Concerns
58

Calls to the Integrity Action Line will not be traced or recorded and callers can remain anonymous if they choose. (For obvious reasons, calls in which the caller identifies himself or herself are often easier to investigate than those calls made anonymously.) An operator will take your information or your question and communicate it to the Global Compliance and Business Practices department, which will then coordinate an investigation if one is warranted and thereafter take appropriate action.

The caller can also arrange a call back time to receive information about the Company's response to the call or to provide additional information.

Will my identity be kept confidential?

You will never be required to reveal your identity when you use the Integrity Action Line. In all cases, confidentiality is a priority and efforts will be made to protect it. However, Schering-Plough may be required by law to reveal your identity or it may be impossible to keep your identity confidential (for example, if you are a colleague in a very small office where it may be obvious from the facts who you are or if you tell other colleagues "in confidence" that you have made the call). This may be the case even if the call is made anonymously.

How long will it take to get a response?

This will depend on the nature of the call. Questions will be answered as soon as possible. Matters requiring investigation will naturally require more time. If you give your name, we will keep you informed on the progress as warranted. If you call anonymously, you should check back with the Integrity Action Line after two weeks for a status update, using the number you were given at the time of your initial call.

What about disciplinary action?

While adherence to law, regulation and Company policy, including the Standards, is the responsibility of all colleagues, monitoring and enforcement of such compliance is the responsibility of management with the support of the Global Compliance and Business Practices department. Any violation of a law, regulation or Company policy can result in corrective or disciplinary action. In addition, disciplinary action, up to and including termination, may occur, if you:

  • Direct others to violate the law, regulations or Company policies;

 

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Copyright 2007 Schering-Plough