The ethical principles embodied in Our Credo are the lenses through which our employees make thousands of business decisions each day. To help ensure that we conduct business according to these principles, we have policies and procedures that define what we expect of our people throughout the world. Our Family of Companies provides employees with comprehensive systems that support ethical behavior, accountable business practices and compliance with laws and regulations.
These documents are core to our responsible business practices:
- The Policy on Business Conduct sets expectations that all employees will comply with all laws and regulations governing our company’s behavior, including those in the areas of employment, environment, relationships with health care practitioners, financial reporting and political contributions training.
- Our Health Care Compliance Guidelines help ensure the integrity of the relationship between our representatives and doctors.
- Principles of Corporate Governance, adopted in 2006, apply to members of the Board of Directors and senior management, whose ethical character, integrity and values are considered a critical element ensuring ethical and Credo-based behavior.
- The Code of Business Conduct & Ethics for Members of the Board of Directors and Executive Officers sets the expectations for behavior related to conflict of interest, fair practices, gifts, and compliance, among other topics.
- Global Labor & Employment Guidelines ensure that each operating unit throughout the world follows consistent principles relative to labor and employment practices.
- In addition to our employment guidelines, Johnson & Johnson has formal policies on Equal Employment Opportunity and Harassment.
- Our Policies for selling, marketing and interacting with health care professionals require that employees act according to the laws of the countries where we do business and comply with applicable industry codes of behavior.
Anti-Corruption
It is the policy of Johnson & Johnson to comply with the laws of each country in which our companies do business. This includes compliance with the applicable anti-bribery laws and regulations such as, but not limited to, the U.S. Foreign Corrupt Practices Act, the Organization for Economic Cooperation and Development (“OECD”) Convention on Combating Bribery of Foreign Public Officials, the United Nations Convention Against Corruption (“UNCAC”), and national implementing statutes.
Accordingly, J&J prohibits, directly or indirectly, offering, promising, giving, or authorizing anyone to give anything of value to or for anyone acting in an official capacity for or on behalf of: a national, regional or local government; an agency, department or instrumentality of a national, regional or local government; a government-owned or government-controlled company; or a public international organization to influence any official act (or failure to act), or any decision in violation of his or its lawful duty; or induce the use of his or its influence to affect any governmental act or decision; or secure any improper advantage in connection with business. Furthermore J&J Companies will strictly comply with applicable commercial bribery rules.”
Compliance and Monitoring
The Johnson & Johnson Compliance Committee consists of senior leaders from several corporate functions as well as three senior compliance leaders from the pharmaceutical, medical device and diagnostic, and consumer sectors. The Johnson & Johnson Chief Compliance Officer chairs the Committee. The Compliance Committee is responsible for overseeing and approving corporate and sector-specific compliance policies, procedures and programs, and periodically reporting to the Executive Committee and the Board of Directors, including reports on the state of compliance.
The corporate functions represented on the Committee play a key role in overseeing the effectiveness of compliance programs in their functional area. They carry out this role by setting standards and policies, providing enterprise-wide training on new standards and policies, and reviewing the results of audits, testing and monitoring, programs, resource allocations, training plans, and management action plan reviews.
In addition, Corporate Internal Audit conducts independent audits of the businesses that address several compliance areas, including Health Care Compliance, anti-corruption, and privacy. The corporate representatives also periodically report to the Compliance Committee on regional and global enterprise-wide compliance matters.
The Law Department and the Johnson & Johnson Office of Health Care Compliance & Privacy are responsible for setting enterprise-wide standards with respect to anti-corruption laws and interactions with Health Care Professionals.
As a general rule, the Finance organization is responsible for assuring appropriate accounting controls at all levels of the organization that ensure accuracy over financial reporting, including the investigation of potential frauds, thefts, defalcations and falsification of financial results. The organization is also responsible for evaluating, testing and monitoring accounting control systems on an ongoing basis to be reasonably assured that the controls in place continue to be appropriate and function properly. Part of this evaluation includes documenting all the steps taken to evaluate and monitor controls, as well as documenting existing accounting and internal control systems and procedures.
Training
Training on Our Credo and our Policy on Business Conduct is made available to employees worldwide in 16 languages, which we estimate covers the language needs of more than 90 percent of our worldwide employees. The training provides information on Johnson & Johnson policies regarding conflicts of interest and compliance with laws and regulations. Training on the U.S. Foreign Corrupt Practices Act (FCPA) is provided to employees outside the United States.
Our employees are asked to refresh their education in these areas every two years, and successful completion is recorded. Additionally, specific training on health care laws and regulations applicable to our businesses is undertaken through an extensive network of compliance officers throughout our worldwide business. Policies for selling, marketing and interacting with health care professionals.