At Merck, protecting the health and well-being of our employees and the public, protecting and preserving the environment, ensuring the safety of our employees and those who live in the vicinity of our facilities, and being in full compliance with the law all are of fundamental importance to the way we operate.

Our mission and values are articulated by Merck's corporate environmental, health and safety (EHS) policy. In addition to compliance with all applicable country, regional and local safety and environmental laws, we strive for EHS performance that is among the best in the pharmaceutical industry.

Merck's commitment to environmental, health and safety begins with Merck's Executive Committee, which has established Merck's corporate EHS Council to focus on this area. The corporate EHS Council is composed of senior-level executives, responsible for providing active leadership and participation in driving enterprise-wide excellence in EHS management and performance. Specific Council duties include:

• Establishing EHS strategy, policy and management systems
• Providing enterprise-wide oversight of EHS issues, risk mitigation and control strategies
• Monitoring the EHS performance of the company and establishing continuous improvement targets
• Promoting and recognizing EHS excellence in the company's divisions
• Allocating resources and taking EHS performance into account when determining divisional and individual compensation and awards

Merck's vice president of global safety and the environment is responsible for communicating to Executive Committee and to the corporate EHS Council our progress on goals, objectives and metrics and other material issues, as well as recommending long- and short-term goals, objectives and metrics. Delivery of EHS performance is the responsibility of operations personnel supported by corporate and site EHS professionals. Merck operations are responsible for compliance with all regulatory requirements and applicable Merck internal requirements. Our corporate EHS organization is responsible for:

• Developing corporate policies, procedures, guidelines and standards, and tools and programs to drive EHS performance and implementation of compliance requirements
• Providing technical and regulatory support to the site safety and environmental groups and to operating organizations
• Auditing Merck's operating organizations to ensure that appropriate programs are in place to ensure compliance, employee safety and environmental protection
• Looking both externally and internally for emerging trends, issues and practices that should be addressed in our operating organizations
• Anticipating, tracking and commenting on new regulations

Our site and operating area EHS professionals are responsible for implementing programs and supporting the EHS needs of their areas, which might include manufacturing, research operations, sales and administrative activities, by:

• Ensuring that operations fully understand EHS requirements
• Establishing, assessing and improving EHS programs
• Providing regulatory and technical support to employees and the operating areas
• Routinely assessing the performance of the operating area against both regulatory and Merck requirements
• Acting as the primary liaison with local regulators and inspectors

Merck operations are responsible for compliance with all regulatory requirements and applicable Merck internal requirements.

Policies & Management Systems

Merck's policies, procedures and guidelines (PPGs) provide clear direction to our sites and operating organizations regarding expectations for EHS processes and program implementation. PPGs play a critical role in the classic management construct of "plan, do, check, act." They bridge the "planning" of management (goals, objectives, metrics) with the "doing" of the sites and operating organizations. They also help bridge the discovery of program gaps found in "checking" (auditing) by providing guidance on how to "act" to close those gaps.

Merck's PPGs are integrated into program elements of our Management Systems. These are reviewed by our Environmental, Safety and Health Operational and Technical committee (ESHOT), comprising Corporate EHS staff, legal and representatives from each of the operating organizations. ESHOT ensures that new or revised internal requirements not only comply with legal requirements and help ensure a safe, healthful and environmentally responsible workplace, but also are practical, cost-effective and meet the needs of all stakeholders.

Internal Auditing Program

For more than 20 years, Merck has conducted corporate safety and environmental audits of our facilities worldwide. All manufacturing and research sites are audited. Most sites are audited every two or three years; lower risk sites may be audited less frequently. In many cases, particularly outside of the United States, our internal auditors work with independent consultants who have regulatory expertise in the laws of the host country. In addition, managers in each of our operating sites must perform periodic self-evaluations using formal compliance tools. To continue to drive improvements, we have enhanced our corporate audit practices to make our audits more detailed and rigorous, helping us better identify compliance and performance issues.

• Our audit leaders have extensive experience in auditing procedures, regulatory requirements and hazard recognition
• Our core auditor pool includes additional staff members with extensive subject matter expertise
• We place a strong emphasis on rapid resolution of all identified compliance issues—those identified during audits or by any other means
• Findings from our audit program are also used to alert other Merck EHS managers to potential compliance concerns

Training

Training is critical to ensuring that our managers, our EHS staff and our employees worldwide understand their role in driving EHS performance, and have the knowledge and skills to fulfill their responsibilities. Our training program is designed to meet the needs of these various roles.

Manager training covers specific management responsibilities for compliance, as well as management's role in conducting EHS inspections, driving closure of findings, contributing to incident investigations and communicating more effectively about EHS requirements and expectations. In 2010, the program's focus was on driving behavior change to ensure a safety-first culture. Trained facilitators brought the program to first-line managers in research and manufacturing globally.

EHS staff training is based on established standard curricula designed to drive more consistent technical expertise and improved EHS support capabilities around the world. The curricula address technical training needs from core fundamentals through expert-level topics using both internal subject-matter experts and approved external instructors. Defined curricula also facilitate cross training between disciplines. This approach helps us develop our EHS professionals at all levels of the organization.

A Management System program defines our comprehensive EHS training expectations for all employees. The program includes standardized guidance documents to provide clear expectations on topics and content.