Panasonic promotes a companywide compliance program for serious misconduct, including cartelization and bribery. In fiscal 2019, the company put forward the following initiatives to strengthen its compliance infrastructure worldwide, with a focus on anti-bribery efforts:

  • Executive-level participation: The management team, consisting of the CEO, company presidents, regional directors, and general counsel, issued compliance memoranda for all employees and discussed compliance at board of directors’ meetings and other executive conferences. Another example of executive management’s direct involvement in compliance is when the general counsel visits international group companies and discuss compliance with local managers.
  • Compliance awareness and a culture of compliance: Panasonic creates and distributed comics and posters covering serious misconduct. It also planned and held participatory compliance events for employees. Moreover, all employees were subject to taking the Compliance Awareness Survey. In fiscal 2019, roughly 146,000 employees responded, a 12.5% increase over fiscal 2018.
  • Education and awareness: Panasonic offers e-learning courses about serious misconduct to all employees, and in fiscal 2019, approximately 140,000 employees took these courses. The company also publishes a quarterly newsletter on serious misconduct for business division heads.
  • Establishing a new global hotline: As described in the Whistleblowing Systems section above, Panasonic has realized unified report management by establishing a global hotline. The company immediately conducts internal investigations when it discovers potentially illegal activities through hotline notifications and reporting or through related audits. After confirming the facts surrounding illegal activities through these internal investigations, Panasonic immediately addresses the violations, while seeking out their actual causes, implementing measures meant to prevent recurrences, and punishing all relevant parties.
  • Improving and enhancing anti-bribery programs: In light of Panasonic’s global bribery risk assessment results, management teams of each company and the General Counsel have been discussing compliance, sharing issues, and investigating countermeasures. In fiscal 2020, each company is already implementing and promoting the outcomes of these discussions as specific initiatives.
  • Strengthening compliance auditing and investigation functions: In fiscal 2019, divisions of the Panasonic main office conducted compliance audits for bribery and corruption risks to quickly detect, prevent, and handle these risks. Starting in fiscal 2020, Panasonic intends, as part of its organizational efforts, to periodically conduct compliance audits at all new locations and to follow up on points discovered in such audits. Additionally, on July 1, 2019, Panasonic updated its companywide whistleblowing and investigation systems with its new global regulations: Regulations Concerning Whistleblower Reports and Their Investigations, and Regulations Concerning the Prohibition of Retaliatory Treatment Toward Whistleblowers. (For details, see the chapter on Whistleblowing Systems.)

Moreover, in fiscal 2020, while continuing to further last year’s initiatives, Panasonic is promoting new projects, including the establishment of a separate compliance committee. This committee will form to discuss and give direction to focal points regarding risks and compliance infrastructure at the management level.

Preventing Cartels

We at Panasonic are taking the fact that our company has been implicated in multiple international cartel incidents seriously, and we are working to prevent cartelization activities. 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 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 audits, and speeding up personnel rotations.

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

Preventing Corruption

In addition to preventing the bribery of public officials, Panasonic, through the stipulations in the Panasonic Code of Conduct, has prohibited offering benefits of any kind—regardless of whether they occur as entertainment, gifts, or in any other form—or receiving any personal benefits in any situation in which they would be in violation of laws or social ethics.
To more thoroughly prevent bribery and corruption worldwide in a manner appropriate for today’s reality, Panasonic, on July 1, 2019, enacted new global regulations that apply to all Panasonic Group employees and executives. These regulations include the Global Anti-Bribery/Anti-Corruption Policy, Rules on Third-Party Intermediary Risk Management for Anti-Bribery/Anti-Corruption, Rules on Gift and Hospitality for Anti-Bribery/Anti-Corruption, and Rules on Conflict of interest. The company will also introduce processes for reviewing new risks to discover bribery and corruption risks before transactions take place when starting or renewing dealings with "Third-Party Intermediary".
The company enacted the Global Anti-Bribery/Anti-Corruption Policy to effectively prevent, discover, investigate, and correct acts of genuine corruption or those deemed to be corruption with regard to the bribery of public officials and corruption related to business partners. Specifically, it prohibits facilitation payments and acts considered bribery or corruption in connection with political contributions, donations, or sponsorships; lobbying; hiring and recruitment; and mergers, acquisitions, and joint ventures. It also specifies procedures for preventing bribery and corruption.
Panasonic enacted Rules on Third-Party Intermediary Risk Management for Anti-Bribery/Anti-Corruption to establish general rules for identifying, reviewing, selecting, and registering intermediary sellers and special subcontractors, as well as for initiating and terminating transactions with such parties.
These rules are meant to mitigate the risks of bribery and other forms of corruption regarding intermediary sellers or service providers and to prevent, discover, investigate, and correct genuine or potential problems related to these risks.
With the Rules on Gift and Hospitality for Anti-Bribery/Anti-Corruption, the company enacted specific procedures for prohibiting the provision or receipt of gifts or entertainment, including meals, hospitality, and travel costs, in relation to public officials or business partners. These procedures are meant to prevent the risks related to these acts of bribery or corruption.
The Rules on Conflict of Interest establish specific actions that could be conflicts of interest, while also establishing rules related to preventing, identifying, managing, and correcting conflicts of interest.
To ensure full compliance with these new global regulations on bribery and corruption prevention, Panasonic will continue raising awareness and promoting efforts companywide.