In Our Business
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    or organizations that do business with Schering-Plough.
  • Receiving any form of compensation from a competitor, customer, supplier or distributor.
  • Becoming involved in a business transaction on behalf of Schering- Plough with an organization in which you have a direct or indirect interest or investment, especially if you are in a position to control or influence the Company's decisions or actions with respect to the transaction.

If you believe that you have a potential conflict of interest, the way to handle it is to promptly disclose it to your manager in writing. Many conflicts of interest can be resolved in a simple and mutually acceptable way. Also remember that any appointment to serve as a director or officer of a public corporation must be approved by the CEO and, where applicable, by the Board of Directors.

Corporate Opportunities. Colleagues have a duty to the Company to advance its legitimate interests when the opportunity to do so arises.

This means:

  • Not using Schering-Plough property, information or position for personal gain.
  • Not becoming involved in activities that compete with Schering-Plough.

Q. What if I’m not sure
whether a conflict of interest
exists?

A. You need to review the
relationship or activity with
your manager to assess whether
the relationship or activity
could influence or impair your
business objectivity in making
business decisions on behalf
of Schering-Plough.

Q.I’m leading a Company team
that is reviewing the possibility
of acquiring a company in which
I own stock. Do I need to
notify anyone about this?

A. Yes, you should notify your
manager about the situation.
Generally, colleagues may have a
financial interest in a competitor,
customer, vendor or contractor if
the financial interest is less than
1% of any class of securities in a
publicly-held corporation listed
on a recognized stock exchange
or over-the-counter market.
However, even an investment of
less than 1% may be considered
a conflict of interest where the
employee is in a position to
control or influence Schering-
Plough’s decisions or actions
with respect to a transaction.

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Copyright 2007 Schering-Plough