CORE DOCUMENT VAULES

EXCELLENCE To take pride in doing things really well.

EECUTION To get things done through a bias for action.

PERIPHERAL VISION To see both the immediate task and the full picture, and to be sensitive to how one's actions affect others.

would likely consider it important in deciding whether to purchase or sell a security. Employees must not trade on inside information about Schering-Plough or other companies gained by virtue of their positions at Schering-Plough.

This means:

• Do not buy or sell securities if you have knowledge of material non-public information such as:
  • introduction of an innovative new product
  • significant new contracts
  • changes in dividends
  • mergers, acquisitions and joint ventures
  • major developments in litigation
  • earnings statements and forecasts
  • expected governmental actions
  • material licensing agreements
  • information you obtained about another company confidentially during the course of your work
• Do not give inside information to anyone else so they can trade.

Employees who have inside information can lawfully trade in the market once the information is made public and enough time has passed for the information to be absorbed by the public. This is usually at least 48 hours after the information is made public.

Trading in Securities Policy C-129. The Law department can answer questions about application of this policy.

Records Management

Maintaining complete and accurate records is essential to the work of Schering Plough, and care must be taken to ensure that records are managed properly.