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.

We have a well-established compliance program that:

• is consistent with recommendations set forth by the Medicines and Related Substances Act 101 of 1965 as amended and the South African Code of Practice for the marketing of Health Products;
• The Compliance Institute of South Africa is a non-profit organisation offically incorporated under Section 21 of the Companies Act
• 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.

MSD's Board of Directors and senior management, including the company's Chief Compliance Officer and Corporate Compliance Committee, oversee the company's global compliance program, including compliance-related policies and procedures, education and training – all of which reflect the highest standards and are tailored to MSD's business and culture.

In addition, we:

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

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