2019 Health for Humanity Report
Responsible Business Practices
Responsible Business Practices Ethics & Transparency
GRI
  • 102-17
    Mechanisms for advice and concerns about ethics
  • 102-25
    Conflicts of interest
  • 205
    Anti-corruption 2016
  • 205-1
    Operations assessed for risks related to corruption
  • 205-2
    Communication and training about anti-corruption policies and procedures
  • 206
    Anti-competitive Behavior
  • 406-1
    Incidents of discrimination and corrective actions taken
  • 419
    Socioeconomic Compliance

Commitment to Ethics & Compliance

Our responsibilities to patients, consumers, healthcare professionals, employees, communities and shareholders are enshrined in Our Credo. This is the foundation of our values that has guided our business for more than 75 years. At Johnson & Johnson, we are committed to maintaining the highest level of integrity and ethical culture. Our comprehensive policies, procedures and compliance training help our employees and contingent workers navigate the applicable laws, regulations and industry codes, as well as our own ethical standards. See our Position on Ethics and Compliance.

Our Code of Business Conduct (CBC) and Health Care Compliance (HCC) policies specifically set forth our Company’s values, which apply to all employees and contingent workers worldwide. They list comprehensive ethical standards for decisions and actions in every market where we operate. The CBC and HCC policies are regularly communicated, and mandatory training for HCC is conducted each year with CBC training every other year. The Johnson & Johnson Credo Hotline, an integral component of our strong compliance culture, offers a secure channel for all employees, contingent workers, customers, third-party agencies and other partners to anonymously report—where legally permitted—suspected violations. We issue an annual reminder regarding the obligation to raise concerns related to ethics and compliance via the Credo Hotline and other channels.

In 2019, we maintained our robust programs to communicate, train and enforce our business conduct standards. Key additional activities in 2019 include:

Revision of the CBC: In 2019, we updated our CBC to keep pace with the evolving business environment, changes in regulatory requirements, and expectations of stakeholders, and be able to offer needed guidance for employees around the world. During an interactive, collaborative process over nine months, involving leaders of different businesses functions, we implemented several changes, including:

  • Enhancing the section on anti-corruption and anti-bribery;
  • Adding a section on our respect for human rights;
  • Improving guidance around political activity;
  • Enhancing guidance on fair treatment of employees, including adding reasonable accommodation requirements for individuals with disabilities and/or with needs relating to religious observances; and
  • Enhancing the section on conflicts of interest to reflect not only personal conflicts of interest, but those of an organizational nature as well.

These changes were approved by our Executive Committee, reviewed by our Board of Directors’ Regulatory Compliance Committee and incorporated in our CBC training for all employees.

Communicating our Escalation Procedure: At our Company, we build our culture of integrity and accountability by requiring employees to report actual or potential violations of our policies or the law, as well as risks that could jeopardize our reputation. The Escalation Procedure specifies responsibilities for all employees relating to what should be reported, the timeframe, and how. It includes reporting requirements and guidance for the full range of actual or potential ethical conduct or compliance violations such as those related to travel and expenses; accuracy of books and records; theft or fraud in any form; non-compliance with our government contracts or pricing obligations; misconduct of any kind; conflict of interest or data privacy breaches and more. In 2019, a comprehensive toolkit with training materials, real-world case scenarios and video resources was published to all managers to support the enterprise-wide communication of this important procedure.

Anti-corruption and anti-bribery: Johnson & Johnson takes a strong stance against bribery consistent with the anti-bribery laws that exist in many countries around the world. We strictly prohibit any illegal offers that may inappropriately influence patients or customers. Our products are purchased and sold based on quality and price. In our policies, we comprehensively address anti-corruption and anti-bribery, following the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and other applicable local anti-bribery and anti-corruption laws and regulations. In 2019, we updated our Position on Anti-Corruption.

  • 97%
    of assigned employees and
  • 91%
    of assigned contingent workers15 completed the CBC training.
  • 90,000
    employees and
  • 95%
    of sales and marketing employees completed the Health Care Compliance training.
  • 97%
    of employees believe they are held accountable for adhering to the highest quality and compliance standards.
  • 100%
    of senior leaders certified the compliance of their organizations with the Code of Business Conduct.*
    * Certifiers include senior leaders at VP2 level and above, selected Managing Directors and General Managers based on country or business segment risk profile and executives of recently acquired companies.

Our Performance

Inquiries and Complaints Brought through the Credo Hotline by Category

2019

2018

2017

Human Resources-related 60% 58% 59%
Financial-related 13% 11% 10%
General information questions 11% 13% 12%
Other (privacy, general security, EH&S, etc) 8% 10% 11%
Healthcare compliance-related 6% 6% 6%
Quality assurance-related 2% 2% 2%

Compliance-related Investigations

2019

2018

2017

Number of compliance-related allegations investigated through Triage Committee 738 707 693
Percentage of Compliance allegations, by category
Financial 50% 40% 34%
Healthcare Compliance 40% 46% 54%
Other (legal, quality, antitrust, product registration, privacy) 10% 14% 12%
Number of warning letters or untitled letters issued by OPDP or APLB in the U.S.* 0 Not reported Not reported
* OPDP: Office of Prescription Drug Promotion and APLB: Advertising and Promotional Labeling Branch of the U.S. Food and Drug Administration Center for Biologics Evaluation and Research.

15 Contingent workers (i.e. workers supplied by third party agencies that are the worker’s employer of record) are intended to supplement or temporarily replace existing workforce and are directly supervised by a Johnson & Johnson employee.

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