In our business, adherence to the rule of law, ethical working practices, good corporate governance, transparency and respect for people are critically important to patients, healthcare professionals, our employees, our investors and the purchasers of our products—and to our sustainable business success.
We have strong corporate policies and safeguards in place, and a long history of abiding by, and promoting, high ethical standards and the law. Every Merck employee is responsible for adhering to business practices that are in accordance with the letter and spirit of the law and with ethical principles that reflect the highest standards of corporate and individual behavior.
Inappropriate behavior can never be rationalized as being in the company's interest. No act of impropriety advances the interest of the company; no act of impropriety will be tolerated.
The Merck Office of Ethics was established in 1995. In 2009, the Office of Ethics became part of the Global Compliance Organization, which was formally established following the merger between Merck and Schering-Plough.
The Office of Ethics is led by the vice president, Ethics, Privacy and Policy, who reports to the company's chief ethics and compliance officer. There are seven ethics officers who handle ethics concerns and ombuds matters. The Office of Ethics also has an ethics professional who supports training, communication and reporting., In addition there are four administrative professionals who support the Office of Ethics staff. The 2011 budget for the Office of Ethics was $2,341,068.
Resources for Employees
The Office of Ethics serves as an additional employee resource for raising concerns about ethical issues. Employees can do so in several ways. One is to contact (via toll-free telephone or intranet) the AdviceLine, which is run by an outside vendor. Or employees can contact the Office of Ethics directly, to speak to an ethics officer or an ombudsman.
The Merck Ombuds Program offers a safe haven for U.S.-based employees to discuss work-related issues without fear of retaliation. This program confidentially addresses employees' concerns about conduct that may be inconsistent with Merck's policies, practices, values and standards. Outside the U.S., employees may also contact the Office of Ethics directly or use the AdviceLine to raise concerns. About 40 percent of the calls that the Office of Ethics receives each year are classified as part of the ombuds process and, as such, are kept confidential.
Addressing Misconduct
In 2010, the Global Compliance Organization launched a Sigma project to harmonize the process of managing and tracking investigations. During 2011, the rollout of the global investigations process referred to as Compliance Issue Visibility and Response (CIVR) was largely completed. The implementation of that global process has already increased management's visibility and awareness of ethics and compliance concerns. This increase is shown in the Performance & Commitments tab to the right.
When Merck substantiates allegations of ethical misconduct, it imposes any of a variety of disciplinary actions on those responsible, such as dismissal from the company, issuance of final written warning letters, or financial penalties. We also take appropriate steps to address any needed improvements in organizational and process controls.
