Beyond the activities associated with raising concerns, the Office of Ethics functions as the center of excellence for Values and Standards Program.

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 business conduct, Our Values and Standards, which was first developed and distributed to Merck employees in 1999, and updated in 2002 and 2004. Edition III of the Code of Conduct was published in June 2011. Our Code of Conduct applies one standard of conduct to all employees worldwide and is available in 26 languages. Ethical business practices are a key measure in annual performance evaluations of all our employees globally. Merck's Code of Conduct has been designed to deter wrongdoing and to foster:

• Honest and ethical conduct, including the ethical handling of actual or potential conflicts of interest between personal and professional relationships
• The protection of our confidential and proprietary information and that of our customers and vendors
• Compliance with company policies, applicable governmental laws, rules and regulatory requirements
• Prompt internal reporting of violations of this code
• Accountability for adherence to the values and standards set forth in this code

To download a copy of the Merck Code of Conduct, Our Values and Standards, Edition III, or locate company resources to raise a question or concern, click here.

Ethics Training & Development

At Merck, our standards for conduct do not vary and apply equally to every Merck facility in every country. At the same time, we understand that employees face varying situations in different parts of the world. We recognize that in some cases we are asking people to act in ways that are contrary to prevailing cultural practices. For this reason, we adapt our training to different countries or regions to accommodate cultural differences and to assist our employees in managing real-world challenges.

In 2010, the Global Compliance Organization (GCO) launched a Sigma project to harmonize compliance training across the new Merck. The scope of this project is to develop, install and realize a GCO training system that includes processes with clear procedures and documentation for training analysis, design, development, implementation and evaluation (metrics); an organizational structure to support this; appropriate governance; and a supporting systems infrastructure.

All employees worldwide are required to complete Know the Code training. In addition, all employees are required to complete the Safe to Speak Up training, which emphasizes the importance of raising concerns.

A key measure in employees' annual performance reviews, ethics also play an integral role in our decisions about employees' advancement in the company. The Merck Office of Ethics also supports a "train the trainers" program for the Code of Conduct through which it certifies employees to assist the Office of Ethics in communicating with employees about the company's commitment to ethical, legal and responsible business practices. To date, more than 100 such trainers have been certified in 38 countries.

Conflicts of Interest

Merck's Conflict of Interest Policy provides that all directors, officers and employees are expected to regulate their outside activities so as to avoid any conflict of interest. An important component of Merck's corporate compliance program is its annual compliance review, which includes training, an annual conflict of interest certification and disclosure process, and compliance with key corporate policies. All directors, officers, managers and other selected company employees must certify in writing the absence or existence of actual or potential conflicts of interest under this Conflict of Interest Policy. The process also requires employees to certify compliance with corporate policies on ethical business practices, which prohibits illegal or unethical payments or conduct. It also requires antitrust law compliance, and forbids insider trading, while requiring that all U.S.-based employees certify compliance with Merck's corporate policy on the effects of exclusions, debarments, suspensions and healthcare-related criminal convictions, reporting and screening.

External Suppliers' Ethical Standards

We abide by strict ethical standards in our own operations—and we insist on equivalent standards from our suppliers.

We purchase goods and services from external suppliers, ranging from the active pharmaceutical ingredients and intermediates in our products, to office furniture, promotional items and supplies, to cleaning and printing services. For more information on how we work with our suppliers to uphold ethical standards, please click here.