Our employees worldwide understand that they should bring to the attention of management workplace issues of any type, including potential violations of law, company policy or the company's Code of Conduct.

Merck strives to provide a work environment that encourages employees to communicate openly with management, without fear of retaliation or retribution.

In 2010, we launched a project to harmonize the process to manage and track investigations. The scope of this process is to provide global visibility and response to ethics and compliance issues. Through this established process, we will ensure that events are escalated to the appropriate place within the company, and properly and thoroughly investigated. This approach also will ensure the appropriate disciplinary action is taken, up to and including dismissal when necessary.

In addition to these channels to address potential violations, there are a variety of resources for employees to raise concerns in a confidential manner, without fear of retaliation.

We believe that our marketing, sales and advertising activities make an important contribution to medicine by informing our customers of treatment options based on the most current scientific information and findings from rigorous clinical studies. We take our responsibilities related to this seriously and evaluate our marketing, sales and advertising activities on an ongoing basis to ensure they are consistent with laws and regulations as well as Merck policies and values. Learn more about the Office of Ethics.

In addition to our global Code of Conduct for interactions with healthcare professionals, to minimize noncompliance and foster ethical promotional practices, Merck has several mechanisms in place:

• Hiring people with the right values and then reinforcing them: We look for people who we believe have a similar value system. In our interview process, we try to ascertain how candidates make decisions. We want people who will want to commercialize our medicines and vaccines based on the merits of our products and the science.
• Strict control over promotional materials: Every promotional claim we make throughout the world has to be approved by our medical and legal experts for accuracy and balance, in accordance with legal requirements and ethical considerations. In the United States, we also submit new promotional materials for new product approvals and new indications to the FDA prior to use.
• Strong medical and legal oversight: Merck's medical and legal teams are active partners to help foster ethical promotional practices, helping to achieve business goals by reducing risk and increasing compliance with the laws and guidelines in a highly regulated environment. Our medical and legal teams are also involved in training the sales force to provide balanced information to physicians and healthcare decision-makers.
• Promotional approach that reflects customer input: Our sales and marketing teams actively seek input from healthcare professionals, consumers and payers to understand their needs regarding our common goal of improving patient outcomes. We incorporate their feedback into training efforts and promotional activities to build trusting partnerships with our customers and to achieve our common goal.
• Performance management system that rewards ethical behavior: Our company-wide annual performance management system considers not only what an employee has achieved but also how they have done so, with a specific focus on ethical behaviors.
• Working to raise marketing standards industry wide: Merck is active in numerous industry association committees that address marketing standards.
• Global risk assessment tool: We have developed a process to assess risks associated with sales and marketing-related business practices and processes, benchmarked to industry best practices. It has been implemented so far in 29 countries around the world. By the end of 2009 it will cover all major country operations.

The review and approval of global promotional and educational materials for healthcare practitioners follows a comprehensive and strict process as outlined in the "International Medical Media Standards" (IMMS) guidance document. The IMMS principles are followed by Merck employees on a worldwide basis and define the concept of "fairness and balance" in the communication of scientific/educational information. At Merck, all such materials are reviewed and approved by medical and legal personnel, captured in a global data base, and assigned a unique identifying number and expiration date. All regional and country medical personnel involved in the review and approval of promotional/educational material receive comprehensive training on corporate policies, IMMS, the medical-reviewer role, and the required database functionalities.