As a condition of their continued employment, all of our sales and marketing employees are required to be certified periodically on sales and marketing practices.

In the United States, for example, employees who do not satisfactorily meet these training requirements may not conduct specific activities on their own and must complete the training again until they meet the requirements.

All new employees receive testing and certification on relevant policies and Merck’s ethical operating standards. And although many of our employees who market and sell our medicines and vaccines have advanced scientific or medical degrees and backgrounds, our sales representatives must complete general sales and product training. This includes training specific to the country where the employee is based and covers the scope of the employee’s responsibilities to ensure compliance with applicable laws and regulations.

For example, our sales representatives in the United States are required to understand, among other things, their responsibilities under the Anti-Kickback Statute, the U.S. Prescription Drug Marketing Act and all applicable FDA promotional regulations.

After this initial training, we require periodic training aimed at recertifying employees on relevant policies and practices according to local and functional requirements. In addition to mandatory training on our Code of Conduct, employees receive training on other levels of business practices and compliance, according to their roles and responsibilities. We evaluate and update the content for all marketing and sales training periodically to ensure it remains relevant and current.