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TRANSPARENCY AT MSD

Operating Ethically and Transparently

We strive to apply the highest standards of ethics and integrity to everything we do. Our efforts to be more transparent about our operations include:

• Grants: Ongoing education for healthcare professionals is important and required. We often make grants to U.S. organizations that provide independent, professional education initiatives for physicians, including accredited continuing medical education (CME). MSD has no influence over the content of these courses.These grants are posted on merck.com.

• Relationships with physicians: MSD interacts regularly with physicians to share information about the newest medicines and treatments, as well as hear about patients’ experiences with our products. We disclose payments to healthcare providers who speak on our behalf in the United States. We also have endorsed pending legislation that mandates disclosure of certain financial relationships between physicians and the pharmaceutical industry.

• Clinical trials registration and disclosure: Conducting clinical trials is a critical step in determining if our products are safe and effective. We register our trials online when studies are initiated to make patients and healthcare providers aware of these trials. We also make study results of marketed products-regardless of the outcome-available following study completion. More.

• Social and environmental responsibility: Our transparency efforts also extend to other important aspects of our operations such as our environmental performance, our efforts to expand access to our medicines and vaccines around the world and our progress on diversity in the workplace. Data on these and other key performance indicators are available in our latest corporate responsibility reports:

MSD’s 2008 Report
MSD’s 2008 Report Online
Schering-Plough 2009 Report on Safety, Health and Environment

• Political contributions: MSD is committed to participating constructively in the political process and to disclosing information about our political contributions.

• We were among the first companies to follow the Center for Political Accountability’s Model Code of Conduct for Corporate Political Spending.

• We annually post information on our Web Site about our corporate political contributions in the United States, Australia and Canada.

• MSD also discloses any contributions to committees known as 527 organizations

MSD provides an opportunity for U.S. employees to participate in the political process by joining a non-partisan political action committee. Except for administrative expenses, the MSD Employees Political Action Committee (MSD PAC) is completely funded through voluntary contributions from eligible MSD employees. View information about MSD PAC contributions on the U.S. Federal Election Commission’s Web site.

For more information about transparency at MSD, view our 2008 corporate responsibility report.

POLITICAL CONTRIBUTIONS

View Our Political Contributions