The Merck Code of Conduct, called Our Values and Standards, is considered to be the foundation of our company’s success. These values and standards apply worldwide, wherever our company does business.
Ethics and integrity make up one of our five core values, as outlined in our mission statement. These values are underscored in the company’s Code of Conduct, Our Values and Standards, which was first developed and distributed to Merck employees in 1999, and was updated in 2002 and 2005. Edition III of the Code of Conduct was published in June 2011, and includes information on the Foreign Corrupt Practices Act (FCPA), which prohibits providing gifts and other benefits to gain business.
Our Code of Conduct, available in 26 languages, applies one standard of conduct to all employees worldwide, with ethical business practices serving as a key measure in all annual performance evaluations.
The values and standards embodied in Merck’s Code of Conduct are designed to promote ethical business practices as our employees conduct activities in a continuously evolving business environment and deter employee misconduct. These core values included in the Code of Conduct are intended to foster:
- Compliance with company policies and applicable governmental laws, rules and regulatory requirements
- Safeguards to protect the privacy of personal information, as well as honesty and transparency in communications about our products
- Measures to mitigate potential conflicts of interest
- Prompt internal reporting of potential violations of the Code of Conduct and policies
- Employee accountability for adherence to the values and standards set forth in the Code of Conduct
To download a copy of the Merck Code of Conduct or locate company resources to raise a question or concern, click here.
Ethics Training & Development
We provide training to all employees worldwide on our Code of Conduct to ensure awareness of our values and standards. In 2012, we introduced a new training program on the Code of Conduct that all employees were required to take. The purpose of this training is to provide guidance on the Code of Conduct, emphasizing the importance of raising concerns. This year, we are introducing an annual refresher training course on the Code of Conduct as an additional reminder to reinforce our values and standards. In addition to the Code of Conduct training courses, we have other training programs that reinforce ethical business practices relating to specific topics, such as anticorruption, privacy, and preventing discrimination and harassment.
To assist in this effort, the Global Compliance Organization developed a training system that includes appropriate governance, clear procedures and documentation for training analysis, design, development, implementation and metrics on the number of trainings that are completed.
Ethics and integrity are key leadership competencies that are assessed as part of annual performance reviews. These core leadership competencies also play an integral role in our decisions about employee advancement in the company.
Annual Ethics & Policy Certification
An important component of Merck’s corporate compliance program is its annual ethics and policy certification.
The annual review process requires all directors, officers, managers and other selected company employees to certify compliance with the Code of Conduct, corporate policies on ethical business practices, antitrust law compliance and insider trading. These employees are also expected to regulate their outside activities to avoid any conflicts of interest and certify, in writing, whether actual or potential conflicts of interest exist. Where potential conflicts are identified, the Office of Ethics will work with management to take actions to mitigate the potential conflict. In addition, all U.S.-based employees must certify compliance with Merck’s corporate policy on the effects of exclusions, debarments, suspensions and healthcare-related criminal convictions, reporting and screening.
The certification process also includes a question, soliciting employees to report any concern they may have about the company’s business not being conducted in full compliance with laws, regulations and company policies. Although the number of responses submitted represented less than one percent of all employees, the company investigated each issue to ensure full compliance with laws, regulations and company policy.
External Suppliers’ Ethical Standards
We abide by strict ethical standards in our own operations—and we insist on equivalent standards from our suppliers. Merck has a Business Partner Code of Conduct that is based on Merck’s Code of Conduct, Our Values and Standards, as well as the Pharmaceutical Supply Chain Initiative’s (PSCI’s) Pharmaceutical Industry Principles and the 10 principles of the United Nations Global Compact.
To download a copy of the Merck Business Partner Code of Conduct, click here.
For more information on how we work with our suppliers to uphold ethical standards, please click here.
Last Updated October 24, 2013