|
|
|
|
|
|
|
 |
20 |
 |
|
|
institutions or other government
employees in order to avoid potential
bribery and corruption issues.
- Accurately recording in Schering-
Plough's books and records all
transactions, including any gift or
payment to any third party.
- Accurately recording 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. A person is considered a
government employee if he or
she either receives any part of his
or her salary from the government
(including a state-owned
company), or performs a
governmental function with or
without pay. If you have questions
whether a healthcare professional
or individual is considered a
government employee, or
whether a payment or gift is
appropriate or legal, seek advice
from the Global Law department
or your local Compliance Officer.
International TradeSchering-Plough does business around
the globe and is subject to and complies
with applicable international trade
controls (trade sanctions, restrictions
on dealings with denied parties, export
controls, and antiboycott regulations)
and customs requirements.
This means:
- Not engaging in any dealing
whatsoever, commercial or otherwise, with a party located in
|
|
|
|
|
(Continued)
Falsification of any Company record, including a false statement of the date of signature, could be a violation of this requirement. You must seek the advice of your manager, the Global Law department or your local Compliance Officer to determine how best to deal with your filing requirement without creating any backdated or otherwise false documents.
International Trade
Q. While processing an
order for products for Syria, you identify a document that requests a statement regarding
dealings with Israel.What should you do?
A. Immediately report the
receipt of the document to the Global Law department, and
take no action whatsoever responsive to the document until
the Global Law department provides guidance.
Q. Q. You have been requested
to ship biologic materials for vaccine testing from your site
to a Schering-Plough affiliate located in another country.
What should you do?
A. There are strict export
controls on certain pathogens and toxins. These controls apply...
(Continued on next page)
|
|
