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Fair Operating Practices:Performance Evaluation and Development

Appointing Directors and Executive Officers Responsible for Ensuring Compliance with the Code of Conduct and Obtaining Written Pledges

Directors and executive officers are appointed at Panasonic as well as each Group company, business division, and subsidiary to ensure thoroughgoing compliance with the Company’s Code of Conduct. At the same time, steps are taken to carry out apporpirate education and training.

The Code of Conduct is distributed to all employees and is always available for reading. A written pledge is obtained from Directors, executive officers and employees regarding observance of the Code of Conduct when he/she enters the company, assumes an executive position or the Code of Conduct is revised. If a countries’ laws, regulations or other restrictions make it difficult or improper for Panasonic to obtain a written pledge, we make sure employees have received a copy of the Code of Conduct and related training.

Compliance Awareness Month and the Compliance Committee

Panasonic has designated September as Compliance Awareness Month, during which it addresses risks and strives to embed awareness of ethical and legal compliance issues among employees around the world. Amid changes in business conditions and our operations, Compliance Awareness Month provides an opportunity to get an accurate grasp of evolving risks in specific business fields, divisions, countries and regions, as well as uncover signs of possible legal violations and misconduct.
During the month, we emphasize the importance of compliance throughout the organization through the communication of ethical and legal compliance policies as well as our stance by core management, including the president, company presidents, business division directors and regional representatives.
We also conduct a Compliance Awareness Survey during the month.

Since it was established in fiscal 2004, the Compliance Committee has been headed by the president and comprised of directors, executive officers and corporate auditors, who ensure compliance with the Anti-Monopoly Act, confirm the thorough implementation of companywide compliance measures throughout global operations, such as the prevention of corruption, and check on the current status of efforts at relevant business divisions.

Compliance Training

Employees undergo training on the Code of Conduct when they enter the company, receive a promotion, and on other occasions.
Panasonic publishes the Compliance Guidebook as a tool for the practical application of the Code of Conduct. Having undergone several revisions since it was first published in October 2006, the Compliance Guidebook explains in easy-to-understand examples how employees should conduct their daily work activities, comply with laws and regulations, and meet the expectations of society. It includes 54 subjects considered especially important from a compliance standpoint.

Examination and Reporting of Annual Adherence to and Application of the Code of Conduct

In order to embed a plan-do-check-act (PDCA) cycle into compliance, it is important to constantly monitor the effectiveness of implemented measures and the degree to which they have become established practices. For this reason, Panasonic confirms once a year that the Code of Conduct is being followed and applied as intended at all of its sites around the world. Specifically, Panasonic confirms that directors and executive officers have been appointed to ensure adherence to the Code of Conduct, education and training is given on matters related to the Code of Conduct, and written pledges to follow the Code of Conduct are obtained from employees.
These findings are reported to the auditing company as a part of internal control audits.

Whistleblowing System

Panasonic has a Business Ethics Hotline for both domestic and overseas; an Equal Employment Opportunity Office for reporting gender-related matters and sexual harassment; a Fair Trade Hotline for reporting monopolistic behavior; a Fair Business Hotline for our suppliers and customers; and a procedure to report financial and accounting matters to the Board of Corporate Auditors.
The Code of Conduct states that Whistleblowers shall be protected from dismissal, demotion, or any other retaliatory treatment because of their well-intentioned reporting of possible violations of any law or regulation. We will ensure thorough and confidential treatment of all information reported. Employees can raise concerns through any of these hotlines confidentially without fear of retaliation.
The company accepts anonymous reporting if a response is unnecessary.
In addition to a global hotline, Panasonic also has regional reporting systems in North America, Europe and Asia.
Panasonic strives to create an environment that facilitates the use of hotlines, and has contracted with external, independent service companies to provide the hotlines in North America and Europe.

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