The MOVs to earth probably violate UL 1449, anyway.
I would strongly suggest purchasing a copy and reading it in detail; it's a bit of a slog, reading standards, but it is the primary source. It would be foolish to take random answers on the internet at their word, when it comes to something as important as product safety!
On that note: I wasn't able to find a copy of it to prepare this answer, so consider this hearsay and apocrypha. The safety-related discussion is however motivated by standards such as IEC 60950-1, which I have read. The mains wiring is common knowledge, and also reflected in various standards and codes.
Most often, a GDT is used, in series with the earth connection to the pair of MOVs, to eliminate ground leakage current.
A GDT is not used, alone, because once ignited by a surge, it can continue to conduct, when neutral-earth voltage is present.
High neutral can occur in two situations: swapped lines (unpolarized or incorrectly wired outlets), and both-lines-high environments. North America residential 240V is 120-0-120V with respect to earth (both hot), and commercial/industrial circuits can also be 208V or 240V line-to-line (three phase). It is not a good assumption to assume neutral is always near earth.
Note that much equipment gets by without common-mode surge protection, by merely handling the voltage with sufficient isolation. 2.5kV is a typical rating; it's given by the CAT(egory) rating of the equipment.
Without specifications for what you're protecting, or what standards you aim to meet, I'm afraid there isn't much to be said about your circuit, nor transformations of it.
Here is one article illustrating a simplification:
A circuit simplification for AC power supply surge protection devices | EDN
however, note that they do not test a high-neutral condition, which as mentioned, can result in a fault or hazardous condition.