• Enforcing Company policy by monitoring colleague compliance and implementing appropriate discipline for misconduct.
• Supporting colleagues who in good faith raise concerns regarding potential misconduct.

Can the policies summarized in the Standards be waived?

Waivers of the policies summarized in the Standards are an exception and will only be granted in special circumstances.

Schering-Plough will waive a policy only where:

• Circumstances warrant granting a waiver,
• Such waiver would not permit illegal or unethical conduct, and
• There are appropriate controls over the particular situation.

Waivers for colleagues will be made only with the approval of the Senior Vice President, Global Compliance and Business Practices. Waivers of any of the provisions of the Standards for corporate officers may be made only by the Business Practices Oversight Committee of the Board of Directors after receiving the recommendation of the Senior Vice President, Global Compliance and Business Practices. Waivers relating to the CEO, CFO and Controller will require approval of the Audit Committee of the Board of Directors. Such waivers, if granted, will be promptly disclosed as required by law, regulation and NewYork Stock Exchange rules.

How do I use The Standards?

The Standards consist of:

• This Introduction;
• Four substantive sections that cover policies and legal requirements relating to conduct in the Workplace, in the external Marketplace where we sell our products, in our internal Business operations, and in the Communities where we operate;
• A brief but important section, Upholding the Standards, that offers some common sense tips for applying the Standards;
• A section offering guidance in effectively Raising Concerns and Seeking Advice regarding any compliance or integrity issues that arise; and,
• An Acknowledgement that we each must read and understand the
  matters contained in this Booklet.