Fair Operating Practices
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.
In addition to initiatives aimed at correcting the issues that we have discovered through such efforts at the business division level, we also bring those issues together centrally and comprehensively at our Head Office and reflect them in groupwide policies with consideration to societal conditions and the like, and repeat this process in the pursuit of continuous improvement. We are currently promoting activities under the themes of abiding by antitrust laws and preventing bribery of government officials.
Also, 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.
Panasonic has established as part of our management philosophy the Basic Management Objective set forth by Konosuke Matsushita, Founder of Panasonic Corporation, that says “Recognizing our responsibilities as industrialists, we will devote ourselves to the progress and development of society and the well-being of people through our business activities, thereby enhancing the quality of life throughout the world.” With this Basic Management Objective, we will engage in our business activities in a manner that ensures that our business contributes to the improvement of living standards around the world and to the progress of society. In order to put our management philosophy into practice, we have established the Panasonic Code of Conduct which includes elements from the OECD (Organisation for Economic Co-operation and Development) Guidelines for Multinational Enterprises and other norms, have translated it into 22 languages, and share our basic stance as a company in terms of our aspirations for the Panasonic brand and answering the demands of society in relation to corporate social responsibility (CSR) with all of our directors and employees globally.
Panasonic Code of Conduct (Excerpts)
The Panasonic Code of Conduct defines our efforts to establish fair business practices as a public entity of society.
Chapter 1: Our Core Values
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.
Chapter 2: Implementing the Code in Business Operations
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.
Panasonic aims to make compliance and fair business practices penetrate our worksites globally through our directors and executive officers in charge of ensuring adherence to the Code of Conduct; the legal divisions we have created at the Companies, business divisions, and regional headquarters; and the export control chief officer and individuals with job function responsibilities, based on the thinking that the level of compliance awareness of the chief executive of the business is of upmost importance. Specifically, we share the compliance policies for the fiscal year with the Companies and regional headquarters at the beginning of each fiscal year at our Global Legal Conference, and September is designated as Compliance Month (for details, refer to Compliance Training). We also contact and notify those responsible for legal matters at the Companies and other relevant organizations whenever there are changes to laws, governmental or ministerial ordinances, or notices from other authorities that have any effect on our business.
Panasonic conducts training on compliance and the Code of Conduct regularly, including when employees join the company or are promoted.
We have assembled a Compliance Guidebook to serve as a tool for putting into practice items related to compliance with the Code of Conduct. The Guidebook explains 54 topics that Panasonic considers critical from a compliance perspective, explaining each of them through examples in a way that is easy to understand, addressing how employees at Panasonic can stay in compliance with the law in the course of their daily work activities and answer societal expectations, covering topics such as preventing corruption and preventing cartels.
We also implement e-learning on compliance with a variety of laws that involve antitrust laws including those concerned with cartels, export controls, and copyright laws in sales, procurement, engineering, and other functional divisions at each Company.
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 President, 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 2016, compliance training through e-learning was held in eight languages, with 47,000 employees from 19 regional offices taking part.
Responsible Executive and Framework
The executive in charge is Managing Director Jun Ishii (as of August 2016).
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.
In fiscal 2016, we established a new organization unifying multiple response functions whose aim is to identify compliance, risk, and governance issues that span multiple work functions. This should help speed up our support for fair operating practices in all business units.
Within our company, we have established the following whistleblower hotlines as systems for receiving a variety of internal reports regarding compliance:
- "Business Ethics Global Hotline" for general information on compliance in Japan and abroad.
- "Equal Employment Opportunity Office" for consultations regarding sexual harassment, equitable treatment, and the like.
- "Fair Trade Hotline" for the reporting of legal violations concerning cartels, bribery, the Subcontract Act, and so on.
- "Internal Control Promotion Office Hotline" for accounting irregularities.
- "Fair Business Hotline" for receiving reports from our business partners.
- "Auditor Report System" for reports concerning our accounting and audits.
The Panasonic Code of Conduct stipulates that "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." At all the hotlines above, mistreatment of whistleblowers is strictly forbidden and confidentiality is assured. In addition, reports can be made anonymously if there is no need to contact the whistleblower for additional information (some hotlines are excluded).
In fiscal 2016, roughly 230 reports and consultations were handled through these whistleblowing systems. These systems respond to all reports and consultations by investigating and verifying facts with the cooperation of the relevant divisions.
Outside Japan, in addition to the "Global Hotline," region-specific reporting systems have been set up in North America, Europe, Asia, and Latin America.