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and Company procedures for
reporting and disclosing financial
information, including those
promulgated by the U.S. Securities
and Exchange Commission, the
Financial Accounting Standards Board
and the New York Stock Exchange.- Ensuring that all financial and
non-financial arrangements with
customers are recorded and properly
documented so that Schering-Plough
can abide by all government
contracting and price reporting
requirements, including those
under U.S. healthcare programs.
- Never deliberately making a false or
misleading entry in a report or record.
- Not altering or destroying Company
records except as authorized by
established policies and procedures.
- Never selling, transferring or
disposing of Company assets, or
engaging in any financial transaction
such as a contract, without proper
documentation and authorization.
- Always cooperating with our internal
and external auditors. In discussions
with auditors, colleagues must
provide truthful and accurate
information.
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Q. I believe there is a serious
internal accounting control
problem in my subsidiary.
Should I report this matter?
A. You must report this matter.
It is important that all internal
control concerns are addressed
in a timely manner. You should
discuss these types of matters
with your manager or contact
the Corporate Controller.
Q. I just took over a new job
in a new department. The accounting records maintained
by the previous colleague in my position are not what I consider
to be up to minimal standards.Should I prepare original
documentation for these prior transactions?.
A. No, you should not create
records for previous transactions.
First you should ensure that
all transactions going forward
are properly documented. You
should discuss the shortcomings
of the previous records with
your manager, as there may
be records elsewhere in the
department or Company
that meet the minimum
documentation requirements.
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