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Employee Conflicts of Interest
Under our Policy on Business Conduct, these activities may present a conflict of interest:
• Ownership or an interest in a competitor or a business the Company has, or is contemplating, a relationship with, either directly or indirectly.
• Profiting or helping others to profit from confidential information or business opportunities that are available because of employment by the Company.
• Providing a service to a competitor, a proposed or present supplier or customer.
• Soliciting or accepting gifts, payments, loans, services or any form of compensation from suppliers, customers, competitors or others seeking to do business with the Company. Customary social amenities of modest value associated with legitimate business relationships are permissible. All business dealings must be at arm’s length and free of any favorable treatment resulting from the personal interest of an employee.
• Influencing or attempting to influence a business transaction between the Company and another entity in which an employee has a direct or indirect financial interest or acts as a director, officer, employee, partner, agent or consultant.
• Buying or selling securities of any other company using non-public information obtained in the performance of an employee’s duties, or providing such information to others.
Employees who do business internationally are also responsible for complying with the Foreign Corrupt Practices Act and the anti-corruption and anti-bribery laws of the countries in which they conduct business activities. This U.S. law prohibits a U.S. corporation or person from making or offering a corrupt payment to a foreign government official in order to obtain or retain business.
Disclosure is Key
To ensure that our employees have every opportunity to avoid conflicts of interest, Johnson & Johnson has clear guidelines regarding disclosure. Each employee is obligated to disclose his or her own conflict of interest or any appearance of a conflict of interest. We encourage employees who may have questions about a situation to disclose the pertinent details, preferably in writing, to their supervisor. Supervisors are responsible for arriving at a decision after consulting with the appropriate higher level of management.
Presidents, General Managers and Managing Directors must advise their Company Group Chairman or International Vice President in writing, of all disclosures and decisions made under this Policy.