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About Panasonic > CSR > Fair Operating Practices
The Panasonic Code of Conduct outlines our strict adherence to the principles of conducting our daily activities with ethics and integrity. We have created a management structure to detect, report, and address violations of the Code by all employees, including directors and executive officers. Our focus is primarily on these three key areas.
Each Panasonic regional domain is tasked with creating their own point of view on their risk priorities, as well as what measures should be in place to address those risks. When assessing the risks we face, we consider two primary factors: the frequency or likelihood of the risk occurring and the size of the financial impact if it does occur. Although there are region-specific risks, we also have three key priority issues across the globe: fair trade, export/import control, and anti-bribery.
Making sure that employees of Panasonic's operations are aware of our compliance policies, since 2006, we have dedicated the month of September to "Compliance Awareness Month." We use this opportunity to do a thorough review of our employees' understanding of the laws and regulations regarding how to proceed with daily business activities, as well as to determine any instances of non-compliance. During this period, a message regarding compliance is issued from our top management to every employee. We also conduct our "Compliance Awareness Survey" to identify trends in risk awareness and to determine how we can continue to improve our initiatives.
We also implement E-Learning on our Code of Conduct in Japan and in the United States, and are in the process of implementing E-Learning in Asia, including China, as well as other parts of the world. Each region will customize trainings according to which risks are most important locally.
As we expand our overseas business, it is increasingly important to educate employees who are working abroad about the potential compliance risks in the countries they will live in during their overseas assignments. Addressing our potential risks overseas is an important matter, and we provide a "Legal Guidebook for Employees Working in Overseas Countries," as well as relevant training to educate employees about the local legal context and risks.
In addition to making sure Panasonic employees are aware of and are in compliance with our Code of Conduct, we have made every effort to provide all employees, including directors and executive officers, with avenues to raise their concerns about potential business risks in their workplaces.
Panasonic has six hotlines* for employees: a Business Ethics Hotline for both domestic and overseas; an Equal Employment Opportunity Office for reporting genderrelated matters and sexual harassment; a Fair Trade Hotline; a Fair Business Hotline for our suppliers and customers, for example, who have been forced to pay a bribe; and a procedure to report financial and accounting matters to the Board of Corporate Auditors. Employees can raise concerns through any of these hotlines confidentially so that there is no retaliation of any concerns raised through these hotlines. The company accepts anonymous reporting if a response is unnecessary.
* Excludes some countries.
The company entered into plea agreements with the United States Department of Justice (in September 2010) and the Canadian Competition Bureau (in October 2010), and paid fines to resolve claims that its household refrigerator compressor business unit engaged in cartel activity.
The company also accepted the European Commission ("Commission") decision imposing a fine on refrigeration compressors that the Commission announced in December 2011.
In order to assure that no further cartel activity will occur, the company has enhanced its long-standing antitrust compliance policy by implementing a global compliance program specifically designed to prevent cartels. In 2008, the company introduced "Rules Concerning Activity and Relationship with Competitors" to clearly set forth the rules employees must follow when contacting competitors. It also implemented a prior approval system, which requires directors and employees to obtain prior approval from their division directors
and legal managers before contacting competitors. The company also introduced an in-house leniency system to encourage employees with knowledge of possible cartel activity to disclose the relevant facts to management.
Chaired by the president and attended by directors and executive officers related to compliance matters, this compliance committee meets annually to discuss current global compliance issues that are relevant to the company.
In fiscal 2012, the company reviewed the efforts related to the company' s compliance activities in the corporate "Compliance Committee" and discussed additional personnel measures. The top management again strongly restated that it is the company' s policy not to engage in cartel activities and requests employees mainly in sales and marketing departments to confirm whether they encounter suspicious activities or not.
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About Panasonic > CSR > Fair Operating Practices
