• Always exercise great care and vigilance when entering into transactions with employees of public institutions or other government officials in order to avoid potential bribery and corruption issues.
• Accurately record in Schering-Plough’s books and records all transactions, including any gift or payment to any third-party.

Anti-Bribery and Corruption Policy C-147; Global Marketing Policy C-100. If you have questions whether a healthcare professional or individual is considered a government official, or whether a payment or gift is appropriate or legal, seek advice from the Law department or your local Compliance Officer.

Competitive Intelligence

In our complex business environment, we acquire a large amount of information about our competitors and their products and services. It is proper to accumulate public information and it is generally not unethical or illegal to make use of it in conducting our business. However, employees and third parties working on behalf of Schering-Plough must only use ethical and legal means for gathering competitive information.

This means:

• Always gather information about competitors from public sources such as Web sites, published articles, price bulletins, advertisements, brochures, public presentations and customer conversations.
• Accept competitive information only when there is a clear and reasonable belief that receipt and use of the information is lawful and ethical.
• Do not obtain information through the use of unlawful or unethical means such as misrepresentation, deception, theft, spying or bribery.
• Do not recruit or hire employees of competitors, customers or vendors for their knowledge of proprietary information of present or former employers.