Auditing is a critical element of Schering-Plough's commitment to conduct business in a responsible manner. Since 1991, management has maintained a separate audit unit that is independent of both the operating units and the Global Safety and Environmental Affairs department. The mission of Global Environment, Health, Safety and Transportation (EHST) Audits is to: (1) advise management of the status of compliance with company and government environmental, health, safety and hazardous material transportation requirements and the associated management systems at all company operations worldwide; and (2) ensure that all detected instances of noncompliance are resolved properly and in a timely manner. Global EHST Audits is a part of the Global Compliance and Business Practices group. The unit provides regular reports to the Corporate Environmental and Safety Council.

In 2008, Global EHST Audits conducted 38 audits of company operations and 10 assessments of external manufacturers in the company’s supply chain. In addition, three assessments against the U.S. Environmental Protection Agency’s National Environmental Performance Track criteria were done. In 2009, 13 of 43 planned EHST audits and eight of 22 planned external manufacturer assessments have been completed through April 2009. The data reported in the figure below reflect only the audit findings for the company’s operations.

Schering-Plough does not publish information regarding specific audits. However, in 2008, the company reported that 99.3 percent of the audit findings noted for the period 2005 to 2007 had been closed. Only one finding from 2006 and three from 2007 remained open. As seen in the figure below, one finding from 2006, three findings from 2007, 156 findings from 2008 and 79 findings from 2009 remain open as of April 2009.