In addition to Johnson & Johnson’s own employment policies, the Company requires that all suppliers abide by the following policy on the employment of persons under the age of 18 (“young persons”) in the manufacture of any product, or any component of a product, by or for Johnson & Johnson or any of its affiliates worldwide.
Age, Health & Safety
No person under the age of 16 shall be employed. No person between the ages of 16 and 18 shall be employed unless such employment is in compliance with the health, safety and morals provisions of the International Labour Organization Convention 138 Concerning Minimum Age (“ILO Convention 138”), a summary of which is attached hereto.
No young person shall be required to work more than 48 hours of regularly scheduled time and 12 hours of overtime per week nor more than six days per week.
Laws & Regulations
No young person shall be employed unless such employment is in compliance with all applicable laws and regulations concerning age, hours, compensation, health and safety.
No manufacturer shall be engaged to manufacture any product, or any component of a product, for Johnson & Johnson or any of its affiliates worldwide unless such manufacturer has entered into an enforceable written agreement to comply with this policy, submit to periodic compliance inspections and maintain the records necessary to demonstrate compliance. If any such manufacturer shall be found to be in breach of such agreement, the manufacturer’s engagement shall be terminated. (See attached Model Compliance Provision for Contract Manufacturing Agreements.)
Exceptions & Interpretations
Upon good cause shown in a specific situation, an exception to the Age and Hours (but not Health & Safety) provisions of this policy may be granted by the responsible Executive Committee Member with the concurrence of the General Counsel, if such exception is consistent with ILO Convention 138 and all applicable laws and regulations. (See below for summary of ILO convention 138.) Requests for definitive interpretations of this policy should be directed to the General Counsel.
NOTE. The Age provision of the Johnson & Johnson Policy on the Employment of Young Persons is more restrictive than ILO Convention 138. The following summary is provided only as an explanatory supplement to the Health & Safety and Exceptions provisions of the Johnson & Johnson policy. For guidance on specific situations, please contact the Johnson & Johnson Law Department.
Summary of ILO Convention No. 138 Concerning Minimum Age
For work likely to jeopardize the health, safety or morals of the worker, the minimum age is 18; if there is adequate protection and training of the worker, then the minimum age for such work is 16. (No exception to this provision is available under the Johnson & Johnson policy.)
For work, which is not likely to jeopardize the health, safety or morals of the worker, the minimum age is 14. (Requires an exception under the Johnson & Johnson policy.)
For light work, which is (a) not likely to be harmful to the health or development of the worker, and (b) not such as to prejudice his/her attendance at school or participation in vocational training, the minimum age is 12. (Requires an exception under the Johnson & Johnson policy.
Model Compliance Provision for Contract Manufacturing Agreements
(Modify as necessary to properly identify the parties and to conform to the style and terminology of the agreement.)
Contractor has read and understands the Johnson & Johnson Policy on the Employment of Young Persons (the “Policy”). In the manufacture of the articles, which are the subject of this agreement, Contractor shall employ young persons only as permitted by the Policy. Contractor shall permit representatives of Company to enter Contractor’s premises at any reasonable time to inspect relevant employment, health and safety records and to observe the manufacturing process. Contractor shall maintain the records necessary to demonstrate compliance with the Policy. If Contractor shall fail to comply with this provision, then Company shall have the right to terminate this agreement forthwith and without penalty.
Last Updated: 2015