UPHOLDING THE STANDARDS

We are counting on you to assist the company by knowing your responsibilities under the Standards and letting us know when help is needed.  Following are some tips on how to act responsibly – to Lead with Integrity – in any work situation.

KNOW AND LIVE THE STANDARDS. You can serve as a role model by knowing the laws, regulations and company policies that are summarized in the Standards and living them every day.

KNOW THE LAW AND ASK TOUGH QUESTIONS. You are expected to be familiar with the laws, regulations and company policies that apply to your specific job function and level of responsibility.  If you are not sure whether a law or policy applies, or whether it exists at all, ask.

DON'T MAKE ASSUMPTIONS. Do not assume that “management already knows” or “management doesn’t want to hear bad news.”  Do not assume that no action will be taken, or that you will be penalized for taking action.  Management is dedicated to ensuring that the Standards are upheld.  We want you to tell us if something is wrong.

DON'T IGNORE VIOLATIONS. We all need to take the law and company policies that are summarized in the Standards seriously.  If you think someone may be violating laws or the Standards, please take steps to address the situation.

HELP IMPROVE CONTROLS AND PROCESSES. Some violations can happen, or can go undetected, because of weakness in an existing control or process.  In these situations, do not hesitate to suggest improvements.

DON'T BE PRESSURED. You are never expected to violate a law, regulation or company policy nor should you ever feel encouraged or pressured to do so – even if the violation will improve the bottom line or help meet a performance goal.

Letter from the EMT and Advisors

“Leading with Integrity.” Three simple words,
but they speak volumes about what the New Schering-Plough is all about. At the New Schering-Plough each colleague is a leader. We have identified and asked every Schering-Plough colleague to exhibit six Leader Behaviors that we believe are critical to transforming our company into a high performing, global company. One of these behaviors, Business Integrity, is the foundation of our Global Compliance and Business Practices program.

By making business integrity a part of each decision we make, and by adhering to our Values and to the business practice standards set forth in these Standards of Global Business Practices, we will make progress toward our vision to earn trust every day. This in turn will also help us regain leadership in the pharmaceutical industry with leading health innovations, with leading business performance, and with a leading reputation with patients, physicians, regulators, employees, shareholders and even our competitors.

The objective of Schering-Plough’s Global Compliance and Business Practices program is to give each colleague the knowledge he or she needs to do his or her job in full compliance with the law, and the confidence that whenever he or she does the right thing, he or she will receive our full support, and the full support of his or her colleagues.

The Standards of Global Business Practices are not designed to answer every possible question that might arise. Read them carefully. If you have any questions about how the Standards apply to your responsibilities, seek advice from your manager or a member of the Global Compliance, Law, or Global Human Resources departments. You can also contact any of us identified below. Our signatures represent our total commitment to the Standards of Global Business Practices and all the elements of “Leading with Integrity.”