All TPIs engaged by Johnson & Johnson Companies are selected following a thorough, documented due diligence process. Due diligence also occurs for contract changes and, potentially, for sub-intermediaries.

As part of this process, Johnson & Johnson Companies document their relationships with TPIs in written agreements that include appropriate representations by the TPI concerning compliance with:

• All applicable anti-bribery and anti-corruption laws
• The rights of Johnson & Johnson Companies to audit books and records related to services provided
• The rights of Johnson & Johnson Companies to terminate the agreement for violation of any anti-bribery or anti-corruption laws

Each Johnson & Johnson Company provides specific due diligence instructions to the TPIs they engage.