange Commission

Type of Action:    SEC Administrative Proceeding

Docket or Case Number:    3-17606

Name of Prosecuting Attorneys:    Unknown

US Assisting Agencies:   Unknown

Foreign Enforcement Action/Investigation:   Unknown

Foreign Assisting Agencies:   Unknown

Origin of the Proceeding:    Unknown

Whistleblower:    Yes (Highly-placed whistleblower in GlaxoSmithKline's China operation )

Case Status:    Resolved


Summary  Information

GlaxoSmithKline plc ("GSK"), a corporation incorporated and headquartered in the United Kingdom, was a global provider of pharmaceuticals and consumer health care products. Its common stock was registered with the SEC and traded on the New York Stock Exchange.

GlaxoSmithKline (China) Investment Co Ltd (“GSKCI”) was a wholly-owned subsidiary of GSK that sold and marketed its pharmaceutical products in China.

Sino-American Tianjin Smith Kline & French Laboratories Ltd (“TSKF”) was a public-private joint venture with Tianjin Zhong Xin Pharmaceutical Group Corporation Ltd and Tianjin Pharmaceutical Group Co Ltd. GSK indirectly owned 55 percent of TSKF.

From 2010 to June 2013, GSKCI and TSKF engaged in a variety of transactions that included possible improper payments to healthcare professionals in China, who are considered foreign officials because China's healthcare system is state owned and controlled. These payments took the form of gifts of electronics as well as travel expenses and speaking fees that were not properly recorded and could thus not be verified as legitimate.

On September 30, 2016, the SEC filed a settled administrative action against GSK alleging violations of the books & records and internal controls provisions of the FCPA. Under the terms of the settlement, to which GSK neither admitted nor denied the findings, the SEC ordered GSK to cease and desist its violations of the FCPA, to pay a civil penalty of $20 million, and to undertake and enhanced anti-corruption compliance polices and procedures, including reporting on the status of those policies and procedures to the SEC for a term of 2 years.

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