Where
do the Standards apply?
The Standards
apply regardless of the country in which you work. However,
application of the Standards
may vary in different countries, due to local business practices
or a need to comply with local laws and regulations. In any
situation where you are unclear about how the Standards
apply, you should consult your immediate supervisor or another
manager, the Law department, or your local Compliance Officer.
What laws apply to me?
Schering-Plough employees are subject
to the laws and regulations of the country in which they work
and, because Schering-Plough is incorporated in the United
States, they may also be subject to certain U.S. laws and
regulations. In situations where U.S. laws and regulations
differ from local laws and regulations, employees should generally
apply the stricter law. Employees should consult their immediate
supervisor or another manager, the Law department, or the
local country Compliance Officer if questions arise.
What are my individual responsibilities?
You are responsible for becoming
familiar with, and following, all the laws, regulations and
company policies that apply to your job and level of responsibility.
You are also responsible for seeking advice when needed, raising
concerns and reporting suspected or known violations of law,
regulation or company policy. Although you may not know certain
specific legal requirements in all situations, you should
know if something doesn’t seem appropriate. In any such
situation, you have an obligation to follow-up and to use
company resources, such as your immediate supervisor or another
manager, the Law department, your local Compliance Officer,
or call the Integrity Action Line to find an answer or raise
a concern. The Integrity Action Line is described fully on
page 44.
What are management’s responsibilities?
Managers have a responsibility to
set the right example – to
Lead with Integrity. Each
manager is responsible for informing the people who work for
him or her about company policies and ensuring that they have
adequate knowledge and resources to take action. Managers
are also responsible for enforcing company policy, monitoring
employee compliance, implementing discipline for misconduct
and ensuring that employees who raise concerns regarding potential
misconduct receive appropriate support.
Can the policies summarized in
the Standards be waived?
Waivers of the policies summarized
in the Standards
are an exception and will only be granted in special circumstances.
Schering-Plough will waive a policy only where:
- Circumstances warrant granting a waiver,
- Such waiver would not permit illegal or unethical conduct,
and
- There are appropriate controls over the particular situation.
Waivers for employees will be made
only with the approval of the Senior Vice President, Global
Compliance and Business Practices. Waivers of any of the provisions
of the Standards
for corporate officers may be made only by the Business Practices
Oversight Committee of the Board of Directors after receiving
the recommendation of the Senior Vice President, Global Compliance
and Business Practices. Waivers relating to the CEO, CFO and
Controller will require approval of the Audit Committee of
the Board of Directors. Such waivers, if granted, will be
promptly disclosed as required by law, regulation and New
York Stock Exchange rules. |
