US-EU Safe Harbor Privacy Statement

It is Schering-Plough’s policy to respect and protect personally identifiable information collected or maintained by or on behalf of the Company. In furtherance of our commitment, Schering-Plough has certified to the US-EU Safe Harbor Agreement regarding personal data collected in the European Economic Area (EEA) in support of Schering-Plough's human resources, commercial, and clinical and pharmacovigilance operations. Schering-Plough adheres to the Safe Harbor privacy principles and the “Frequently Asked Questions” document, as agreed to by the U.S. Department of Commerce and the European Commission.

Scope

This Safe Harbor Statement sets forth the principles under which Schering-Plough manages the processing of personal data that it receives from its affiliates, subsidiaries and agents in the EEA in support of our human resources, commercial, and clinical research and pharmacovigilance operations. The categories of personal data covered by this Statement include personal data relating to current and former Schering-Plough employees, prospective employees, temporary workers, contract workers, consultants, consumers, business partners, such as health care professionals at speaking or educational events, key opinion leaders, market research participants, website visitors, clinical trial subjects and site personnel, and individuals who report adverse events or product complaints.

Definitions

The following terms are used throughout this document and are defined as follows:

Agent
“Agent” means any third party that processes personal data under the instructions of, and solely for, Schering Plough or to which Schering-Plough discloses personal data for use on its behalf.

Schering-Plough
“Schering-Plough” means Schering-Plough Corporation, including its wholly -owned subsidiaries that are incorporated in any state or territory of the United States.

Personal Data
“Personal data” means any information or set of information in any form that identifies or can reasonably be used to identify a natural person. Personal data does not include anonymized data or data that is reported in aggregate.

Sensitive Personal Data
“Sensitive personal data” means personal data that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, any data that concerns health or sex life, or information relating to the commission of a criminal offense.

Privacy Principles

Notice: Schering-Plough notifies individuals about the types of personal data it collects about them, the purposes for which it collects such data, the types of third parties to which it discloses such data, and how to contact the organization with any inquiries or complaints. Notice will be provided in clear and conspicuous language at the time of collection, or as soon as practicable thereafter, and before Schering-Plough uses or discloses the information for a purpose other than that for which it was originally collected.

Choice: In the event personal data are to be used for a new purpose incompatible with the purposes for which the data were originally collected or subsequently authorized or transferred to a third party exercising independent control over the data, individuals are given, where practical and appropriate, an opportunity to decline to have their data so used or transferred. In the event that the data used for a new purpose or transferred to the control of a third party are sensitive personal data, the individual's explicit consent will be obtained prior to the use or transfer of the
data.

Onward Transfers: Schering-Plough will only transfer personal data to an Agent where the Agent has given assurances that they provide at least the same level of privacy protection as is required by these privacy principles. Where Schering-Plough has knowledge that an Agent is using or sharing personal data in a way that is contrary to these principles, Schering-Plough will take reasonable steps to prevent or stop such processing. Schering-Plough will only transfer personal data to a non-agent third party where individuals have been provided notice and have
given their consent.

Security: Schering-Plough takes reasonable and appropriate administrative, technical and physical precautions to protect the confidentiality, integrity and availability of personal data, whether in electronic or tangible, hard copy form.

Access: Individuals have reasonable access to their personal data and may request corrections, deletions, or additions, as appropriate, and except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy or where the rights of persons other than the individual would be violated.

Data Integrity: Schering-Plough limits the collection, usage, and retention of information to that which is germane for the intended purposes for which it was collected, and takes reasonable steps to ensure that all data are reliable, accurate, complete and current.

Enforcement: Schering-Plough has put in place mechanisms to verify ongoing compliance to these privacy principles. Any employee that violates these privacy principles will be subject to disciplinary procedures in accordance with Schering-Plough’s Disciplinary Policy.

Dispute Resolution: In case of disputes, individuals are able to seek resolution of their questions or complaints regarding use and disclosure of their personal data in accordance with the principles contained in this policy. If you feel that Schering-Plough is not abiding by this policy or is not in compliance with the Safe Harbor principles, you should first contact Schering-Plough at the contact information provided below.

Schering-Plough has agreed to cooperate with the European Data Protection Authorities (DPA’s) for the purpose of handling any unresolved complaints regarding personal data collected in support of our human resources operations.

For inquires related to commercial, clinical and pharmacovigilance data , if you do not receive acknowledgment of your inquiry or you think it has not been satisfactorily addressed, you should then contact the TRUSTe Safe Harbor Dispute Resolution Program or by mail at WatchDog Complaints, TRUSTe, 685 Market Street, Suite 270, San Francisco, CA, USA 94105, by phone at 415-520-3400, or by fax at 415-520-3420.

TRUSTe will act as a liaison to Schering-Plough to resolve your inquiries.

Limitation on Scope of Principles
Schering-Plough adheres to these privacy principles except, as required or allowed by law, to meet legal, governmental, law enforcement or national security obligations, or to protect the health or safety of an individual.

How to Contact Us
Please contact us with any questions concerning this Privacy Statement or any of our privacy practices at:

Schering-Plough Corporation
Office of Global Privacy
2000 Galloping Hill Rd
Kenilworth, NJ 07033
privacyoffice@spcorp.com

Changes to this Privacy Statement
This privacy statement may be amended consistent with the requirements of Safe Harbor. When we do update the privacy statement, we will also revise the “Last Updated” date at the bottom of this document. Any material changes to this privacy statement will also be posted on www.schering-plough.com/safeharbor.

Last Updated: July 22, 2009