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Responding department: Corporate Citizenship & Sustainability

Stock Exchange Symbol: (JNJ:US)

Does your company have a publicly available commitment to respect human rights?

See our Statement on Human Rights here: [link]

Additional relevant policies: [link] [link] [link] [link] [link] [link] [link]

How are human rights governed in your company?

At Johnson & Johnson, we are guided by a statement of beliefs we call Our Credo, which outlines our responsibilities to our customers, our employees, our communities around the world, as well as our shareholders. These responsibilities guide our business and social practices with a strong focus on the people, customers and communities we serve.

As a decentralized and global company, we work to support our commitment to human rights through strong governance and policies as well as through the provision of clear guidelines for implementation throughout our operating companies. Responsibility for human rights follows our management structure and resides in our local operating companies. Implementation of the many policies, guidelines, and practices that inform our commitment to human rights is managed by the relevant corporate and business group functions.

Our Vice President of Human Resources reports directly to our Chief Executive Officer and is responsible for overseeing our internal human rights efforts. Compliance is monitored under our global Policy on Business Conduct through individual business units. Our Policy on Business Conduct is communicated across Johnson & Johnson. Compliance training is required of all employees, and compliance with communication, training, and execution of our Policy on Business Conduct is audited. Each business and all senior leaders must certify compliance with our Policy on Business Conduct annually, and results are reviewed by the Corporate Secretary’s Office, Internal Audit and the Board’s Regulatory, Compliance & Government Affairs Committee.

We are continually working to improve our governance of human rights and are presently engaging in a “Human Rights Refresh” to ensure we have the appropriate governance structures in place to manage both human rights risks and opportunities. Please see pages 42-44 our 2013 Citizenship & Sustainability Annual Report for more details on our approach to human rights.

How are human rights managed within your company?

One of the key areas where human rights is managed within the company is in our Supply Chain. Our Responsibility Standards for Suppliers outlines compliance expectations for suppliers and external manufacturers. Our external manufacturing partners are subject to assessments that may include an onsite audit or periodic inspections and must maintain records to demonstrate conformance to our supplier standards.

Related to human rights, these standards state that external manufacturers must:

  •  Not use forced, bonded, indentured or involuntary prison labor
  •  Not discriminate against or harass an individual on the basis of race, color, religion, gender, pregnancy, HIV status, sexual orientation, national origin, age, disability, veteran’s status, marital status, or political affiliation
  •  Not treat or threaten to treat an individual harshly or inhumanely. Harsh or inhumane treatment includes sexual harassment or abuse, corporal punishment, coercion or verbal abuse
  •  Avoid unsafe working conditions by providing sufficient rest periods during the workday and honor agreed upon days off from work and maximum working hours
  • Pay wages for all hours worked and clearly communicate the wages that employees are to be paid to them in advance of commencing work and communicate to all employees if overtime is required and the wages to be paid for such overtime
  •  Comply with the Johnson & Johnson Policy on the Employment of Young Persons and not employ anyone under the age of 16 and not employ anyone under the age of 18 to perform hazardous work
  •  Respect workers’ rights to make informed decisions free of coercion, threat of reprisal or unlawful interference regarding their desire to join or not join organizations
  • Respect workers' rights to bargain collectively without unlawful interference

As part of our enterprise goals called Healthy Future 2015, we have a goal that requires all suppliers in high-risk countries to confirm awareness of and conformance with the human rights provision of our policies, and that requires all critical Johnson & Johnson employees receive human rights training.

Another key area of management is within Access to Medicine and the right to health. In 2013, Johnson & Johnson signed Guiding Principles on Access to Medicines developed by Business for Social Responsibility’s (BSR) Healthcare Working Group to frame industry’s approach to expanding access to quality health care globally. Johnson & Johnson is a founding member of the Healthcare Working Group.

More on our work here: [link]

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Engagement with stakeholders on human rights issues varies depending on the area of the business. One example pertains to our clinical trials protocols. Before anyone can enroll and participate in a clinical trial sponsored by one of our operating companies, the clinical investigators must ensure that they and anyone who participates in a trial are fully informed of the potential benefits and risks of the medicine or device. We have procedures in place to fully inform participants of potential benefits and risks, to protect the confidentiality of their private information, and to protect vulnerable populations. We abide by the guidelines for Good Clinical Practice of the International Conference on Harmonization. To ensure that study participants know what to expect and can make an informed decision about whether to participate in a study, they must be given relevant information about the treatment option they are considering and what it could mean for them. They are also informed about available alternative therapeutic options. Patients can share this information with their families and their physicians. Clinical investigators are also required to give potential trial participants time to discuss and consider whether to participate in a specific clinical trial. Another form of engagement is with our suppliers in our supply chain. OurResponsibility Standards for Suppliers outline compliance expectations for suppliers and external manufacturers. Our external manufacturing partners are subject to assessments that may include an on-site audit or periodic inspections and must maintain records to demonstrate conformance to our supplier standards.

Priority human rights issues: What are some of the priority human rights issues for your company?

  • Health (including workplace health & safety, prevention of pollution)
  •  Workplace diversity / non-discrimination
  •  Forced labour and human trafficking (including in supply chains)
  • Conflict minerals
  • Transparency in payments to governments / responsible tax practices
  • Other issue(s): Clinical Trials

Actions on conflict minerals

Along with governments, NGOs, the investment community and other corporations, Johnson & Johnson is concerned with human rights violations, such as forced labor, sexual violence, human trafficking and child labor, which we understand are occurring in the Democratic Republic of Congo and adjoining countries (the “DRC region”) as a result of the civil discord there. We understand that the armed groups responsible for the conflict in the DRC region may be directly or indirectly financed by the mining of and trade in the ores from which tin, tungsten, tantalum and gold are derived.

We are taking steps to determine the use, country of origin and source of 3TG minerals in our global product portfolio across our Consumer, Pharmaceutical and Medical Devices & Diagnostics businesses.

Using a documented reasonable due diligence process, as suggested by the Organization for Economic Cooperation and Development (OECD) guidelines, we are working closely with our suppliers to determine the presence of 3TG in our supply chain. In furtherance of our commitment, we:

  • Expect our suppliers to source materials from suppliers who also source responsibly, including from legitimate, conflict-free mines in the DRC region;
  • Require all our 3TG suppliers to conduct the necessary due diligence and provide us with proper verification of the country of origin and source of the materials used in the products they supply to Johnson & Johnson companies;
  • Support initiatives to verify smelters and refiners that are conflict-free and expect our suppliers to utilize any such conflict-free smelter/refiner programs that are available;
  • Reserve the right to verify any information received from our suppliers.

If a supplier is found to not be in compliance with these objectives, the supplier is expected to develop, implement and document plans to remedy such non-compliance in a timely manner. If the noncompliance cannot be resolved, we reserve the right to terminate the relationship with the supplier.

See our Statement on Conflict Minerals for additional context: [link]

Actions on 'other' issues

Clinical Trials

Our clinical trials policies and management systems are designed to respect the human rights of trial participants. This includes monitoring how we develop trials for quality and how the trials are conducted. We do this in consultation with regulatory authorities to advance science. We have a strong record of conducting ethical, safe clinical trials, a commitment guided by our Ethical Code of Conduct for Research and Development and our approaches to Conducting Clinical Trials and Research & Development in the Developing World. We also adhere to 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. [link] [link] [link] [link] [link] [link]

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Our Human rights commitments and various policies in relation to human rights reside on our Corporate Citizenship website ([link]).

Additionally, information on how we meet human rights indicators according to the Global Reporting Initiative (GRI) is included in our annual Corporate Citizenship & Sustainability report [link].

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

As mentioned earlier, Johnson & Johnson is guided by a statement of beliefs we call Our Credo, which outlines our responsibilities to our customers, our employees, our communities around the world, as well as our shareholders. These responsibilities guide our business and social practices with a strong focus on the people, customers and communities we serve. All employees, vendors, distributors and customers have the opportunity to anonymously report potential violations of policy or law through the Company’s Credo Hotline, available by phone and also 24 hours a day in 23 languages by website. Additionally, anyone can report allegations through other methods (phone calls, emails, etc.) within their local business unit or to the Audit, Law, and Security or Human Resource organizations. All Credo Hotline reports are routed by the external vendor to Corporate Internal Audit, which triages the reports to corporate, sector or operating company personnel for follow-up investigation and action. In addition, a Triage Committee comprised of the Chief Compliance Officer, Internal Audit, the Law Department, Worldwide Security and Human Resources reviews the serious allegations to determine the best means to investigate.

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

Johnson & Johnson is a signatory of the UN Global Compact. We also follow the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. The company’s Citizenship & Sustainability team has been a member of Business for Social Responsibility’s (BSR) Human Rights Working Group since 2013, and plays an active role in ongoing discussions and benchmarking activities with other peer company members. Additionally, BSR is a key business partner to Johnson & Johnson in ongoing benchmarking on the subject.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

In partnership with BSR, we developed our first Statement on Human Rights in 2010, prior to the UN Guiding Principles being formally endorsed. Since then, we have continued to monitor the human rights landscape to ensure that our approaches are in line with the Guiding Principles. In 2014, we engaged BSR to take a fresh look at our current statement to ensure alignment and to identify opportunities for improvement, as needed. Also, we are conducting a gap analysis of our current human rights management system against the Guiding Principles and our current statement.

What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

As a large, multinational corporation, we encounter many of the same challenges that other companies our size face. One example is in managing the complexities of very large supply chains that include thousands of suppliers where monitoring and assessing human rights commitments of each and every one of them becomes an enormous undertaking.