Johnson & Johnson is a large and diverse company, with thousands of daily transactions that must comply with hundreds of regulations around the world. We take compliance issues seriously, investigate each one, and revisit our operational controls. Our Policy on Business Conduct sets expectations that all employees will comply with all laws and regulations governing our company’s behavior.
Antitrust and Competition Laws
We require that employees comply with the antitrust and competition laws of each country in which our companies do business. Employees may not engage in anti-competitive conduct nor are they permitted to take unfair advantage of any customer, supplier, competitor or other person through manipulation, concealment, misrepresentation of material facts or other unfair-dealing practice.
Environmental Laws and Regulations
Johnson & Johnson is committed to conducting our business in an environmentally sound manner. In addition to carrying out the corporate-wide programs the Company has initiated, all of our employees are required to be familiar with environmental laws and regulations relevant to their employment responsibilities and to comply with them.
Healthcare Compliance; Approval, Manufacture, Sales and Marketing of Drug, Medical Device, Diagnostics, and Consumer Products
No aspect of our business is more subject to governmental regulation than the development, manufacture, approval, sales and marketing of health care products. Due to the complexity of many of these regulations, we take particular care to ensure employees are aware of regulatory requirements and comply with them.
Johnson & Johnson is committed to marketing all our products responsibly. Our product marketing and communications efforts include educational brochures, videos, direct-to-consumer (DTC) advertising and online vehicles. These forms of direct-to-consumer education give people information they can use when communicating with their doctors about the benefits and risks of treatments.
We require our people to follow industry guidelines on advertising medicines and medical devices to ensure our product advertising and communications are helpful to people and doctors and give them full information about the benefits and the risks of our products.
Sales Intermediaries must agree in writing to the following contractual obligations:
- Agreement to comply with all applicable laws, including the US Foreign Corrupt Practices Act (FCPA) and local law;
- Agreement to comply with the applicable policies contained in the Health Care Business Integrity Guide;
- A provision permitting termination of the agreement by the J&J Company if its receives evidence that there may have been an offer, promise, or payment in violation of the FCPA or local law;
- Agreement to report any change in ownership or the undertaking of any official position by anyone affiliated with the Sales Intermediary and a provision for termination if such a development raises potential corruption issues;
- Agreement to certify compliance periodically at the J&J Company’s request;
- Rules regarding payment of compensation and sufficient transparency of detail of bills to enable proper record keeping;
- A provision prohibiting assignment of the agreement;
- Agreement not to use subcontractors without the Operating Company’s prior approval, which may be based on a certification by the Sales Intermediary that required due diligence was performed;
- Audit rights for Johnson & Johnson; and
- Agreement to cooperate in case of disputes.
Employment and Labor Laws and Policies
Our most important resource is our employees. It is our policy to comply with all applicable laws and regulations, including those concerning hours, compensation, opportunity, human rights and working conditions. Johnson & Johnson strictly prohibits discrimination or harassment against any employee because of the individual’s race, color, religion, gender, sexual orientation, national origin, age, disability, veteran’s status or any status protected by law.
In addition to local laws and regulations, the Company’s Policy on the Employment of Young Persons prohibits the employment of people under the age of 18 in the manufacture of any product, or any component of a product, by or for any of our businesses. Forced or compulsory labor of any workers is also prohibited.
It is our policy that all employees work in a clean, orderly and safe environment. The Company requires full compliance with applicable workplace safety and industrial hygiene standards mandated by law.
Compliance with Securities Laws
Johnson & Johnson is often required by the Securities Laws of the United States to disclose to the public important information regarding the Company. All such disclosure, as well as all public communications, should be full, fair, accurate, timely and understandable.
An employee who knows important information about the Company that has not been disclosed to the public must keep that information confidential. Employees may not buy or sell securities of any other company using important non-public information obtained in the performance of their duties or provide that information to others.
Political Activities and Contributions
We encourage our employees to be involved personally in political activities. Nonetheless, employees may not use or contribute funds or assets of the Company to any political party, candidate or campaign unless this is the accepted practice, is lawful in the country involved and is approved by the appropriate Company Group Chairman.
Respect for Trade Secrets and Confidential Information
It is our policy to respect the trade secrets and proprietary information of others. Although information obtained from the public domain is a legitimate source of competitive information, a trade secret obtained through improper means is not.
Johnson & Johnson maintains a hotline for employees that is accessible by telephone or online at www.credohotline.com. This hotline can also be accessed by non-employees, customers and vendors of the enterprise. Global Compliance Services, Inc. operates the confidential hotline, and sends an annual summary report to Johnson & Johnson Corporate Internal Audit. Reports are forwarded to the appropriate company or corporate staff for investigation and resolution.
The information on this page represents only a summary of the policy views and of various laws and regulations. For more information, refer to the Policy on Business Conduct.