• Fail to cooperate in a Company investigation of possible violations;
• Retaliate against another colleague for reporting a concern or violation; or
• Fail to effectively monitor the actions of people who work for you.

The Global Compliance and Business Practices department and Global Human Resources will recommend appropriate discipline to management after a full investigation and review of the facts. Management is responsible for implementing corrective or disciplinary action.

May I report a concern directly to the Board of Directors?

Anyone with a concern that they believe warrants the attention of the Board of Directors may call the Integrity Action Line and request that the report be routed to the appropriate members of the Board. Reports regarding accounting practices, internal accounting controls or auditing matters will be routed to the Senior Vice President, Global Compliance and Business Practices and the Audit Committee of the Board of Directors as required. You may also write to the Corporate Secretary at 2000 Galloping Hill Road in Kenilworth, N.J., 07033-0530 and request that the correspondence be forwarded to the Business Practices Oversight Committee or particular members of the Board. If you are unsure if a matter warrants the attention of the Board, you should contact your local Compliance Officer

What if I fear retaliation?

Retaliation against any colleague who seeks advice, raises a concern or reports misconduct is strictly prohibited and will not be tolerated. Schering-Plough will take appropriate action against any individuals engaging in retaliatory conduct against a colleague who has truthfully, and in good faith, reported a violation. Appropriate action will also be taken against any individual who has intentionally made a false report. This "no retaliation" policy is not intended to protect a person who is involved in wrongdoing about which he or she is making a report or who has ongoing performance problems. If you suspect that you, or someone you know, has been retaliated against for making a report, you should contact the Global Compliance and Business Practices or the Global Human Resources department immediately.