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- Business gifts or meals should be infrequent.
- Gifts, meals and entertainment
may be provided or accepted in the
normal course of business as long
as they.
-
- Involve persons with whom
Schering-Plough has or may have
business;
- Are reasonable and consistent with
applicable laws and with accepted
ethical standards and local
business practices;
- Are of modest value and properly
recorded in Company records so
they could not be construed as a
bribe, payoff or kickback; and
- Are not in violation of the rules of the recipient's organization.
- Honorariums or fees for speaking or presenting on behalf of the Company should not be accepted.
What is considered "modest" may vary, depending on the country in which we are doing business. Certain exceptions to the Standards may be made in countries where differing practices
are customary with approval of your management in consultation with your
local Compliance Officer. Any questions regarding the appropriateness of a
gift should be addressed with local management and your local Compliance
Officer.
Special gift and entertainment rules
apply to government employees. Schering-Plough colleagues may not
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Gifts and Entertainment
Q. I recently met with a
potential vendor to evaluate their services to perform work on a large project. I mentioned
to them that my son was a fan of their local football team. Several days later, I received tickets for an upcoming game from this vendor, in appreciation for considering
their company as a candidate. Can I accept these tickets from the vendor?
A. No. Schering-Plough is
committed to an unbiased, objective evaluation of all of our current or potential suppliers and
vendors. There should not be even the slightest hint that any contractual relationship is colored
by personal gain. Personal trips or entertainment like this are inappropriate. However, user
conferences or other educational events that relate to your work for Schering-Plough may be
appropriate. You should always consult your manager before accepting such trips. In deciding
among competing vendors, you must be objective and unbiased to avoid even the slightest hint of
favoritism. If you were to accept these tickets, it could appear as if your independent judgment
is affected.
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