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. |
