1.Safeguarding against corruption
Panasonic’s business philosophy is to provide the best products and solutions in a fair and honest manner in all business dealings. This leads to greater business opportunities. We strongly reject any profits gained from acts of bribery or corruption involving government officials or other commercial business partners.
Our Commitment
- We do not tolerate any acts of bribery or corruption in our relationships with government officials or with other commercial business partners, or even the appearance of corruption.
- We have established internal rules and procedures to manage and mitigate the risks in dealing with third-party intermediaries, sales intermediaries and administrative service providers and to safeguard against corruption involving third parties. We conduct due diligence screening of our business partners. Our contracts with intermediaries prohibit bribery and corruption. If we reasonably believe that any of our business partners are associated with acts of bribery or corruption which are not remedied to our satisfaction, we may take action up to and including suspension, non-renewal or termination of any relevant business relationships.
- We have established and rigorously enforce internal rules regarding gift giving and entertainment with government officials and other third parties.
- We prohibit our members from offering any benefit or support to a government official to encourage or speed up a routine government or regulatory procedure or decision, other than payments officially specified by law or regulation. These prohibited payments are often referred to as “facilitation payments” and examples include payments of small amounts requested by individual government officials to accelerate or complete customs clearance or other government approval procedures.
My Commitment
- I comply with applicable internal rules on anti-corruption and prevention of bribery.
- I do not provide or offer any benefit to any government official or third party, including suppliers, customers or business partners (or their relatives or close contacts), to improperly influence a decision regarding Panasonic business or to obtain or continue any improper business advantage, even if providing a benefit is customary in the local market. “Benefit” can take many forms, examples include cash; cash equivalents such as gift cards, transportation cards (taxi, train, bus), gift vouchers, gift coupons, loans, and frequent flyer mileage; gifts; meals; travel and other forms of hospitality or entertainment; service credit; political or charitable contributions; donations; sponsorships; employment; or business opportunities and internships (paid or unpaid).
- I do not encourage or request anyone to provide a benefit to me or to any of my relatives or close contacts, or accept any benefit from any government official or any third party suppliers, customers or business partners, in return for any business advantage.
- I conduct business transactions in accordance with applicable internal rules, including screening of third-party intermediaries, sales intermediaries and administrative service providers for corruption and bribery risk.
- I comply with applicable internal rules and procedures when conducting activities on behalf of our company, such as government contributions, donations, sponsorships, lobbying, employment/engagement of individuals, mergers/acquisitions and joint ventures.
2.Meeting our commitments and ensuring safety
and quality of our products and services
We conduct our business always with fairness and honesty and our customers expect the very best. We can only continue to meet the commitments we make to our customers and to society by prioritizing compliance with legal requirements and our customers’ specifications for the safety and quality of our products and services.
Our Commitment
- We give utmost priority to the safety and quality of products and services in all design, development, manufacturing, marketing and sales activities. We have established the necessary internal procedures to comply with all applicable requirements including laws, regulations, quality standards and the contractual commitments we make to our customers.
- We comply with regulations applicable to our business including obtaining the necessary permits, licenses, and qualifications. We also ensure that all Panasonic members comply with applicable regulations including making sure they hold the qualifications necessary to perform their role.
- If we receive information regarding the safety of our products or services, or if we suspect that a requirement has been violated, we promptly investigate the matter and determine the cause. If we identify a potential safety issue, we cooperate fully and transparently with public authorities, taking prompt action as necessary to remove serious threats to public health and safety and to prevent any recurrence.
- We develop better products and services in terms of safety, quality, performance, design, affordability, environmental friendliness and ease of use, promoting safety assurance and improvement for various people, that are accessible to a wide range of individuals without feeling inconvenience in their lives and society.
- We implement measures to provide our customers with products and services that use safe and secure information technology.
- In order to prevent accidents and ensure the safe use of our products and services, we provide our customers with easy-to-understand instructions and explanations on how to correctly use our products and services. We also ensure that all of our related activities, ranging from product installation to after-sales maintenance and repair, are conducted in a safe and responsible manner.
My Commitment
- I carry out my work while being mindful of the safety and quality of our products and services.
- I do not falsify or inaccurately report performance or testing results to meet applicable requirements including laws, regulations, quality standards and the contractual commitments we make to our customers.
- I understand and comply with the information and training provided by the company regarding the laws, regulations and standards applicable to the products and services I work on and the commitments made to our customers. If I am not sure, I ask questions to my manager or the relevant department(s) until I am clear.
- I properly acquire the qualifications, certifications and licenses which our company informs me are necessary for my work. Where my role requires any qualification, license or other certification, I will not carry out the relevant activity until I have obtained the necessary certification.
- I promptly report or raise a concern if I become aware of any information regarding the safety of products and services, or suspected violation of any requirements. (See also Reporting or raising concerns)
- If I believe that the procedures I am required to follow are impractical or impossible to comply with, or do not make sense based on my training or qualifications, I ask questions to my supervisor or manager or raise a concern.
- 【For leaders】 I proactively learn about the legal and regulatory requirements applicable to the manufacturing process, products and services relevant to my area of responsibility, including local requirements relevant to the location of manufacture, the point of sale, delivery and end-use. I share this information with my team. I take these requirements into account and assign Panasonic members with the appropriate skills, expertise and qualifications to each task.
3.Building fair and transparent supply chains
Our suppliers are essential business partners supporting us to provide products that deliver the value sought by our customers. We work with our suppliers in a relationship of mutual trust and confidence to pursue increased performance. We build sustainable supply chains with our suppliers, sourcing materials and services in compliance with corporate social responsibility and local laws and regulations to provide our customers with high quality, competitive products and services that can be used in a safe and secure manner.
Our Commitment
- We fully adhere to our Clean Procurement Declaration and, based on our philosophy that a company is a “public entity of society”, we conduct transactions with global suppliers on a fair and transparent basis.
- Together with our suppliers we engage in procurement activities in a responsible manner, taking into due consideration society’s expectations regarding human rights, labor practices, health and safety, protection of the environment, export control and information security. We comply with related laws, regulations and international standards in our procurement activities.
- We have established Supply Chain CSR Promotion Guidelines and require our suppliers to comply with these Guidelines.
My Commitment
- I will not allow my personal interest to influence the procurement process. I conduct all transactions with suppliers on a fair and transparent basis in accordance with the internal policies and procedures. (See also Acting in our company’s interest)
- I understand the importance of following strict ethical standards to build a healthy relationship with suppliers and allow competition to occur in a fair and transparent manner. Unless permitted by applicable internal rules, I do not accept or exchange any entertainment invitations or gifts, including meals, entertainment or travel costs and expenses, with any business partners including suppliers and customers. (See also Safeguarding against corruption)
- If I become aware of any behavior that breaches our company prohibitions on unfair or non-transparent business transactions, I take the necessary steps within my control to remedy such behavior and I report my concerns. (See also Reporting or raising concerns)
- Where required under applicable internal rules for the responsible procurement of goods and services, I require the suppliers I work with to comply with applicable laws, regulations and social standards, to respect our management philosophy and this Code, to take due consideration of the environment, human rights and health and safety of their personnel and of the personnel in their supply chain and to maintain the confidentiality of important information. I carry out the procedures set out in our internal rules including confirming our suppliers’ implementation of the above. (See also Safeguarding Health and Safety, Protecting and using our company’s assets, Respecting human rights and Protecting the environment)
4.Interacting with government bodies
Dealing with government bodies is not the same as dealing with a private company or individual. Private companies interacting with government bodies and state-owned enterprises are often held to higher standards of integrity and transparency and must follow specific rules including ethics and information sharing in bidding and government procurement procedures. Panasonic and all Panasonic members need to understand and comply with the unique rules that apply when conducting business with government bodies and state-owned enterprises.
Our Commitment
- We deal with government bodies in a truthful, fair and transparent manner. We ensure that our communications with government bodies are not deceptive or misleading.
- We comply with all applicable government contracting rules, laws and regulations, including in ordinary commercial transactions in which a government body is the end customer.
- We train and educate our members not to engage in improper conduct such as bribery, corruption, or anti-competitive behavior in bidding and procurement transactions with government bodies. (See also Safeguarding against corruption and Building our business on trust and fair competition)
- We disclose all required information when requested to do so in our dealings with government bodies.
- We do not participate in any contracts or bidding transactions when we are able to influence government bodies’ decision making, for example where we are assisting a government body to design their bidding or contracting rules, or helping a government body to evaluate other parties’ bids.
My Commitment
- If I am responsible for any transaction with a government body (including when a government body is the end customer), I will first ensure that I understand the statements made by Panasonic under “Our commitment” above and comply with all applicable internal rules relating to dealings with government bodies.
- Before bidding for any government business, I familiarize myself with the relevant government body’s procurement rules. I ensure that any bid I submit conforms with those rules.
- When dealing with a government body, I do not inappropriately attempt to obtain information from the government body, including information related to the selection of contractors or details of competitors’ bids.
- When receiving a request for information from a government body or any work proposal from government-related individuals, I consult with and follow the instructions of my superiors (who may require to consult with the legal and compliance department) as appropriate.
- I report any concerns or misconduct that I notice in connection with a government body contract or government body relationship.
- If I intend to provide a gift, including any customary gift, to a government official, I first ensure that I comply with all applicable internal rules and follow the required procedures.
5.Building our business on trust and fair competition
We strive to provide products and services that are superior to our competitors and satisfy the needs of our customers through open and fair competition.
Our Commitment
- We respect and encourage open and fair competition.
- We comply with competition laws and regulations.
- We do not engage in prohibited anti-competitive conduct, such as agreeing with other companies to control prices or other conditions of sale, colluding with any other parties in bidding transactions to ensure that a particular bidder wins or loses or any other conduct that illegally affects the freedom of our competitors and business partners to make independent business decisions.
- We are committed to increasing consumer confidence in Panasonic by providing products and services of the highest quality and providing accurate information to our customers.
My Commitment
- I comply with applicable internal rules relating to relationships with competitors.
- I do not disclose any sensitive, non-public information to our competitors, including the sharing of intentions with respect to future pricing decisions, that could impact competition, such as wholesale or retail pricing of our components or end products, quantity, quality, performance, specification, allocation of customers, markets, categories and other conditions of sales of our product or service warranties, or market share of our products or services.
- Before responding to any invitations from competitors or attending any meeting or call with competitors, I will review the planned agenda for any topics which may involve disclosure of sensitive information by any participant and seek any necessary pre-approvals to participate in the event.
- I reject any invitation from our competitors to share sensitive information and remove myself from the discussion. I immediately report any such invitation to the legal and compliance team.
- I do not engage in anti-competitive conduct such as controlling or seeking to control the price at which our customers offer our products for sale, abusing a dominant market position to force suppliers, vendors or customers into agreeing to unfair terms and conditions or other unfair trading practices.
- I do not make unsubstantiated or untrue statements or misleading advertising about Panasonic’s products and services.
6.Trading globally
We conduct business with the aim of improving the well-being and quality of life of people around the world. Trade restrictions and economic sanctions have been established in countries and regions where we conduct our business activities and are constantly changing. We must fully understand and comply with these laws and regulations as we expand and develop our global business activities.
Our Commitment
- We comply with all import and export related laws and regulations, including export controls, customs regulations and sanctions that apply to business transactions involving our products, services, software, technology and technical data. This includes requirements that may apply to activities that occur overseas.
- We obtain all necessary licenses and permits required for shipping our products and for sharing technical information.
- We conduct necessary verifications and screenings of our business partners and related parties, investment targets and sources of capital to ensure that our business transactions comply with all applicable restrictions regarding sanctioned individuals, entities, regions or countries.
- We prohibit any relationship with terrorist organizations and organized criminal groups and take a firm stance against any demands from such parties.
My Commitment
- I comply with applicable internal rules regarding export controls, sanctions, and customs clearance.
- I confirm that the products, destination and end-use are not prohibited or subject to restrictions under applicable import and export related laws and regulations.
- I conduct the required screenings of direct and indirect business partners before starting business and if I find any parties subject to restrictions or sanctions, I consult with the legal and compliance team.
- I comply with applicable internal rules to block interaction with organized criminal groups.
- If I become aware of any potential violation of export controls, sanctions or customs laws at Panasonic or by any customs brokers or freight forwarders acting as our agent, I will report my concerns promptly. (See also Reporting or raising concerns)
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