ANTI-CORRUPTION AND
ANTI-BRIBERY POSITION

Anti-Corruption
and Anti-BriberyPosition
Introduction
As a global and socially responsible company, Kenvue is committed to conducting businessaround the world with integrity and the highest ethical standards. As such, we oppose corruption
and bribery in all of its forms. Our Code of Conduct and our core values of putting people first andearning the trust of our customers and business partners, live at the heart of this Anti-Corruption
and Anti-Bribery position.
Engaging in bribes or corruption violate the U.S. Foreign Corrupt Practice Act (FCPA), anti-money
laundering laws, local and regional anti-corruption laws, and other local and foreign laws andregulations. Not only are such activities unlawful, but they can harm consumers, violate faircompetition, and lack transparency. Our products should always be chosen freely based on theirmerits and not as the result of an inducement.
Kenvue has a zero-tolerance policy on bribery and corruption. We take all reasonable steps toensure Kenvuers and third-party partners understand and abide by company expectations andrequirements, and conduct themselves in accordance with the highest ethical standards at alltimes.
Anti-Corruption and Anti-Bribery Principles
Value Transfers
Kenvue will not offer, promise, or give anything of value to a healthcare professional (HCP),
government official (GO), or private person in return for a business advantage, nor will we ask foror accept anything in return for Company business. Examples of prohibited activities include:• Fraudulent conduct such as kickbacks, facilitation payments, and other illegal payments• Charitable donations made in exchange for business• Company job appointments for an individual or their family member in exchange for abenefit to the Company

ANTI-CORRUPTION AND
ANTI-BRIBERY POSITION

In many markets there are also anti-corruption and anti-bribery laws. For example, as a US
headquartered company, we must comply with the US Foreign Corrupt Practices Act (FCPA) andthe anti-corruption laws of the other countries in which we do business.
Kenvue has implemented internal controls at all levels of the organization to ensure compliancewith anti-corruption and anti-bribery laws. We audit and refine these internal controls on anongoing basis. Continuous monitoring includes documentation of existing accounting, books andrecords, and internal control systems, evaluation procedures, and risk assessments.
Engagements with HCPs and GOs
Globally there are laws and regulations that govern interactions with GOs. GOs may also be
subject to special ethics rules, disclosure obligations, and conflict of interest provisions
depending on the jurisdiction. Examples of interactions with GOs include lobbying activity andinteractions with regulators and inspectors.
Because some GOs and HCPs may be able to influence the purchase and use of Kenvue
products, it is important to avoid real or perceived conflicts of interest that would interfere withthem performing their official duties, and in the case of HCPs, their clinical judgement. Any
funding or payment to an HCP, GO, or a health care organization or government entity (e.g.,contractual arrangement) must never be conditioned on the current or expected futurepurchasing or recommendation of our products. Because of these special considerations, Kenvue
closely reviews relevant business activities before engaging in certain interactions with or projects
involving an HCP and/or GO (especially when it involves a value transfer, including gifts andhospitality).
Third Party Intermediaries
From time to time, Kenvue may contract with third party intermediaries to conduct activities andmake payments on its behalf. Under the FCPA and other anti-corruption laws, Kenvue can be held
responsible for improper payments or other value transfers by anyone acting on behalf of theCompany if the Company knew or reasonably should have known that the activity was improper.
As such, Kenvue takes proper due diligence measures prior to engaging third parties such as
business justification and an information questionnaire. Kenvue also informs third parties that they
are prohibited from engaging in corrupt activity on the Company’s behalf. Kenvue monitors its
third parties via a risk-based management process and investigates any wrong doing and takes
appropriate corrective action as needed.
Books and Records
Company books and records will accurately reflect the transactions that occur and must never befalsified to disguise corruption or bribery. The Company:• Establishes and maintains adequate internal accounting controls• Keeps records sufficient to prepare financial statements consistent with generally
accepted accounting principles• Assures that all corporate assets are properly controlled and accounted for, including
performing proper review of expense reports

Kenvue ensures that invoices received from third parties accurately describe the underlying
services and have sufficient detail to enable compliance with the above requirements.

ANTI-CORRUPTION AND
ANTI-BRIBERY POSITION

Political, Community, and Charitable Contributions
Kenvue believes in contributing to the communities in which it does business, and permits
donations to community projects, local and foreign charities, and other qualified recipients. Before
making a contribution, the Company verifies that donations to foreign-based charities and otherrecipients are not disguised illegal payments to foreign officials in violation of anti-corruption laws.
Risk Assessment
Kenvue conducts regular risk assessments of the business activities it engages in around theworld. These risk assessments consider current company activities that may be associated withbribery and corruption risk, emerging risks based on future business plans, the evolving legal andregulatory environment, and the corruption index in local markets where business activities takeplace.
The results of these risk assessments are a key input into the Compliance Office’s priorities. As
risks are identified, the Compliance Office, in alignment and partnership with the relevantbusiness leaders, develops and implements mitigation plans. These plans may include
strengthening policies and procedures, conducting additional training and education, performing
follow-up auditing and monitoring, implementing governance strategies, and establishingmanagement action plans.
The risk assessment process minimizes Company corruption risk by continually improving andstrengthening the Compliance program, fostering strategic alignment between Compliance andthe business, allowing for risk-based adjustments to compliance program priorities and allocationof resources, and providing leadership with line of sight into Company risk areas. Any discovery ofpotential non-compliance or unlawful activities resulting from the risk assessment process will be
immediately investigated and completed in a timely matter.
Reporting
The Company has established the Kenvue Integrity Line (www.KenvueIntegrityLine.com) where
suspected or known prohibited or unlawful activity may be reported in a safe and anonymous
manner. Reports can be made either online or by phone, 24 hours a day / 7 days a week, and isavailable in multiple languages.
Conclusion
There are penalties for individuals and companies that violate anti-corruption and anti-bribery
laws. For individuals, this may include fines, debarment from certain interactions withgovernments, imprisonment, and Company disciplinary action up to and including termination.
Companies may face fines and debarment as well.
Kenvue aims to be a responsible and ethical company. Our brands are among the mostrecognizable in the world, and our continued success depends on maintaining the trust andconfidence of our customers, consumers, and business and government partners. As such, we
prohibit bribery and corruption in all its forms, and are committed to adhering to the principles set
forth herein, which form the basis for Company anti-corruption and anti-bribery policies andprocedures.