We are striving to strengthen our "internal control, prevention, detection, and response" with regard to compliance, placing priority on abiding by antitrust laws and preventing corruption.
As corporate activity expands globally, improprieties occur with some frequency, due not just to deliberate dishonest and criminal acts but also to a lack of awareness and understanding. Employees doing business in countries and regions where legal systems are incompletely realized must perennially exercise a high degree of awareness of norms.
We at Panasonic have set down a clear set of rules for compliance with the law and corporate ethics. We strive to achieve thorough adherence to these rules, with the aim of promoting fair operating practices in all countries and regions of the world, and to realize a sustainable society. This is the "Panasonic Code of Conduct," which incorporates the requirements of the OECD (Organisation for Economic Co-operation and Development) Guidelines for Multinational Enterprises and other norms.
In our observance of our own Code of Conduct, we have a global network of legal departments, directors, and executive officers in charge of ensuring adherence to the Code of Conduct, as well as managers in charge of export control and other persons responsible for supervising various other functions in our Companies, business divisions, and regional headquarters outside Japan.
Each year, we designate September to be "Compliance Awareness Month," marked by efforts to strengthen our awareness of the need to observe ethical and legal requirements. We conduct a "Compliance Awareness Survey" to check the degree of compliance awareness dissemination among our employees around the world. Once each year, we check the status of observance and practice of the "Panasonic Code of Conduct" in our business locations around the world.
In addition, to prevent improprieties and achieve quick resolutions, we have established hotlines for whistleblowers in our domestic and foreign business locations, and for our business partners.
We strive to resolve, at the business location level, the issues that are identified through these efforts, but these measures are also collected in a unified, comprehensive manner at the Group Head Office level, so they are reflected in corporate-wide measures based on social conditions as well. Currently, our priority themes are abiding by antitrust laws and preventing corruption.
The Panasonic Code of Conduct defines our efforts to establish fair business practices as a public entity of society.
An Enterprise as a Public Institution
Since our business is dependent on our customers and other stakeholders, we must remember that "an enterprise is a public institution," that must strive to fulfill its social responsibilities. In addition to listening to stakeholders' opinions, we must conduct our business activities transparently in order to be accountable. In short, we must continue to be fair, truthful, honest and swift in taking action to comply with our social responsibilities.
II-3. Compliance with Laws, Regulations and Business Ethics
(1) Compliance with Laws, Regulations and Business Ethics
We will conduct business with integrity, a law-abiding spirit, and the highest ethical standards.
We will fulfill our tasks by always observing not only applicable laws and regulations, but also the highest standards of business ethics. Compliance with laws, regulations and business ethics in all our business activities is essential to the survival of our business.
(2) Fair and Sincere Action
We will respect free and fair competition, and abide by all applicable antitrust (competition law) and other laws and regulations. All of our transactions shall be properly and fairly recorded.
We will not engage in bribery of any kind. We will be sensitive to, and shall abide by laws and regulations and social ethics that govern the offer of benefits of any kind, including gifts, meals and entertainment. In the same manner, we will not receive personal benefits from any of our stakeholders.
Moreover, we remain steadfast in our attitude to oppose any illegal group or organization.
(3) Thorough Observation of Relevant Laws and Regulations
To ensure that all employees observe applicable laws and regulations and respect their spirit, we will establish appropriate in-house codes and promote employee understanding through seminars and training.
(4) Prompt Redress and Strict Treatment for Violations of Laws and Regulations
If we suspect that our activities violate applicable laws, regulations or business ethics, we will report such information to a superior, or to the legal affairs section or other relevant section, or via an in-house notification hotline. Whistleblowers shall be protected from dismissal, demotion, or any other retaliatory treatment because of their well-intentioned reporting of possible violations of any law or regulation. We will ensure thorough and confidential treatment of information reported.
Once we have established that a law or regulation has been violated, we will immediately seek to remedy the violation, take appropriate action and prevent it from recurring.
Compliance with antitrust laws is one of our priority themes. We have established the following basic policies to prevent cartels and bid rigging.
Based on these basic policies, we established the Rules Concerning Activity and Relationship with Competitors in 2008, which apply to all group employees.
Throughout the year, we strictly observe the "Panasonic Code of Conduct," which incorporates the requirements of the OECD (Organisation for Economic Co-operation and Development) Guidelines for Multinational Enterprises. Once each year, we check the status of observance and practice of the Code of Conduct in our business locations around the world.
Each year, we designate September as "Compliance Awareness Month" to check up on our efforts to ensure that the mental attitude of strict adherence to ethics and the law has taken hold globally and to respond to risks. In recent years, as our business and the business environment have changed, this has presented opportunities to strengthen our efforts to accurately grasp signs of changing risks, legal violations, and improprieties in specific fields / units of business, countries and regions.
In this interval, the heads of Companies and business divisions, regional representatives, and other senior executives have clarified policies and positions on the observance of ethics and the law, ensuring the dissemination of the importance of compliance down to the ground level.
During this period, we also conduct a "Compliance Awareness Survey" among our employees.
In fiscal 2015, our Compliance e-Learning was conducted in six languages in 10 countries. Approximately 61,000 employees participated.
Executive in charge: Managing Director Jun Ishii (as of July 2015)
To ensure the dissemination of compliance and fair business practices at the ground level throughout the world, we have legal departments, directors, and executive officers in charge of ensuring adherence to the Code of Conduct, as well as managers in charge of export control and other persons responsible for supervising various other functions in our Companies, business divisions, and regional headquarters outside Japan.
Beginning in fiscal 2016, we are establishing a new organization whose aim will be to identify compliance, risk, and governance issues that span multiple work functions and to unify our response functions. This should help speed up our support for fair operating practices in all business units.
Panasonic has been a member of the Business Ethics Research Center (BERC) since BERC was founded in 1997. Together with BERC and other member companies, we have engaged in research, practice, education, and promotional activities for management ethics through panels, study groups, information-exchange activities, and so on.