To monitor the understanding of compliance policies, the effectiveness of measures, and the degree of adherence, once each year we conduct checks on the status of observance and practice of the “Panasonic Code of Conduct” in all our business locations around the world.
More specifically, at each group member company, a director / executive officer is appointed to be in charge of ensuring adherence to the Code of Conduct. Education and training are conducted regarding the Code of Conduct; written pledges regarding the observance of the Code of Conduct are obtained; and checks are made regarding the status of these items.
Our auditor conducts an audit of internal control.

Grave Violations and Corrective Measures

Panasonic and its US subsidiary, Panasonic Avionics Corporation (PAC), were subject to an audit by the US Securities Exchange Commission (SEC) and the US Department of Justice (DOJ; collectively, “US authorities”) in connection to the Foreign Corrupt Practices Act and other US securities-related laws. The US authorities investigated PAC’s actions related to specific transactions with airlines and its appointment of agents and consultants for these transactions. In May 2018, after negotiating with the US authorities, we agreed to pay a fine, which we have since paid. We are taking this matter seriously and managing operations to prevent further recurrences. See the section titled, “Fair Operating Practices:
Compliance Programs,” for more information on our corruption prevention strategies.
In the event that Panasonic becomes aware of any serious violations of laws or corporate regulations, we stop the violating behavior immediately, and in addition to reporting to executive management, we will consider countermeasures after verifying facts and analyzing the causes of the violation in relevant divisions. We report on such matters to the Board of Directors as necessary and correct the violations swiftly and cross-sectionally groupwide based on the resolution of the Board.