Our sales and marketing practices are governed by external laws, regulations and industry codes of conduct; as well as by our global Code of Conduct, business practices and compliance program.

These practices are monitored and enforced to ensure that our interactions with customers and consumers help inform their decisions accurately and in a balanced manner. We believe that compliance, in letter and spirit, with all policies governing scientific, business and promotion-related activity is a corporate and individual responsibility of the highest order. Our ethical behavior will ensure that scientific information predominates in prescribing decisions.

U.S. PhRMA Code Compliance

Some have expressed concerns over the way pharmaceutical companies provide information to healthcare professionals and consumers. Merck’s long-standing Code of Conduct, business practices and compliance program have sought to prevent and address inappropriate practices. We are constantly evaluating our policies and practices and revising them as appropriate.

Over the past several years, the pharmaceutical industry as a whole has recognized that more needed to be done to address concerns raised by public officials and stakeholders in the healthcare community. The revised PhRMA Code sets the standards that govern the industry’s sales and marketing practices in the United States and ensures that companies have adequate policies and procedures in place to comply with this Code.

Key Components of the PhRMA Code

Among the Code’s key components is an annual requirement for company CEOs and chief compliance officers to certify personally that they have processes in place that foster compliance with the Code. The Code also encourages companies to obtain third-party verification of their compliance policies and procedures. Merck has completed PhRMA Code certification in each of the last three years. In 2011, an independent third party validated that Merck's compliance program fosters compliance with the Code.

Other requirements of the Code had previously been incorporated into Merck’s already-strong ethical practices. For example, the company follows the standards for commercial support of Continuing Medical Education established by the Accreditation Council for Continuing Medical Education (ACCME), and our compliance program already required that company representatives be periodically assessed to make sure they comply with relevant company policies and standards of conduct.