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

In the United States, for example, employees who do not satisfactorily meet the training requirements may not conduct specific activities without direct supervision, and must complete the training again until they do meet the requirements.

All new employees receive testing and certification on related policies and Merck's ethical operating standards. In addition, 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 employee's responsibilities to ensure compliance with local laws and regulations that relate to pharmaceutical sales and marketing. For example, our sales representatives in the United States are required to understand their responsibilities under the Anti-Kickback Statute, the U.S. Prescription Drug Marketing Act, and U.S. FDA drug-promotion regulations.

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