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Table of Contents

     
INTRODUCTION TO THE STANDARDS OF GLOBAL BUSINESS PRACTICES 2
  What are the Standards of Global Business Practices? 2
  How do these Standards relate to the six Leader Behaviors we must exhibit in everything we do? 2
  Why are the Standards important to Schering-Plough’s success? 3
  Why do honest employees need the Standards? 3
  Who should follow the Standards? 3
  Where do the Standards apply? 4
  What laws apply to me? 4
  What are my individual responsibilities? 4
  What are management’s responsibilities? 5
  Can the policies summarized in the Standards be waived? 5
     
THE STANDARDS – IN OUR WORKPLACE 8
  Equal Treatment 9
  Discrimination/Harassment-Free Work Environment 9
  Safety and Health 10
  Drug and Alcohol Abuse 10
     
THE STANDARDS – IN THE MARKETPLACE 14
  Competition and Antitrust Laws 15
  Unfair Business Practices 16
  Bribery and Corruption 17
  Competitive Intelligence 18
  Gifts and Entertainment 19
  Marketing Integrity 20
  Privacy and Information Security 20
  Scientific Integrity 21
  Product Quality and Patient Safety 22
  Trade Issues 23
     
THE STANDARDS – IN OUR BUSINESS 26
  Books and Record Keeping 27
  Company Computers and Software 28
  Confidential Information, Intellectual Property and Proprietary Information of Others 29
  Company Funds, Property, and Time 31
  Conflicts of Interest and Corporate Opportunities 32
  Trading on Inside Information 33
  Records Management 34
     
THE STANDARDS – IN OUR COMMUNITIES AND IN THE PUBLIC 38
  Protecting the Environment 39
  Animal Welfare 39
  Media and Public Inquiries 40
  Political Activity and Lobbying 40
  Investigations 41
     
RAISING CONCERNS AND SEEKING ADVICE 44
  What if I have questions about the Standards? 44
  When should I raise concerns? Whom should
I contact?
44
  How does the Integrity Action Line work? 44
  Will my identity be kept confidential? 45
  How long will it take to get a response? 45
  What about disciplinary action? 46
  May I report a concern directly to the Board of Directors? 46
  What if I fear retaliation? 47