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consultation with and the approval of
the Vice President of Corporate
Government Affairs.
Personal Political Activity. Schering-Plough encourages political activity by
colleagues in support of candidates or
parties. But you should only engage in
the political process on your own time
and with your own resources. Never use
Company time, property or equipment,
including e-mail, for personal political
activities.
Investigations
Internal Investigations. Schering-Plough
is committed to investigating alleged and
potential violations of the Standards and
related laws, regulations and Company
policies.
This means:
- Conducting fair and impartial
investigations.
- Cooperating with internal
investigations and providing truthful
and complete information.
- Investigations will result in appropriate
actions.
Government Inquiries and Investigations. Schering-Plough is regulated by
governments throughout the world.
From time to time, colleagues may
come into contact with government
officials responsible for enforcing the
law. The Company cooperates fully
with governmental inquiries and
investigations.
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Political Activity and Lobbying
Q. I am hiring an outside
consultant and the consultant
might perform U.S. federal
lobbying activities for our
Company.What obligations
do I have?
A. You must confer with the
VP of Corporate Government
Affairs prior to approving any
third-party U.S. federal lobbying
activity on Schering-Plough’s
behalf, and you must include in
the consultant contract a clause
that requires the consultant to
timely disclose to the Schering-
Plough designated colleague and
VP of Corporate Government
Affairs any federal lobbying
reports submitted to government
entities, as a result of lobbying
on Schering-Plough’s behalf.
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