Management System

As our business activity expands globally, the frequency of improprieties increases, due not only to deliberate dishonest and criminal acts but also to a lack of corporate awareness and understanding. Employees doing business in countries and regions with fragile legal systems must constantly exercise a high degree of awareness of fair operating norms.
Panasonic has adopted 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 embodied in the “Panasonic Code of Conduct,” which incorporates the requirements of the OECD (Organisation for Economic Co-operation and Development) Guidelines for Multinational Enterprises, among other norms.
We have a global network of legal departments, the Executive Director in charge of compliance with Panasonic Code of Conduct, as well as managers in charge of export management and other persons responsible for supervising various other functions in our Divisional Companies, business divisions, and regional headquarters outside Japan.
Panasonic implements compliance programs throughout the year to enable employees to address each risk item. We also strive to enhance awareness of ethical and legal compliance issues among employees. Once each year, we review how our business sites around the world observe and practice the Panasonic Code of Conduct, and we hire an external auditing firm to conduct an internal control audit.
In addition, we have established hotlines for whistleblowers in our domestic and foreign business sites, as well as for our business partners in order to prevent misconducts and take immediate corrective actions. For sites deemed to have a high risk of bribery or corruption, the responsible Headquarters division conducts compliance audits to quickly identify, handle and prevent these risks.
Besides initiatives aimed at correcting issues identified at the business site level, we also bring those issues together centrally at our Headquarters and comprehensively reflect them in corporate-wide policies, with considerations to external factors such as social expectations. We repeat this process regularly in the pursuit of continuous improvement. We currently carry out activities on the key themes of “implementing risk mitigation measures for potential violations to competition law” and “implementing risk mitigation measures targeting bribery and corruption.”

Policy

Panasonic established the Basic Management Objective as a core management philosophy, initially introduced by Panasonic’s founder Konosuke Matsushita, which states that “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.” In order to put our management philosophy into practice, we adopted the Panasonic Code of Conduct, which includes elements from international norms including the OECD (Organisation for Economic Co-operation and Development) Guidelines for Multinational Enterprises. We have translated the Code of Conduct into 22 languages, and communicate to all our Directors and employees globally our basic stance as a company in terms of our aspirations for the Panasonic brand and how we answer to social expectations in terms of corporate social responsibility (CSR).

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.

Communication

Panasonic aims to make compliance and fair business practices the norm at all business sites globally, through the legal departments and the Executive Director in charge of compliance with Panasonic Code of Conduct. Based on the idea that compliance awareness from top executives is of the utmost importance, we aim to disseminate compliance knowledge across export managers and other individuals with various job functions and responsibilities at Divisional Companies, as well as within certain business divisions and at regional headquarters. Specifically, we notably use Direct Report Meetings to share annual compliance policies with Divisional Companies and regional headquarters, while carrying out various programs addressing compliance throughout the year.
(For further details, refer to Compliance Training). We also contact and notify the persons responsible for legal affairs at our Divisional 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.

Compliance Training

Panasonic conducts e-learning for new hires and newly promoted employees as needed and provides a variety of educational materials on compliance to increase training and awareness throughout the year.
We adopted a Compliance Guidebook to serve as a tool for putting into practice compliance-related items in 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. The Guidebook addresses how employees at Panasonic can stay in compliance with the law in the course of their daily work and answer societal expectations, covering topics including the prevention of bribery, corruption and cartels.
We also implement e-learning on compliance for sales, procurement, engineering, and other functional divisions at each Divisional Company, covering a variety of laws that involve antitrust laws including those targeting with cartels, export controls, and copyright laws.
The Panasonic Group carries out programs throughout the year, aiming to instill a global awareness of ethical and legal compliance while also boosting our ability to respond to risks. In recent years, as our business environment and practices have evolved, we have strengthened efforts to accurately identify changes in risks within specific business areas, divisions, countries and regions, as well as to identify early signs of scandals and legal violations.
Furthermore, senior management, including the President, Divisional Companies’ Presidents, division managers, and regional managers, clearly express Panasonic’s policies and stances on ethical and legal compliance as they strive to fully communicate the importance of compliance at all our business sites.
Corporate-wide compliance e-learning conducted in fiscal 2020 focused on the theme of the Panasonic Code of Conduct and was available to all employees. Approximately 145,000 employees participated in the e-learning.

Responsible Executive and Framework

Panasonic’s General Counsel (GC), Executive Director Laurence Bates, is in charge of fair operating practices (as of August 2020).
In order to ensure the dissemination of compliance and fair business practices at the business site level throughout the world, we have legal departments, the Executive Director in charge of compliance with Panasonic Code of Conduct, as well as export managers and other persons responsible for supervising various other functions in our Companies, business divisions, and regional headquarters outside Japan.

Whistleblowing System

In August 2018, Panasonic integrated its existing whistleblower hotlines for compliance-related issues to create a unified global hotline. The new hotline started addressing issues that included inappropriate use of funds, embezzlement, conflicts of interest, quality fraud, bribery, competition law violations and harassment. We also have an Equal Employment Opportunity Office in Japan available for consultation about fair treatment in the workplace, sexual harassment, and power harassment, as well as an Auditor Reporting System for company accounting and auditing issues.
The Panasonic Code of Conduct stipulates that “Whistleblowers shall be protected from dismissal, demotion, or any other retaliatory treatment that results from their legitimate reporting of possible violations of any law or regulation. We will ensure the thorough and confidential treatment of all reported information.” Retaliation against whistleblowers is strictly forbidden, and their confidentiality is assured through anonymous reporting.
In fiscal 2020, we received approximately 760 reports and requests for consultation, mostly through the abovementioned hotline. For all the contacts received through our global hotline, support desks coordinated with relevant divisions to investigate, check, and respond to claims.
In July 2019, Panasonic adopted two new internal regulations: the “Internal Reporting and Investigation Rules”, and the “Rules on the Prohibition of Retaliatory Behavior against Whistleblowers, and Others”. The former—to quickly detect and resolve violations of laws and corporate regulations—establishes operational procedures and systems for reporting suspected violations, appropriately receiving notifications, and investigating and correcting any violation. Through the abovementioned second new regulation, we will prevent retaliation against whistleblowers, case investigators, investigation collaborators, and others, while making clear that the provisions of the Panasonic Code of Conduct safeguard whistleblowers and similar parties. By doing so, we will encourage whistleblowing and ensure appropriate investigations into these cases.