This Code applies to all Panasonic members around the world. We all accept the following responsibilities:

• I understand that my own behavior can reflect on Panasonic’s reputation for fairness and honesty, our brand image and our company’s role in society.
• I act consistently with our Basic Business Philosophy and this Code at all times.
• I have read and understood this Code and I am familiar with the laws, regulations, company policies, internal rules and processes which have been shared with me as applying to my daily job. If there is anything I do not fully understand, I ask questions until I am clear.
• I complete compliance training promptly when assigned to me.
• I am aware and mindful of what is happening in my workplace. I speak up if I see or hear of any suspicious activity or signs that compliance or ethics are being compromised, regardless of the justification or circumstances. (See also Reporting or raising concerns)
• I will never retaliate by taking any action to disadvantage or discriminate against anyone who I believe has raised a compliance or ethical concern. Retaliation is itself a violation of this Code and if I experience retaliation or see retaliation against anyone else, I will raise a concern. (See also No retaliation)
• If, despite our best efforts, there is a suspected compliance or ethical violation, I will cooperate fully and truthfully with any investigation.

All leaders and anyone with the role of leading a team at Panasonic undertakes additional responsibilities to Panasonic and to their team members:

• I set goals for my team based on our Basic Business Philosophy and this Code and lead my team to contribute to the development of society and well-being of people, while ensuring fairness and honesty in all aspects of our business activities.
• I act as a role model for ethical behavior and compliance and I demonstrate adherence to this Code in my actions, my words and the business decisions I take.
• I communicate with my team regularly, in language which can be easily understood, about the critical importance of compliance, ethics and this Code.
• I create a culture where my team understands that compliance and ethics come before everything. I do not tolerate business performance or customer satisfaction achieved through violation of this Code, a company policy or an applicable law or regulation.
• I proactively keep myself up to date with knowledge of evolving compliance and ethical standards relevant to my area of responsibility, and seek collective wisdom on these matters. I share my learnings with my team.
• I ensure my team has access to regular compliance training and the time to complete learning assignments when due.
• I regularly consider whether existing compliance processes and procedures, and the Panasonic members and resources I assign, are adequate to manage the compliance and ethical risks impacting my area of responsibility, including as the risks change over time. I collaborate with the relevant policy and process owners to propose and make adjustments and improvements as appropriate.
• I foster an environment of trust and encourage my team to take personal responsibility to speak up if they have a concern. I ensure my team know that they will be listened to, can expect to be taken seriously and are protected against retaliation when they do.
• I monitor how compliance is being achieved by Panasonic members who are under my direct supervision.
• If a compliance or ethics concern is raised with me, I follow up promptly to involve other departments and escalate as appropriate. I raise any serious concerns that are brought to my attention as soon as possible for investigation through the proper channels.
• If any violation is identified which affects my area of responsibility, I will work with the relevant policy and process owners to take prompt corrective action of the immediate issue and consider if a more wide-reaching review is required.

In addition to the above, any person appointed to a formal, statutory position or in a leadership role at a Panasonic Group company, including as director, executive officer, advisor, fellow, auditor or special auditor in Japan or equivalent role in any other country and any other head of a Panasonic Organizational Unit, including heads of any Panasonic Operating Company, Divisional Company, Business Division, Headquarters Department, Branch Office, Sales Office, Research Laboratory or equivalent, must fulfill their obligations under applicable laws and internal rules, and undertake the following responsibilities to lead compliance at Panasonic:

• I set clear expectations of our culture for ensuring compliance. I engage in and lead the business that I am responsible for with fairness and honesty.
• I establish, implement and maintain systems and procedures to ensure compliance.
• I implement processes for monitoring the operation of these compliance systems and procedures.
• I regularly review the compliance systems and procedures I am responsible for and revise them if and when necessary.
• If I learn of an actual or suspected compliance breach in an area I am responsible for, with the support of the relevant departments:
  • I promptly and thoroughly investigate the matter;
  • I take measures to remedy the breach and any other related breaches;
  • I identify the root cause; and
  • I implement measures to prevent similar breaches from occurring again.
• If any circumstances arise which suggest an issue with the effectiveness of a compliance system or control, I take concrete steps to review the system and controls and implement any appropriate enhancements.
• If I become aware of any indication of compliance breach or an issue with the effectiveness of a compliance system or control, I take personal responsibility to confirm that the necessary steps are taken.

Panasonic’s ability to contribute positively to society depends on the acts and decisions of each individual at Panasonic. Making ethical decisions involves careful consideration before taking action. If you cannot make a decision with confidence, it may be helpful to ask yourself the following questions:

• Is this legal?
• Is this in line with the Company’s Basic Business Philosophy, this Code, and the other internal rules which apply to my role?
• Would this damage the Panasonic brand image?
• Does this feel like the right thing to do?
• Will this adversely impact our stakeholders?
• How would this be written if it becomes a news headline or shared on social media?
• How would Panasonic be impacted if all Panasonic members behaved this way?

Team leaders, supervisors and managers should ask themselves the following additional questions:

• Has this been done the right way?
• Have the proper procedures been followed?
• Is this issue one-off or could it be part of a wider problem?

Reporting or raising concerns: If your answers to these questions suggest that there may be violations of or deviations from the Basic Business Philosophy, this Code, our internal rules and procedures or applicable laws and regulations, or if you are not sure, you are expected to ask questions, report or raise your concerns and not to stay silent. You may report an actual or suspected violation, raise your concerns or discuss something you are not sure about or any doubts with any of the following resources. Panasonic will investigate all concerns that are raised:

• Consult supervisors, managers or the management team.
• Contact the human resources team, legal and compliance team, or other relevant functional teams responsible for your business or department.
• Visit the Global Hotline EARS: Available 24/7. All Panasonic members (including former Panasonic members) and business partners may raise concerns anonymously without disclosing their identity to anybody. All reports and concerns will be handled confidentialy.

No retaliation: Panasonic does not tolerate any retaliation or other action which discriminates against or disadvantages anyone who acts in good faith to raise a compliance concern.