Robert Wood Johnson, former chairman from 1932 to 1963, emphasized that “every time business hires, builds, sells or buys, it is acting for the ... people as well as for itself, and must be prepared to accept full responsibility for its acts.”

That business philosophy reminds us that we are accountable to the people we touch. They are the people who use our products and who help make our products. They are our neighbors with whom we share the planet, and the shareholders who invest in our vision of how to advance health care.

To help assure that we conduct business according to the values embodied in Our Credo, we have policies that define what we expect of the people within the Johnson & Johnson Family of Companies throughout the world.

Policy on Business Conduct
Our Policy on Business Conduct is at the center of our rules. It gives clear direction on how to act according to our business values, as well as the laws and regulations where our companies operate around the world. Every employee is required to follow this Policy. Managers must enforce it and certify each year that their employees understand and follow its requirements. Employees are required to report any prohibited or unlawful act and can do so anonymously through a dedicated phone line available at each Johnson & Johnson operating company throughout the world. They can also mail complaints directly to corporate headquarters in New Jersey.

The Policy is translated into many languages and compliance is assessed as part of our internal audit program. Among its mandates, the Policy directs that:

• The sale of our companies’ products and services and the purchase of products and services from suppliers are to be based solely on quality, price and service and never based on giving or receiving payments, gifts, entertainment or favors.
• Company funds, assets and information are never to be used for illegal purposes or personal gain.
• Relationships that conflict with Company interests or influence business actions must be avoided.
• All Company funds and assets are to be disclosed and recorded accurately.
• No payments are to be made to unaffiliated distributors or sales agents outside the country where a product is sold.

Full Policy on Business Conduct

Complying with Laws and Regulations
In addition to setting standards for how we do business, our Policy on Business Conduct also requires management and employees of our Family of Companies to follow the laws and regulations of the countries where they do business. It defines acceptable employee behavior on important issues and sets out the Company’s policies.

There are training programs to help employees become familiar with the regulations and to comply with them. Employees of Johnson & Johnson and our Family of Companies are responsible for complying with all laws applicable to them and their business activities, including:

• 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 that require important public information about the Company be disclosed in a full, fair, accurate, timely and understandable way, and that make it a violation to buy or sell 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.