U.S. Healthcare Laws

Both the United States federal government and many state governments in the United States have enacted laws to prevent, detect and punish healthcare fraud and abuse. These laws include the Federal Civil False Claims Act, the Federal Program Fraud Civil Remedies Act and similar state laws. Under these laws, false or fraudulent claims submitted to the government for payment or reimbursement of healthcare expenses are subject to the payment of damages and punishable by substantial fines and penalties. The federal False Claims Act and some state False Claims Acts also include provisions under which individual citizens with evidence of fraud against the government may file "whistleblower" suits on the government's behalf to recover the lost funds. If a whistleblower suit is successful, the person who filed it may receive a portion of whatever money the government recovers. These laws also prohibit retaliation against persons who file whistleblower suits.

Gifts and Entertainment

Exchanging social amenities or business gifts of a modest value such as small gifts, meals and entertainment is permitted as a common practice meant to create goodwill and establish trust in business relationships. Schering-Plough expects the use of good judgment and moderation when giving or receiving entertainment or gifts. Avoid situations that could compromise or appear to compromise your impartiality.

This means:

• Business gifts or meals should never be conditioned upon, or be a reward for, purchasing, prescribing or promoting Schering-Plough's products and services.