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Responsibilities of Managers and Employees
All of our managers are responsible to enforce and comply with the Policy on Business Conduct, including distribution of the Policy to employees to ensure awareness and compliance. Managers at certain levels are periodically required to certify compliance with the Policy. False certification is dealt with severely.
At all levels, our employees strive to uphold the ethical principles embodied in Our Credo and they are expected to comply with all policies of the Johnson & Johnson Family of Companies and applicable trade associations, as well as applicable law. Some of these laws include:
• Antitrust and competition laws that protect fair competition among businesses.
• Environmental laws and regulations.
• Health Care Compliance rules that regulate how we interact with health care professionals and how we development, manufacture, seek approval for, sell and market our health care products in the United States.
• Employment and labor laws and our policies concerning hours, compensation, opportunity, human rights, working conditions, discrimination and harassment, orderly and safe work environments, and the employment of young persons.
• U.S. Securities laws requiring that important public information about the Company be disclosed in a full, fair, accurate, timely and understandable way, and prohibiting the buying or selling of stock on the basis of important non-public information.
•All laws and regulations that govern political activities and contributions.
• Trade secret laws and policies that respect the confidential information of others.
Employees having information about a prohibited or unlawful act are expected to report the matter promptly to the General Counsel or other member of the Law Department. Employees may also report violations by:
• Speaking to anyone in line management, including the Executive Committee, Corporate Internal Audit, the Chief Financial Officer, the Treasurer, the Controller or Corporate Secretary.
• Contacting the Audit Committee of the Board of Directors through its Chairman or one of the Board's other independent directors.
• Writing to any of these individuals anonymously at the Company’s Headquarters.
• Calling the Corporate Headquarters anonymous telephone compliance line or one of the Company’s many other anonymous telephone compliance lines globally.
We expect managers to advise employees of this reporting obligation and encourage them to report any prohibited or unlawful activities. There are no reprisals for reporting. We expect employees to provide full assistance and disclosure to both internal and external auditors.