In advance of the passage of the Physicians Payment Sunshine Act, starting in the fourth quarter of 2009, Merck began voluntarily disclosing all payments to U.S.-based healthcare professionals who speak on behalf of Merck or our products. Merck will begin reporting of payments to all U.S.-based healthcare professional who provide advice or consultative services to Merck as early as the third quarter of 2011.
We plan to develop a global training program based on Merck's Guiding Principles for Business Practices Involving the Medical and Scientific Community.
In accordance with Merck's recently established comprehensive corporate guidelines for escalation, investigation, remediation and recognition of noncompliance events, we will ensure that the appropriate place within the company is notified, and properly and thoroughly investigated. We also will ensure that the appropriate disciplinary action is taken, up to and including dismissal, when necessary.
