AMR Benchmark Opportunities: progress update

Research-based pharmaceutical company

GSK plc
This table is part of a November 2023 report that looks at what actions each company in scope of the Antimicrobial
Resistance (AMR) Benchmark has taken with regards to each of the Opportunities set out in its 2021 AMR Benchmark
Report Card. The full 2021 Report Card is also included in this PDF.

2021 O PPO RTU N IT Y

2023 U PDATE

What was the Opportunity shared in the AMR Benchmark?

What progress has been made on this Opportunity?

Expand and tailor access and stewardship plans for

GSK adheres to a structured process to develop accesscritical late-stage R&D projects.

plans for all R&D projects in Phase II and beyond. The

As a leader in antibacterial and antifungal R&D with thecompany is implementing an evaluation process to system-

largest pipeline, GSK can further strengthen their compa-

atically determine which late-stage pipeline projects can

ny-wide policies and project-specific plans to ensure newbring benefits to lower-income countries. In the context ofmedicines are swiftly available to those in critical need

AMR, GSK commits to exploring additional indications forbut also to prevent excessive use. GSK maintains policies

antibiotics under development.

and plans for their late-stage R&D projects and can make

For its vaccine Bexsero, targeting meningitis B, GSK has

plans more wide-reaching and timely. As an example, foraccess plans in place in Thailand. Third-party clinical trials

its vaccine Bexsero, that is in phase III targeting N. gonor-

around the world, including Thailand, are ongoing to assessrhaeae, GSK can define the access countries where it plans

Bexsero’s cross-protective effect against N. gonorrhaeae.

to file for registration, based on burden of disease andFurthermore, GSK continues to commit to developing

where resistance for N. gonorrhaeae is highest and where

new surveillance programmes that will cover the antibiotic

it considers ability-to-pay in its pricing strategy. In addition,

R&D projects in late-stage development.

GSK can expand its stewardship plans for its medicine R&D
projects through more comprehensive surveillance activities
by covering more priority pathogens and countries, as well
as re-evaluating its sales practices for when these medicinesreach the market to safeguard them from overuse andmisuse.
Increase public disclosure on environmental risk

GSK maintains its practice of publicly sharing some aspects

management.

of its environmental risk management strategy. GSK publicly

GSK publishes information on some of the components

reports that in 2022 all its own sites and 98% of its antibi-of its environmental risk-management strategy including

otic manufacturing supplier sites were in compliance withcompliance percentages of its own and suppliers’ sites with

discharge targets outlined by the AMR Industry Alliance.

discharge limits. While it reports 100% compliance at its

However, the company does not publicly disclose results

own sites, it can disclose more information to provide clearof product-specific audits, encompassing antibacterial

evidence of its progress publicly. Disclosure of information,discharge levels for its own sites and suppliers’ sites.

including the results of audits and antibacterial discharge

Additionally, GSK does not disclose the names and locations

levels of its own sites and suppliers’ sites, is important. It canof its suppliers.

also publicly disclose the names and locations of its suppliers and waste-treatment plants for increased transparency.
GSK can also apply limits directly in effluent to fully mitigate
AMR risk.
Comprehensively mitigate COI for educational

GSK continues to be involved in educational stewardshipprogrammes.

activities, while reporting comprehensive conflict of interest

GSK organises medical education programmes for health-mitigation across all organised activities. The company

care professionals on responsible use of antimicrobial medi-

maintains a practice of excluding product branded materials

cines. It ensures that branded materials are not used in mostfor any education programme centred on the responsible

educational programmes. It can ensure that this is applied inuse of antimicrobial medicines.

all educational programmes.

11

AMR Benchmark Opportunities: progress update

Research-based pharmaceutical company

2021 O PPO RTU N IT Y

2023 U PDATE

What was the Opportunity shared in the AMR Benchmark?

What progress has been made on this Opportunity?

Fully decouple incentives for sales agents from sales

GSK does not fully decouple incentives for sales agents

volumes.

from sales volumes. Instead, sales agents are deployed to

GSK links part of its sales agents’ incentives to sales vol-promote its antibacterial and antifungal medicines, withumes of antibacterial and antifungal medicines. It can fully

sales incentives partially decoupled from sales volumes.

decouple incentives for sales agents from sales volumes
again.

GSK maintains a capped compensation ratio of 75% fixedand 25% variable pay for primary care sales agents, including
those selling the company’s anti-infectives portfolio.

Publicly share raw data from surveillance programme.

GSK has shared the anonymised raw data from the multina-

GSK runs the multinational Survey of Antibiotic Resistancetional Survey of Antibiotic Resistance (SOAR) programme(SOAR) programme, which is focused on community-ac-

to the AMR Register, an initiative by Vivli.

quired respiratory-tract infections. It can publicly share raw

As with all datasets available on AMR Register, the data-

data from this surveillance programme, following throughset is available for researchers to access after submitting a

on clear commitments to share this with the University ofrequest, which is then subjected to a review by Vivli and the

Washington (as part of the GRAM project) and on the AMR

relevant company before data is shared.

Register.

GSK extended this data-sharing commitment fromthe SOAR programme to the 2022 Global Research on
Antimicrobial Resistance (GRAM) report, which included
single drug-resistance profiles.

12Antimicrobial Resistance Benchmark 2021

GSK

Overall Performance
2020

2021

86% 84%▼

Access to Medicine Foundation

GlaxoSmithKline plc
Large R&D-based pharmaceutical company
Stock exchange: LSE • Ticker: GSK • HQ: Brentford, UK • Employees: 94,066

GSK
PERFORMANCEGSK is the leader among the large research-based pharmaceutical

Performance in the Benchmark

0%companies in scope and performs well in its evaluated Research Areas.
R&D: With 31 R&D projects, about half of them vaccines, GSK leads in
R&D. Eleven of its projects target critical and/or urgent pathogens. Twoof its medicine candidates in clinical development are novel. GSK reports
access and/or stewardship planning for all five of its late-stage projects.
Responsible Manufacturing: Performs strongly. Reports comprehensive
environmental risk-management strategy for own sites and suppliers;

Appropriate Access: Performs strongly. Files some of its on- and off-

on-patent antibacterial vaccines in access countries.
Stewardship: Performs well. It partly decouples incentives for sales
agents from sales volumes. It publicly shares aggregated results of its
SOAR surveillance programme. It reports broad conflict of interest
mitigation for its educational programmes. It adapts brochures and100%

Points93%

R&D

28/ 3087%

Manufacturing

13/ 1580%

Access20/ 2575%

Stewardship0%

15/ 2050%

100%

How GSK was evaluatedpatent products for registration in access countries. Reports several
strategies to expand access and ensure continuous supply to its

50%

76/ 90

Performance by Research Area

co-leads in reporting compliance with limits at own sites and suppliers;
publicly discloses this compliance.

Points84%

Overall score

A R&D

1

2.1 2.2 2.3 2.4

3

●

●

●

●

1

2

3

B Manufacturing ●

●

●

●

●

1.1

1.2 1.3 2.1 2.2 2.3

3

C Access

●

●

●

4

5

6

7

C Stewardship

●

●

●

●

●

●

●

●

packaging for patients.
● ● ● Scored●

Not scored

OPPORTUNITIES FOR GSKCHANGES SINCE 2020

Expand and tailor access and stewardship plans for critical late-stage R&D projects. As a leader in• In February 2020, GSK joined the Project toantibacterial and antifungal R&D with the largest pipeline, GSK can further strengthen their compa-

Accelerate New Treatments for Tuberculosis

ny-wide policies and project-specific plans to ensure new medicines are swiftly available to those in(PAN-TB), a collaboration among philan-

critical need but also to prevent excessive use. GSK maintains policies and plans for their late-stage

thropic, non-profit and sector partners thatR&D projects and can make plans more wide-reaching and timely. As an example, for its vaccine

aims to develop an investigational drug regi-

Bexsero®, that is in phase III targeting N. gonorrhaeae, GSK can define the access countries where
it plans to file for registration, based on burden of disease and where resistance for N. gonorrhaeae

men capable of treating all forms of TB.
• Compared to 2020 Benchmark analysis, GSK

is highest and where it considers ability-to-pay in its pricing strategy. In addition, GSK can expand its

tracks the compliance of its own and suppliers’

stewardship plans for its medicine R&D projects through more comprehensive surveillance activi-

sites with discharge limits. All of GSK’s own

ties by covering more priority pathogens and countries, as well as re-evaluating its sales practices

sites and 95% of its suppliers’ sites are report-

for when these medicines reach the market to safeguard them from overuse and misuse.
Increase public disclosure on environmental risk management. GSK publishes information on

edly compliant with discharge limits.
• Since 2020, GSK has publicly shared infor-

some of the components of its environmental risk-management strategy including compliance per-mation on compliance percentages of own

centages of its own and suppliers’ sites with discharge limits. While it reports 100% complianceand suppliers’ sites, specific to antibacterial

at its own sites, it can disclose more information to provide clear evidence of its progress pub-production.

licly. Disclosure of information, including the results of audits and antibacterial discharge levels of• GSK received funding from CARB-X, up to

its own sites and suppliers’ sites, is important. It can also publicly disclose the names and locations

USD 18 mn, to support the development ofof its suppliers and waste-treatment plants for increased transparency. GSK can also apply limits

two unique vaccine projects that target thedirectly in effluent to fully mitigate AMR risk.

prevention of group A streptococcus (Strep A)

Comprehensively mitigate COI for educational programmes. GSK organises medical education

infections and infections caused by Salmonella

programmes for healthcare professionals on responsible use of antimicrobial medicines. It ensuresenterica which cause invasive nontyphoidalthat branded materials are not used in most educational programmes. It can ensure that this issalmonellosis (iNTS) disease and typhoidapplied in all educational programmes.

fever. Currently there are no vaccines available

Fully decouple incentives for sales agents from sales volumes. GSK links part of its sales agents’against these infections.

incentives to sales volumes of antibacterial and antifungal medicines. It can fully decouple incentives for sales agents from sales volumes again.
Publicly share raw data from surveillance programme. GSK runs the multinational Survey ofAntibiotic Resistance (SOAR) programme, which is focused on community-acquired respiratory-tract infections. It can publicly share raw data from this surveillance programme, following through on clear commitments to share this with the University of Washington (as part of the
GRAM project) and on the AMR Register.

2

Antimicrobial Resistance Benchmark 2021

Access to Medicine Foundation

SALES AND OPERATIONS

GSK
Turnover by business segment

Therapeutic areas: Respiratory, HIV, Immuno-inflammation, Oncology

2019

Business segments: Pharmaceuticals, Consumer healthcare, Vaccines

2020

Product categories: Innovative medicines, Vaccines, Consumer health

17,554
17,0560

products

10,000

Pharmaceuticals

M&A since 2020: In July 2019, GSK and Pfizer combined their consumer
health care business in a new joint venture, with GSK having the majority and controlling an equity interest of 68%. In February 2021, GSK signed

7,157

8,995

6,982

10,03320,00030,000Consumer
Consumer
Healthcare
Healthcare

Vaccines

40,00050,000mn GBP

40,00050,000mn GBP

GSK
Turnover by region

an agreement to sell the cephalosporin antibiotic business to Sandoz

201913,8908,069(Novartis division) for USD 350 mn in addition to milestone payments up to2020

14,5568,164

USD 150 mn.

010,000

United States

11,795
11,37920,000Europe30,000International

PIPELINE for pathogens in scope

PORTFOLIO for pathogens in scope

Pipeline size: 31 projects targeting pathogens in scope* (15 antibacterialMid-sized portfolio: At least 51 products: 28 antibacterial medicines; 19

medicines; 15 antibacterial vaccines; 1 antifungal vaccine)

antibacterial vaccines; 4 antifungal medicines

Development stages: 10 clinical projects, 5 in Phase I, 2 in Phase II and 3 inOn-patent vaccines: 8 (Infanrix® IPV Hib, Infanrix® Hexa, Boostrix®,

Phase III, including a Phase III project for an expanded indication of its sero-

Infanrix® Hib, Boostrix® Polio, Menveo®, Bexsero®, Synflorix®)group B meningococcal vaccine (Bexsero®) for the prevention of gonor-

Off-patent/generic medicines: 9 of 43 were selected for analysis* (amox-rhoea; and 19 discovery/preclinical projects.

icillin [A], amoxicillin/clavulanic acid [A], cefadroxil [W], cefuroxime [W],Novelty: 2 novel projects, GSK-3036656, for the treatment ofclotrimazole [F], colistin [R], dapsone [T], griseofulvin [F], polymixin B [R])Myobacterium tuberculosis, that meets all four WHO innovativeness

AWaRe medicines**: 8 Access group; 9 Watch group; 2 Reserve group

criteria; and gepotidacin, for the treatment of infections caused by

Anti-TB medicines**: 1Enterobacteriaceae and Neisseria gonorrhoeae, and which belongs to a
new chemical class and has a new mode of action.

GSK
Pipeline for priority pathogens‘Critical’ and/or ‘urgent’ pathogens: 11 projects, with the focus on carbapenem-resistant Escherichia coli and drug-resistant N. gonorrhoeae. GSK has
one vaccine against C. difficile in Phase I of clinical development.
Regulatory approvals: 0 approvals for products targeting pathogens in
scope.

15
0

10

15 1
20

30

40

● Antibacterial vaccine● Antibacterial medicine● Antifungal vaccine● Antifungal medicine

GSK
Products on the market
19
0

20

28 4
40

60

● Antibacterial vaccine● Antibacterial medicine● Antifungal medicine

PERFORMANCE BY RESEARCH AREAA

RESEARCH & DEVELOPMENT Evaluated: medicine & vaccine pipelines for priority* bacteria & fungi

A.1

Largest amount invested in R&D

lute R&D investment figure compared to thetargeting bacterial and fungal pathogens. Out

GSK reports to the Benchmark the amountother companies who reported investments toof the 31 projects, ten are in clinical develop-

invested during 2019 and 2020 in R&D for anti-

the Benchmark. GSK is a contributor to the AMR

ment, 19 are in discovery/preclinical stage andbacterial and antifungal medicines and/or vac-

Action Fund.

2 projects are in technical lifecycle. GSK did notcines for pathogens in scope. Specific invest-

obtain marketing approval for any of its products

ment figures were provided under confidential-

A.2.1 GSK has the largest R&D pipeline among

ity. GSK reports above average R&D investments

the large R&D-based companies

relative to its revenues among the compa-

The company reports 31 projects targeting path-nies assessed. GSK reports the largest abso-

ogens in scope: 15 medicines and 16 vaccines,

during the period of analysis.

Pipeline targeting priority pathogens: 31*** As at 24 September 2021
Discovery

Pre-clinical

Phase I

Phase II

Phase IIIIMI ENABLE or Shigella♦ Enteric fever (bi-valent
conjugate) vaccine [S.
enterica (typhi & paratyphi A)]♦ Invasive non-typhoidal
Salmonella (iNTS; bi-valent GMMA) vaccine [S.
enterica serovars typhimurium + enteritidis]♦ Shigella spp. (multivalent GMMA-based)vaccine♦ Invasive non-typhoidal
Salmonella (iNTS; bi-valent GMMA) vaccine [S.
enterica serovar Typhimurium + Enteritidis &conjugate for S. enterica
serovar Typhi)]♦ Group A Streptococcus(4-valent recombinantconjugated adjuvanted)
vaccine♦ C. difficile vaccine(GSK2904545A)

GSK-070 (GSK3036656) [M. tuberculosis]

Gepotidacin [E. coli]* See Appendix V for information about eligibility for R&D projects andAppendix VII for eligibility
criteria of products.
** Listed on the 2019
WHO EML.

♦ Staphylococcus aureus
vaccine (GSK3878858A)
FimH (GSK3882347)[E. coli]♦ M. tuberculosis prophylactic vaccine [GSK692342/
SB692342; M72/AS01E]

Approval

Gepotidacin - additional
indication [N. gonorrhoeae]♦ N. gonorrhoeae vaccine (Bexsero®) - additional indication of serogroup B meningococcal
vaccine♦ Vaccine
GMMA = Generalized modules for membrane antigens*** Includes 17 projects not shown in the figure: 15 projects provided to the Benchmark on the basis of confidentiality and 2 projects in technical lifecycle (heat-stable and cold-stable formulations of GSK’s Streptococcus
pneumoniae (Synflorix®) vaccine).

3

Antimicrobial Resistance Benchmark 2021

A.2.2 Pipeline with highest number of innova-

Access to Medicine Foundation

jects. GSK’s vaccines in clinical stages of devel-ing pathogens in scope. It reports having pro-opment include candidates targeting C. difficile,ject-specific access plans for most of these pro-

GSK’s clinical-stage medicine pipeline con-

S. aureus and N. gonorrhoeae. Moreover, GSK isjects. All five projects have ongoing trials insists of both innovative and adaptive R&D pro-developing M72/AS01E in collaboration with theaccess countries.†

jects. GSK has four innovative medicine anti-Bill & Melinda Gates Medical Research Institute,bacterial candidates in clinical development,a Phase II tuberculosis vaccine candidate.

tive candidates

making the company’s clinical pipeline the one
with the highest number of innovative candi-

GSK reports that it has developed an equitable pricing strategy framework for low- and middle-income countries (LMICs) that applies acrossA.2.4 Largest number of projects targetingits portfolio and business units. Its access plans

dates among all companies evaluated in the‘critical’ and/or ‘urgent’ pathogens

include equitable pricing strategies, registra-

Benchmark. This includes GSK-3036656, for

GSK has 11 projects targeting pathogens definedtion filings, non-exclusive licensing and supply

the treatment of tuberculosis, which meets allas ‘critical’ by WHO’s list of priority pathogens

chain commitments. GSK states that it does notfour WHO’s innovativeness criteria; and gepoti-

and/or characterised as ‘urgent’ threats by thefile patents in Least Developed or Low-Income

dacin, for the treatment of infections caused by

US Centers for Disease Control and Prevention

countries nor does it enforce historic patents.

Enterobacteriaceae and N. gonorrhoeae, which(CDC). In clinical development, GSK has medi-

GSK does not conduct clinical trials in countries

belongs to a new chemical class and has a newcine candidates against Carbapenem-resistant/where it does not intend to pursue registration

mode of action. GSK also has a non-traditional

ESBL-resistant E. coli and N. gonorrhoeae; andand to make the product available for use. GSK

medicine in clinical development.

vaccine candidates against C. difficile and N.

commits to conducting global surveillance stud-gonorrhoeae.

ies for its new antibacterials to enable appropri-

A.2.3 Largest vaccine pipeline

ate use and support stewardship.

GSK reports 16 vaccine projects in its pipeline.

A.3

project-specific plans for access and

It is by far the largest vaccine pipeline of the

stewardshipsix companies active in vaccine development. It
includes 13 innovative and three adaptive pro-Company-wide commitments and

GSK has five late-stage R&D projects target-B

RESPONSIBLE MANUFACTURING Evaluated: antibacterials manufacturing (APIs and drug products)

B.1

Comprehensive environmental risk-man-pliant with discharge limits.

agement for own sites and suppliers;

GSK expects external private waste-treat-levels themselves are not published. It also
does not publish: (1) the results of environmen-

tracks compliance with limits at own

ment plants to comply with its general envi-

tal audits, conducted at its own sites, the sites

sites and suppliersronmental standards. GSK audits these plantsof suppliers and/or external private and public

GSK reports a comprehensive strategy to mini-at least every 3 years (based on risk) whichwaste-treatment plants; or (2) a list of thesemise the environmental impact of wastewaters

includes checking the suitability of technologies

suppliers and plants.

and solid waste from antibacterial manufactur-

used for processing waste and protocols for pre-ing at its sites, including audits every three years.

venting contamination. It requests external pri-

It reports setting discharge limits in the receiv-

vate and public wastewater treatment plants foring environment for all antibacterials manufac-

dilution and flow rate data to inform the mass

tured at its sites, based on PNECs to limit AMR,

balance approach and employs conservative

GSK reports that its own sites and suppliers

as recommended by the AMR Industry Alliance.

measures when needed.

have a system to maintain high-quality antibac-

Discharge levels are quantified at all sites using

B.3

System in place to maintain production
quality for own and suppliers’ sites; norequests for official corrective action

terial production consistent with international
Publicly discloses some information on

GMP standards. This includes periodic risk-

cal analysis if applicable. GSK reports that all its

environmental risk management andbased audits and tracking of corrective and pre-20 sites, or 100%, are compliant with discharge

compliance with limits

ventive actions. GSK does not require its suppli-a mass balance approach, verified by chemi-

limits.

B.2

GSK publishes some components of its envi-

ers to audit their own suppliers, but do encour-

GSK requires third-party suppliers of anti-ronmental risk-management strategy and is aage them to do so. The Benchmark found nobacterials to follow the same standards, includ-

member of the AMR Industry Alliance. It dis-requests for official corrective action from theing limits based on PNECs. It reports conducting

closes that all its 20 (100%) own sites manufac-

FDA or EMA related to non-conformities withon-site audits every three years. It requests andturing antimicrobials and 32 of 45 (71%) of sup-cGMP at GSK’s own sites or any subsidiaries that

reviews the discharge levels of its suppliers. It

plier sites are compliant with discharge targets

manufacture antibacterials.

reports 37 of 39 supplier sites, or 95%, are com-

set by the AMR Industry Alliance.‡ The discharge

C

APPROPRIATE ACCESS & STEWARDSHIP – ACCESS

Evaluated: access activities relating to antibacterial & antifungal medicines & vaccines in 102 access countries†
GSK is not eligible for indicators: C.1.1 and C.2.1.

countries including 19 LICs. Seven of its rele-gate vaccine Synflorix®, filed in 45 access coun-

For more information, see Appendix VII.

vant products are filed in less than 10 accesstries followed by Infanrix® Hexa, its vaccine usedcountries.

to protect against diphtheria, tetanus, pertussis,

C.1.2 Filed to register off-patent/generic medicines in 16 access countries on average
GSK performs above average, filing eight of its

hepatitis B, polio and bacterial meningitis (Hib),
C.1.3 Filed to register on-patent vaccines in 17
access countries on averagenine relevant off-patent/generic medicines for

GSK has an average performance, filing seven ofregistration in 16 access countries on average. Its

its eight relevant on-patent vaccines for regis-

most widely filed relevant product is the antibi-

tration in access countries. Its most widely filed

otic amoxicillin/clavulanic acid filed in 62 accessrelevant vaccine is the pneumococcal conju-† 102 low- and middle-income countries
where better access to medicine is mostneeded.
‡ Discrepancy with compliance data in B.1
is explained by GSK’s submission data

for the Benchmark being more up todate than publicly available data.

filed in 31 access countries. Two of its eight relevant vaccines are filed for registration in at least
one LIC.

4

Antimicrobial Resistance Benchmark 2021

Access to Medicine Foundation

C.2.2 Several strategies to expand access to

on-patent vaccines in scope. It aims to expand

sharing by conducting 3-year forecasts andoff-patent/generic medicines

access to its on-patent vaccines in access coun-

annual long-term demand forecasting (up to

GSK performs above average. It aims to expand

tries through tiered pricing policies

10 years). GSK mitigates against shortage risks

access to its off-patent/generic medicinesand public or private partnerships. GSK partners

by keeping buffer stocks for both APIs and fin-in access countries through donations, sec-with MSF and UNICEF to provide Synflorix® atished products. It ensures dual sourcing for crit-ond-brands, patient support programs, tenders,

the lowest price tier during humanitarian situ-

ical APIs. GSK reports three capacity build-and equitable pricing policies. GSK provides evi-

ations. GSK provides evidence of patient reaching or technology transfer initiatives in accessdence of patient reach and geographic reach forand geographic reach for some of its reported

countries, such as its support to the Strategic

all its reported approaches. For example, GSK

approaches. For example, it estimates that 56

Training Executives Program (STEP) in GAVI-

donated more than 200,000 units of its branded

mn doses of Synflorix® were supplied to Gavi-

eligible countries. To mitigate against substand-amoxicillin/clavulanic acid antibiotic in 2020

eligible countries in 2020, through its partner-ard and falsified products, GSK works closely

through humanitarian partnerships, includingship with Gavi The Vaccine Alliance.

with local law enforcement, conducts online and

one with Save the Children.

offline investigations or uses security features
C.3

C.2.3 Several strategies to expand access to
on-patent vaccines

Leader in strategies to ensure

such as serialised barcodes and tamper-evident

continuous supply

packaging.

GSK performs above average, with strate-

GSK performs above average, with accessgies reported in all four areas assessed. GSK

strategies reported for all its eight relevant

ensures accurate demand planning and dataC

APPROPRIATE ACCESS & STEWARDSHIP – STEWARDSHIP

Evaluated: stewardship activities relating to antibacterial & antifungal medicines globally
C.4

Broad COI mitigation strategies in place

trends and/or include treatment guidelines forfor its educational programmes

healthcare professionals. In some countries

GSK performs well in conflict of interest (COI)

these include GSK SOAR surveillance data for

mitigation for the five AMR-related educa-

the antibacterials amoxicillin/clavulanic acid

GSK runs the multinational Survey of Antibiotic

tional programmes for HCPs assessed by the(Augmentin™) and cefuroxime (Zinnat®).

Resistance (SOAR) programme, which is focused

Benchmark. Four programmes have all three

C.7

Active in one AMR surveillance programme; openly publishes aggregatedresults

on community-acquired respiratory-tract infecMakes five types of brochure and/tions in more than 30 countries and has been

Benchmark: (1) content is developed inde-or packaging adaptations to facilitate

running since 2002. GSK only shares the aggre-

pendently from its marketing department; (2) aappropriate use by patients

gated results through peer-reviewed open-ac-

COI mitigation strategies looked for by theC.6

pledge not to provide financial or material incen-

GSK adapts brochures and packaging to facil-cess journal articles. In addition, it will be shar-tives to participants; and (3) it does not use

itate the appropriate use of amoxicillin/clavu-

ing SOAR data with the University of Oxford andbranded materials. The remaining programme

lanic acid (Augmentin™) by patients. GSK is the

University of Washington (as part of the GRAM

has two COI mitigation strategies: in some coun-leader in this measure, taking account of lan-

project) as well as on the AMR Register, antries where these programmes were presentedguage, adherence to treatment, literacy, theopen-access data platform, with these projects

the content could be branded.

environment and paediatric use. For exam-

aiming to complete in Q4 of 2021.

ple, it has translated a Patient Knowledge Card
C.5

Engages in sales and marketing practices

into English, French and Portuguese. This card

to address appropriate use

highlights information to improve adherence

GSK is middle-performing in sales practices. It

to treatment. Moreover, GSK has created blis-

reports that it partly decouples incentives forter packaging with a specific lidding foil that issales agents from sales volumes of its antibacte-sensitive to moisture for high humidity environ-rial and/or antifungal medicines. Its percentage

ments. Further, it has created oral suspensionsof variable pay linked to sales volumes is 25%,

and flavoured dosing syringes for paediatricand this is set at the smaller group level.

patients in 35 countries.

GSK engages in marketing practices that
aim to address the appropriate use of its antibacterial and/or antifungal medicines. Its marketing materials reflect emerging resistance5