At Johnson & Johnson, Our Credo guides our business and social practices with a strong focus on the people, customers, and communities we serve. Respect for human dignity and individual rights are some of the fundamental values embodied in Our Credo. As a global company, we have a responsibility to uphold these values everywhere we operate.
We believe our most significant opportunities to impact human rights—and therefore, our greatest areas of responsibility—are in the areas of human rights in the workplace, clinical research ethics, and improving access to health care. Several Johnson & Johnson policies and statements address how we protect human rights. Our Statement on Human Rights acknowledges our commitment to respecting human rights as embodied in the Universal Declaration of Human Rights and its two corresponding covenants, The International Covenant on Civil and Political Rights and The International Covenant on Economic, Social, and Cultural Rights.
We also follow the principles in the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. Our commitments for respecting human rights in the workplace are detailed in: Global Labor & Employment Guidelines, Policy on Employment of Young Persons, Responsibility Standards for Suppliers, and Human Trafficking Policy. Our Global Labor and Employment Guidelines articulate our expectations for labor and employment practices at our sites, including preventing forced labor, discrimination and child labor, among other topics. We conduct assessments against our Global Labor and Employee Guidelines on an ongoing basis through local Human Resources and our Global Employee & Labor Relations function. We consider assessment data confidential. GRI 406-1
In regard to clinical research ethics, we have Ethical Code for the Conduct of Research and Development and the statement on Conducting Clinical Trials. These policies outline how we ensure protection of human rights of trial participants. Our research practices are also consistent with external standards and guidelines, such as the Good Clinical Practice Guidelines of the International Conference on Harmonization, the World Medical Association’s Declaration of Helsinki and the Belmont Report.
Internal Human Rights Efforts
The internal human rights efforts of our Company are overseen by the Executive Vice President of Human Resources, Chief Human Resources Officer, reporting directly to the Chairman and CEO. Following our management structure, responsibility for meeting our internal human rights commitments resides in our local operating companies, managed by the relevant corporate and business group functions.
Compliance with internal and external human rights commitments is also monitored under our global Code of Business Conduct through individual business units. Code of Business Conduct training is required every two years, starting with 2016, of all employees and contingent workers. Each business and all senior leaders must annually certify compliance with our Code of Business Conduct. Results are reviewed by the Corporate Secretary’s Office, Internal Audit and the Board of Directors' Regulatory, Compliance & Government Affairs Committee. GRI 412-1
Grievances GRI 103-2
Procedures exist to remedy all reported employee-related concerns and grievances, regardless of topic. All employees can anonymously report potential violations through Our Credo hotline, to Human Resources, within each operating company locally, including using the Open Door process, and in North America, the Common Ground process. In all other operating regions, an appeal process to re-open grievances exists under certain conditions. In all countries in our Asia Pacific region, we have a grievance resolution policy that explains how employees can raise complaints, and details manager responsibilities to act. We communicate hotline access broadly, and visibility of this access and hotline functionality are in scope for financial audits.
In the Americas and Asia Pacific, Employee Relations staff independently investigates non-compliance in employee relations matters, and verified non-compliant situations are addressed by the respective business unit. In the Europe, Middle East and Africa region, investigations are the responsibility of local human resources and are overseen by regional employee relations teams. We address concerns raised through the Open Door process locally, and do not track them at an enterprise level. Concerns raised through the hotline are reported at an enterprise level.
Collective Bargaining/Minimum Notice Periods
Johnson & Johnson provides the freedom to establish a formal employee organization or representation structure across the enterprise and our operating companies, and company sites can establish an employee representation structure or framework except where prohibited by law. Representation structures vary globally enterprise-wide.
Regarding minimum notice periods, the management of reorganizations and layoffs and the policies associated with them vary depending on the location, nature, size and scale of the restructuring, as well as the qualifications of the employees impacted. Local operating leaders endeavor to communicate significant plans of operational changes to employees and their representatives, where they are present, in a timely and practical manner in advance of actions being taken. Many of our collective bargaining agreements contain negotiated provisions covering severance or separation pay and benefits. Where there is no legal minimum notice period, Johnson & Johnson operating companies attempt to provide notice at the earliest feasible time. GRI 402-1
Human Rights in the Supply Base
Responsibility for our efforts on human rights in the supply base rests with our Chief Procurement Officer. Our Procurement organization publishes and implements our Responsibility Standards for Suppliers, which detail what we expect of our suppliers. Many of the 60 countries in which we operate1are considered by independent organizations to be at risk for human rights violations, including forced labor, child labor and restrictions on the right to exercise freedom of association or collective bargaining. See page 68 of our 2015 Citizenship & Sustainability Report for the full listing of countries at high risk of human rights violations, as defined by independent organizations. GRI 407-1; 408-1; 409-1
Johnson & Johnson strictly prohibits employees, subcontractors, subcontractor employees and agents from engaging in human trafficking-related activities. These activities include engaging in sex trafficking, procuring commercial sex acts (even if this practice is legal in the jurisdiction where it transpires), using force, fraud or coercion to subject a person to involuntary servitude, or obtaining labor from a person by threats of serious harm to that person or another person, among others. Please see our Human Trafficking Policy for more information.
Rule 13p-1 under the Securities Exchange Act of 1934 requires public reporting companies that manufacture or contract to manufacture products containing “conflict minerals” (defined as tin, tungsten, tantalum and gold [3TG]) to conduct due diligence on the source and chain of custody of those conflict minerals to help to determine whether they originated from the Democratic Republic of Congo (DRC) or adjoining countries and directly or indirectly financed or benefited armed groups in those countries. As indicated in our Statement on Conflict Minerals, we are taking steps to determine the use, country of origin and source of 3TG in our global product portfolio. Based on our due diligence efforts for the 2016 reporting period, we do not have conclusive information regarding the country of origin or facilities used to process the necessary conflict minerals in the Johnson & Johnson Family of Companies’ products. For more information, see our Conflict Minerals Report for the calendar year ended December 31, 2016.
Internal Human Rights Efforts
Code of Business Conduct training is required of all employees and contingent workers, and is offered in 25 languages as of the end of 2016. Each business and all senior leaders must certify compliance with our Code of Business Conduct annually, and results are reviewed by the Corporate Secretary’s Office, Internal Audit and the Board’s Regulatory, Compliance & Government Affairs Committee. GRI 412-1
We assigned Code of Business Conduct training to 129,861 employees and 2,703 contingent workers with a completion rate for the training of 78 and 84 percent respectively, representing approximately 8,700 hours of training on human rights in 2016. GRI 412-2
As part of our Healthy Future 2015 Goals, we provided all critical employees, defined as those in positions most sensitive to human rights infringements, with human rights training. This training continued to be offered in 2016 and will be refreshed in 2017 as one of the objectives of a newly formed cross-functional team devoted to human rights in the supply base.
As of the end of 2016, employees were represented by labor unions or work councils at approximately one third of our sites around the world. GRI 102-41
Human Rights in the Supply Base
We continued to reinforce our management approach to human rights issues in the supply base with the goal of creating a more comprehensive enterprise-wide framework. Specifically, under the guidance and oversight of the newly-formed Enterprise Governance Council, we re-assessed our human rights policies and processes to identify gaps and opportunities for improvement. This work provided additional insight for the revision of our Responsibility Standards for Suppliers that continued in 2016. The revised Standards will align closely with the relevant provisions from the UN Guiding Principles on Human Rights. To develop a robust implementation plan for the revised Standards, we established an internal working group represented by Global Community Impact, Environment, Health, Safety & Sustainability, Legal, and Procurement functions. Among other activities, this plan will include a refreshed internal human rights training to launch in 2017.
In our global Sustainable Procurement team, we added dedicated resources focused on human rights issues. We prioritized our supplier categories for risk, including human rights risks, with our External Manufacturers, Active Pharmaceutical Ingredient suppliers and Construction, Capital and Facilities Services suppliers emerging as a higher priority, and undertook a review of our assessment tools, like EcoVadis, to ensure robust coverage of our Responsibility Standards for Suppliers.
As a member of the Board of the Consumer Goods Forum (CGF), we endorsed the CGF Forced Labor Resolution and Priority Industry Principles passed in 2016, and are working to embody these principles into the revisions of our Responsibility Standards for Suppliers, along with additional expectations for human rights and conflict minerals.
1 A list of our operating locations can be found in Exhibit 21 of our 2016 10-K filing.