Johnson & Johnson – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Johnson & Johnson demonstrates a moderate level of governance in its lobbying activities, including some references to climate-related lobbying. The company states that "the Regulatory Compliance & Sustainability Committee of the Johnson & Johnson Board of Directors annually reviews a report of the Company's political contributions as well as the Company’s major lobbying priorities, lobbying policies, practices, and activities," which indicates a structured oversight mechanism. Additionally, the Senior Vice President of Worldwide Government Affairs & Policy and other senior management roles are involved in approving political contributions and overseeing lobbying activities, suggesting accountability at high levels of management. The company acknowledges potential misalignments with trade associations and outlines a range of approaches to address disagreements, such as "declining to participate in certain initiatives sponsored by the organization" or "reaching out directly to the organization’s leadership to examine a possible change in position." However, while these measures indicate some alignment efforts, there is no explicit mention of a systematic process for ensuring that lobbying activities align with its climate policy or goals. Furthermore, while the company’s climate policy and governance are reviewed by the Science, Technology & Sustainability Committee, this oversight does not appear to extend specifically to lobbying alignment. The company does not disclose a detailed lobbying audit or review process that evaluates alignment with climate-related goals, nor does it provide evidence of monitoring mechanisms for indirect lobbying through trade associations. This indicates that while governance structures exist, they lack comprehensive detail and explicit focus on climate lobbying alignment. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Johnson & Johnson demonstrates a moderate level of governance in its lobbying activities, including some references to climate-related lobbying. The company states that "the Regulatory Compliance & Sustainability Committee of the Johnson & Johnson Board of Directors annually reviews a report of the Company's political contributions as well as the Company’s major lobbying priorities, lobbying policies, practices, and activities," which indicates a structured oversight mechanism. Additionally, the Senior Vice President of Worldwide Government Affairs & Policy and other senior management roles are involved in approving political contributions and overseeing lobbying activities, suggesting accountability at high levels of management. The company acknowledges potential misalignments with trade associations and outlines a range of approaches to address disagreements, such as "declining to participate in certain initiatives sponsored by the organization" or "reaching out directly to the organization’s leadership to examine a possible change in position." However, while these measures indicate some alignment efforts, there is no explicit mention of a systematic process for ensuring that lobbying activities align with its climate policy or goals. Furthermore, while the company’s climate policy and governance are reviewed by the Science, Technology & Sustainability Committee, this oversight does not appear to extend specifically to lobbying alignment. The company does not disclose a detailed lobbying audit or review process that evaluates alignment with climate-related goals, nor does it provide evidence of monitoring mechanisms for indirect lobbying through trade associations. This indicates that while governance structures exist, they lack comprehensive detail and explicit focus on climate lobbying alignment.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Comprehensive	Johnson & Johnson provides a highly transparent account of its climate-policy lobbying. It names several concrete policies it has sought to influence, including the EU revision of the Ambient Air Quality Directive, the U.S. “carbon dividends framework” promoted by the Climate Leadership Council, and the Biden Administration’s goal of “cutting GHG emissions by at least 50% below 2005 levels by 2030” and achieving net-zero emissions by 2050, as well as continued U.S. participation in the Paris Agreement. The company explains how it engages: it signed an open letter to President Biden, submitted responses to the EU public consultation on air-quality rules, held “direct engagement with EU policymakers,” participates in trade and business coalitions such as the Climate Leadership Council, Clean Energy Buyers Alliance and We Mean Business, and funds city-level programmes with the C40 Cities Climate Leadership Group—clearly identifying both the mechanisms (letters, consultations, coalition advocacy, direct meetings) and the targets (U.S. President, EU institutions, U.S. federal policymakers, city leaders). Johnson & Johnson is also explicit about the outcomes it seeks, advocating for “a gradually increasing carbon fee,” “carbon dividends for all Americans,” “border carbon adjustments,” “regulatory simplification,” “strong EU air quality standards aligned with WHO recommendations,” and U.S. policies that maintain a credible pathway to net-zero emissions. Together these disclosures demonstrate comprehensive transparency across the policies it lobbies, the ways it lobbies, and the specific legislative or regulatory results it is pursuing.	A