• In the absence of a legislative requirement such as the proposed Physicians Payment Sunshine Act, Merck plans to voluntarily disclose in the fourth quarter of 2009 all payments to US-based health care professionals who speak on behalf of Merck or our products.
• Following the implementation of the revised Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with Health Care Professionals, Merck plans to complete self-certification in 2009 and subsequently pursue external verification.
  
  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 non-compliance events, we will ensure that events are escalated to the appropriate place within the Company, and properly and thoroughly investigated. We also will ensure that the appropriate disciplinary action is taken, up to and including dismissal, when necessary.

The content on this page was last modified on September 15, 2009.

Merck & Co., Inc., Whitehouse Station, NJ, USA, and Schering-Plough Corporation, Kenilworth, NJ, USA, are now one company. We have combined our global operations under the name Merck & Co., Inc. We are working to update our corporate responsibility Web site to reflect our new, combined, global organization.