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.

Once each year, employees fill out "Compliance Awareness Surveys." These surveys include topics that are common globally, such as compliance, and information security, and also other topics that are specific to particular Companies, places of business, and regions. There were around 130,000 respondents globally in fiscal 2018. The survey results are analyzed from a variety of perspectives – region, company, employee rank, and so on – and are used in a wide variety of functions, such as the formulation of policies and measures regarding compliance and responses to specific issues.
For example, there are uneven levels of legislation, depending on the country, within Asia—which Panasonic considers a strategic overseas region. This region poses considerable risks in regard to Panasonic’s efforts to combat corruption. In this business environment, in order to develop fair and powerful solution business – including B2B and B2G – we were able to identify issues through this survey such as: (1) the need for ongoing efforts to instill compliance awareness, (2) the need for repetition of compliance education, and (3) the national differences in compliance awareness. Based on these results, various elements were incorporated in the mid-term action plan to practice in the daily business activities, including (1) the formulation of action guidelines and education campaigns at the level of the regional headquarter, (2) the strengthening of e-learning and training programs in each national language, and (3) the fortification of alliances involving legal departments in each region and the raising of the level of compliance through auditing.

Grave Violations and Corrective Measures

Panasonic subsidiary MT Picture Display (hereafter, MTPD) and three of its subsidiaries argued their case before Tokyo’s High Court for the dismissal of an order to pay fines imposed by the European Commission, but when a decision was reached to deny their claim on April 2016, the companies appealed to the Supreme Court. The Supreme Court announced its decision to deny the appeal in December 2017, making the Tokyo High Court’s decision on the matter final. Panasonic has taken this development seriously and continues to work to ensure that, through complete and thorough management, such issues do not arise again. For information about Panasonic’s policies for preventing cartels, refer to the chapter on “Fair Operating Practices: Fair Trade.”
In the rare event that Panasonic becomes aware of any serious ethical or legal violations, 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.