Bribery and Corruption

Often in our industry, a country’s government is both the regulator of our products and a major customer. We also retain the services of scientists and doctors for consulting and research activities and many of them are employees of public institutions and may be considered government officials.

Most countries in which we do business have laws that forbid making, offering or promising of any payment or anything of value (directly or indirectly) to a government official (and under the U.S. Foreign Corrupt Practices Act this includes foreign political parties and candidates) when the payment is intended to influence an official act or decision to obtain or retain business or secure an unfair business advantage. These laws apply even when the payment is made outside of the home country.

In the United States there is a related anti-bribery law, known as the anti-kickback law, that prohibits inducing someone to recommend or purchase a healthcare product or service covered by a federal healthcare program. The purpose of this healthcare law is to eliminate the influences of money or things of value in the selection of such products or services.

Employees of Schering-Plough must comply with these anti-bribery laws. Violations of these laws will not only result in the loss of business but may also lead to severe criminal and civil penalties for Schering-Plough and the individuals involved. To put it simply, bribery of any kind is illegal worldwide and we will not engage in it.

This means:

• Never make payments or offer gifts, services or anything of value to government officials, employees of public institutions, or persons that prescribe, purchase or promote Schering-Plough’s products, that are intended to influence or even appear to be intended to influence that person’s actions with respect to Schering-Plough.