Political Activity and Lobbying

Corporate Political Activity. Many of the countries in which we do business have laws regulating the activities of corporations in the political process. The laws of the United States and some other countries set strict limits on contributions by corporations to political parties and candidates. Also, in many countries and jurisdictions the act of lobbying requires public disclosure. At Schering-Plough we comply with these laws.

This means:

• Not making direct or indirect political contributions on behalf of Schering- Plough unless authorized by Schering- Plough's Chief Executive Officer and General Counsel (or their designees) in writing. This includes contributions to candidates, office holders and political parties. In addition to cash contributions, contributions include things like:
• • Buying tickets for a political fundraising event.
  • Providing goods or services.
  • Loaning personnel during working hours for fundraising activities.
  • Paying for advertisements and other campaign expenses.

• All lobbying activities should be discussed with your local Compliance Officer or the Global Law department to determine whether disclosure and other rules apply.
• Not approving the U.S. federal lobbying activity of consultants hired by Schering-Plough, without prior