Panasonic believes that cartels and the bribery of government officials can have critical effects on management throughout the entire group, and it acts to combat these phenomena as a group. In more specific terms, within the “control environment, prevention, detection, and response” framework discussed below, each Company and regional headquarters establishes an annual compliance program (such as the one shown below), based on an understanding of the risks that it faces with its business and in its region. At the end of the fiscal year, the Company President or regional Head is required to certify the effective functioning of the program to the Panasonic President. Supervisory organizations relating to these practices have been established in departments at the Panasonic headquarters, and these organizations provide oversight and support for initiatives in Companies and regional headquarters.

  • Control Environment: Particularly during Compliance Awareness Month, the President, Company Presidents, and regional Heads issue compliance messages targeting employees. In each Company, a compliance workshop among the business division directors is held, helping to foster a culture of compliance in all business divisions.
  • Prevention: E-learning is provided in eight languages for the people responsible within the organizations of relevant departments. In fiscal 2018, around 40,800 people underwent this training. Between fiscal 2016 and 2018, group study sessions were conducted with management from overseas companies. In total, around 8,600 people attended. To improve the effectiveness of Panasonic’s anti-cartel and anti-bribery of government officials’ regimes, each location conducts self-checks to examine the operational status of cartel prevention measures, including the functioning of company rules and offering of education, and each Company or regional headquarters reviews or audits these self-checks, especially in places where we conduct BtoB and BtoG business and in countries and regions where the Corruption Perception Index established by Transparency International indicates high risk. We implement improvements immediately when internal rules are found to be less than fully observed.
  • Detection: Hotlines have been established at the group headquarters, in Companies, and at regional headquarters. These hotlines are publicized through educational activities.
  • Internal investigations are conducted immediately when behavior suspected of constituting a violation is discovered through auditing or a hotline tip-off.
  • Response: If internal investigations confirm that violations have occurred, the violation is immediately halted, the true cause is uncovered, measures to prevent re-offense are implemented, and the people involved are disciplined.

Preventing Cartels

We at Panasonic are taking the fact that our company has been implicated in multiple international cartel incidents seriously, and we have positioned the prevention of cartels as a critical groupwide issue. If Panasonic were to become involved in the creation of a cartel, we would not only lose the trust of our customers but also be required to pay high penalties and compensation for damages, as well as lose our designation in public procurement. We take very serious and detailed care to prevent any such involvement, because it would have a variety of negative impacts on our business.

Basic Policies

We have put the following basic policies in place in an effort to prevent cartels, collusive bidding, and other such violations.

  • Contact with competitors is allowed only in absolutely necessary cases and subject to prior approval.
  • Agreements and exchanges of information with competitors regarding prices, quantity, and other competition-related matters are strictly prohibited.
  • One who encounters behaviors that may give rise to suspicions of cartel must make an objection, leave the room, and file an internal report.
  • The company establishes whistle-blowing systems and internal leniency systems to improve its ability to self-regulate and conduct appropriate monitoring based on risk assessment, whereby maintains an effective anti-cartel system.

Rules Concerning Activity and Relationship with Competitors

In 2008, we established the Rules Concerning Activity and Relationship with Competitors for the purpose of preventing behaviors that could lead to cartels or bid rigging or cause suspicion of same, which apply to all group employees. These rules include items such as the following:

  • Prohibition of agreements or exchanges of information regarding product pricing, quantity, performance or specifications that may cause suspicions of cartels or bid rigging
  • Prior approval system under which contact with competitors requires prior approval of the head of the business group and the person in charge of legal affairs
  • Responses to inappropriate activities
  • Duty of reporting possible violations
  • Measures taken in response to violations
  • Internal leniency system

In the device business where the risk of cartels is particularly high, we are promoting global initiatives meant to prevent cartels through activities including making sure once again that these policies are fully understood by executives at Company Management Conferences and Managing Directors Conferences at overseas subsidiaries, cartel prevention training for all employees, identifying suspicious behaviors, submitting written pledges, conducting cartel audits, and speeding up personnel rotations.

Preventing Corruption

Prevention of Bribery of Government Officials

Even as the authorities in different countries continue to bear down harder on corruption, along with the expansion of business in developing countries and solutions business comes a higher risk of bribery of public officials. Panasonic continues to engage in efforts to prevent bribery of government officials through means such as issuing bribery prevention policies from senior executives, establishing standards and approval processes for spending on dinners and the like with public officials, managing business partners, and ensuring that training and awareness-raising activities for executives and employees are thoroughly carried out, especially for business sites located in countries and regions that rank high in the Corruption Perceptions Index.

Rules on Dealing with Government Officials

In 2010, we established the Rules on Dealing with Government Officials for the purpose of preventing bribery of government officials or actions that my raise suspicions of such unlawful behavior.
These rules stipulate that no employee may offer, give, pay for, promise to pay for or authorize the payment or the grant of any benefit to any government officials in connection with obtaining or retaining business.
An approval process and specific standards were established such as for meals with government officials. These are intended to prevent the direct offering of benefit to government officials and also the indirect offering of benefit through consultants, distributors, lobbyists, or other business partners. Careful screening and designation of business partners must be conducted, and contracts must include provisions prohibiting bribery.
In cases of violations of these rules, swift steps must be taken to redress the situation, and strict measures must be taken against the violation.
In addition, regarding expenses for social interactions or gifts, prior approval is required, and detailed reports must be filed. There is also a process for ensuring that no government officials are involved, in an effort to preclude corrupt acts.

Ensuring Transparency of Political Contribution Funds

The Japan Business Federation says of political donations: "Costs commensurate with the task are essential to properly maintaining democratic politics. Political donations by companies are a crucial part of companies’ social responsibilities."
("In order to maintain democratic politics in a proper manner, matching costs are required, and it is important for businesses to make political donations as part of their social contribution.") Panasonic abides by this policy and makes political donations as a part of its corporate social responsibilities.
When making donations, Panasonic complies with the Political Funds Control Act, all other relevant legislation, and with its own strict rules.
In Japan, the legal duty of disclosing political fund income and expenditures falls on political groups. These disclosures are publicly available from the Official Gazette or from official prefectural bulletins.

* Japanese Only

Prevention of Other Corruption

Needless to say the prohibition of bribery of government officials, as provided in the Code of Conduct, it is prohibited to offer benefits of any kind, including gifts, meals and entertainment, and to receive personal benefits from any of our stakeholders, which would go contrary to laws and regulations and social ethics. Concretely, the Panasonic Group has its anti-corruption policies region by region, so that such policies would meet the laws and custom of trade of that country/region.
For instance, the companies in European region have their own guidelines in place on “Entertainment, Gifts and Hospitality” in line with their national laws for public officials and non-public officials, which contain specific limits and examples of what is and is not considered acceptable. Further, each person is obligated to speak out against suspected acts of bribery or corrupt practices.
In emerging countries and regions including China and Asia, it is prohibited to offer directly or indirectly any benefit to business partners including government officials, in connection with obtaining or retaining business. Additionally, each director and employee is required to sign an undertaking letter committing never offering/accepting a bribe, to raise the awareness of bribery.