Being an ethical company is about much more than simply adhering to the letter of the law. But it's an important step.

As part of our long-standing commitment to ethics and good corporate citizenship, our first step is always to comply with the laws and regulations that govern the way we market and sell our medicines, vaccines and other products.

Merck has a well-established compliance program that:

• is consistent with the Code of Ethical Practices created by the Canada's research-based pharmaceutical companies association (Rx&D);
• seeks to prevent, detect and resolve potential violations of law or company policy; and
• undergoes regular assessment and adjustment to make sure we are being responsive to our evolving business and associated compliance risks.

In addition, Merck:

• requires employees to report potential violations of law or company policy;
• holds employees accountable for responding promptly when potential violations arise;
• takes disciplinary action as appropriate; and
• examines whether identified violations are in part due to gaps in our policies, practices or internal controls and, if so, takes appropriate action to prevent future violations.

Merck's compliance program is just one part of our overall commitment to operating ethically, openly and transparently. However, we believe it's the right place to start.