The values that guide our decision making are spelled out in Our Credo, which requires that we uphold its tenets and guides us to consider all actions through the lens of impact to Our Credo stakeholders.
We strive to ensure all employees and contingent workers know their responsibilities to act in accordance with applicable laws, regulations and industry codes, as well as the Company’s internal standards and expectations for ethical and compliant conduct. Building on Our Credo values, Our Code of Business Conduct (Code) and Health Care Compliance (HCC) policies list comprehensive ethical standards for decisions and actions in every market where we operate. Mandatory Code training is conducted every 2 years, and HCC training is conducted each year. All new employees are assigned and required to complete Code, HCC and other relevant required training. Policies & Positions: Position on Ethics and Compliance
In 2023, we competed our biannual revision of the Code to include the following changes:
- a sole focus on the Innovative Medicine and MedTech business segments;
- inclusion of pertinent scenarios that reflect relevant Code topics;
- changes relating to technological advancements, including social media and the communication and storage of confidential business information;
- updates relating to the process to document conflicts of interest;
- insertion of a new “Use of Generative Artificial Intelligence” section;
- alignment with our other ESG-related disclosures, including our updated ESG strategy, Position on Human Rights and environmental sustainability standards and policies.
The J&J Our Credo Integrity Line provides a global, accessible channel for reporting concerns and is available 24 hours a day, 7 days a week and in 24 languages. It is independent, secure and confidential, offering a safe mechanism for anonymous reporting (where permitted by local law) of suspected concerns or potential violations of our policies or the law.
Aspects of ethics and compliance we advanced in 2023 included:
Improving the effectiveness of HCC training
We developed role-specific training scenarios to enhance the application of compliance principles in daily operations. We also introduced an audio-only version of the HCC training to help meet the diverse needs of our employees, including those who are visually impaired or benefit from audio-centric learning. We use a proprietary evaluation methodology to measure learning and again in 2023, HCC training demonstrated a statistically significant impact on learning transfer.
Our Health Care Compliance Academy was honored with the Brandon Hall Gold Award in the category of “Best Launch of a Corporate Learning University,” a testament to our culture of learning and effective programs.
New training tools
In 2023, we introduced a People Leader Training program, encouraging personal accountability in ethics and compliance. We also created a Compliance Week Toolkit, characterized by interactive, gamified activities to make compliance training engaging and effective. These initiatives strengthen the culture of integrity within the organization, equipping mid-level leaders to make ethical decisions daily.
Updating compliance guidance
We updated our Government Contracting & Pricing Compliance Framework that applies to J&J companies or business units that sell to, engage with or participate in government drug pricing programs or receive funds from U.S. government entities for R&D and other programs. The refreshed framework helps J&J companies continue to stay compliant with pricing and contracting regulations, align with regulations and reinforce expectations in a clear and consistent manner.
Providing guidance for ethical use of AI tools
In 2023, we provided guidance for our employees for use of publicly available Generative AI platforms to strengthen compliance on critical issues such as protecting company data. By understanding the ethical challenges of leveraging AI, we can shape our use of this technology to make a positive impact in a responsible manner.
Upholding bioethics
We championed ethical and transparent medical and scientific practices and policies to provide employees with the resources and training to help address bioethics questions that may arise during their day-to-day work. The Office of the Chief Medical Officer (OCMO) sponsors the J&J Bioethics Committee, which serves as an advisory body to our global teams on ethical issues in alignment with our Ethical Code for the Conduct of R&D. Policies & Positions: Ethical Code for the Conduct of Research and Development
