Business Ethics

As our business expands globally, directors and employees must
always have accurate knowledge and high ethical standards to prevent
intentional misconduct and crimes, as well as the various scandals
that could arise due to insufficient knowledge or awareness on the part

Policyof those involved. Simultaneously, companies must clarify policies,

Responsible Executive andFramework

under a sound corporate culture that remains cognizant of the risks

establish regulations and systems, and conduct business activities
found in the external environment, their businesses’ nature, and local
characteristics.

Internal Communication andTraining

our stakeholders, as we conduct business as a “public entity of society”

Whistleblowing Systemessential that we do not violate laws and regulations or social norms, as

Performance Evaluation
Compliance Programs
Compliance Risk
Assessments
Ensuring Transparency of
Political Contribution Funds
Trade ComplianceTax Policy

We must operate the Company properly and fulfill our responsibilities towith the management resources it has entrusted to us. We believe it
we always think about what is right for society and act with integrity andfair play without indulging our self-interests.
With Panasonic Group’s involvement in a wide range of businessglobally, we recognize our constant exposure to noncompliancerisks and promote fair business practices in all countries and regions
worldwide. That means we respect free and fair competition even when
it is fiercest and will not engage in bribery or corruption with government
officials or business partners. Thus, we have established the PanasonicGroup Code of Ethics & Compliance and various internal compliancerules and regulations. Moreover, we are implementing multiple initiatives
to ensure that every single director and employee performs their duties
with high ethical standards and appropriate knowledge.

PolicyOn April 1, 2022, after revisiting the purpose and positioning of thePanasonic Code of Conduct in the context of the environment bothwithin the Group and outside it, and after revising our Basic Business
Philosophy, we arrived at a new version of our code of conduct, now
titled the Panasonic Group Code of Ethics & Compliance (Code of
Ethics & Compliance). This Code encapsulates our revised BasicBusiness Philosophy and defines the commitments to be fulfilled byeach company and every employee within the Panasonic Group as they
carry out the Group’s business. It has been translated into 22 languages
to ensure that it is understood by employees everywhere.

Sustainability Data Book 2023 137

Business Ethics

PolicyResponsible Executive andFramework
Internal Communication andTraining
Whistleblowing System
Performance Evaluation
Compliance Programs
Compliance Risk
Assessments
Ensuring Transparency of
Political Contribution Funds
Trade ComplianceTax Policy

The Board of Directors of Panasonic Holdings Corporation

Group GC and the CLOs of each company regularly reporteducational materials, including e-Learning, on the Code(PHD) revises the established Code of Ethics & Complianceon compliance at the Board of Directors meetings of PHD

of Ethics & Compliance that all employees are required toand informs all Panasonic Group companies of its updates.

and each Operating Company and receive appropriate

follow, as well as on other compliance-related materials

The Code then takes effect by resolution of each company’s

supervision from these Boards.

Board of Directors or other appropriate internal procedures.

We also include compliance-related metrics in the

WEB Panasonic Group Code of Ethics & Compliancecompensation calculations for PHD’s Executive Officers andhttps://holdings.panasonic/global/corporate/about/code-of-conduct.html

Operating Company CEOs.

throughout the year. In fiscal 2023, we trained all Group
employees on the Code of Ethics & Compliance. (See“Compliance Program” below for the results of the training.)
Additionally, each Operating Company and PEX overseas
office conducts compliance-related training for those who

Responsible Executive andFramework

Internal Communication and Training

need it, according to the risks relevant to their businesses

Panasonic Group fosters a compliance-first culture by

and regional characteristics. The Panasonic Group carries

Panasonic Group’s General Counsel (GC), an Executive

regularly disseminating compliance-related messages fromout programs throughout the year, aiming to instill a global

Officer, is responsible for group compliance (as of

the Group CEO, each Operating Company’s CEO, and allawareness of ethical and legal compliance while also

August 2023). As of April 1, 2022, the GC established thebusiness site general managers.

boosting its ability to respond to risks. In recent years, asGroup Basic Compliance Regulations to clarify roles andresponsibilities related to compliance in Panasonic Group,
while the Group Legal Regulations define the legal structureand functions.

Moreover, the CLOs and legal departments assigned toOperating Companies or to overseas companies by PEX,
officers responsible for observance of the Code of Ethics& Compliance, export control officers, and the heads ofour business environment and practices have evolved, we
have strengthened efforts to accurately identify changes inrisks within specific business areas, divisions, countries, andregions, as well as to identify early signs of misconduct andlegal violations.

Under the Group management system based on anfunctional departments implement specific compliance

Operating Company System, PHD is responsible for

initiatives at each business site.

Whistleblowing System

The Group’s legal departments, which play a leading role

Panasonic Group has established a Global Hotline, aestablishing a Groupwide compliance system, with theGroup GC and PHD Legal Department playing criticalroles under the Group CEO’s supervision. Each Operating
Company is responsible for establishing and implementing
a compliance system for its business area based on theprinciples of Autonomous Responsibility Management, with
the Operating Company CEO, Chief Legal Officer (CLO), andlegal department mirroring their PHD counterparts’ roles.

in these efforts, have their legal staff from around the world

Groupwide integrated reporting mechanism that accepts

attend the Global Legal & Compliance Meeting, and thereports from domestic and overseas sites and from business

CLOs from Operating Companies, PEX overseas offices, andpartners to prevent misconduct and facilitate rapid resolutions

the PHD Legal Department attend the Direct Report Meeting

to a wide range of compliance issues in 32 languages,

chaired by the Group GC. Through these and other meetings,

24 hours a day, 365 days a year. The Code of Ethics &the Group’s legal departments learn about annual updates toCompliance includes information on the Hotline along with

the Group’s compliance policies and work toward achieving

the responsibility for reporting. We raise awareness of thecompliance in various areas.

system through various compliance training sessions andand legal departments for each overseas office (formerly,

Moreover, whenever a legal revision, government ordinance,

posters at domestic and overseas workplaces and businessregional headquarters). These officers and departments

or government directive is relevant to the Group’s business,

Furthermore, for overseas Group companies, PanasonicOperational Excellence Co., Ltd. (PEX) assigns the CLOs

are responsible for ensuring compliance in their respective

we notify and communicate it to the business site general

regions. Each CLO plays their role in the business and region

managers, Operating Company CLOs, and relevant

under the Group GC, working as one legal team to ensureorganizations.

compliance.
Additionally, we have established a system whereby thePanasonic provides training and awareness building for newhires and newly promoted employees, through a variety ofsites and post information to the Company intranet—
including reporting statistics, case studies, how to use thereporting system, FAQs on reporting, and appreciative
feedback from whistleblowers—to ensure transparency on
the reporting system’s operations and encourage employees
to use it. In addition, we also ask our business partners to
inform their employees about our reporting system in our

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Business Ethics

CSR Promotion Guidelines for Suppliers and provide a link tomanagement. In fiscal 2023, in response to the revised

the URL of the reporting site on our supplier communication

Whistleblower Protection Act in Japan (effective June 1,

website to promote their use of the system.

2022), we updated our Internal Reporting and Investigation

The Global Hotline website clearly states the necessary

Policyprocedures for reporting issues, how personal data and other

Responsible Executive andFrameworklies. The website additionally allows whistleblowers to check

Internal Communication andTraining
Whistleblowing System
Performance Evaluation
Compliance Programs
Compliance Risk
Assessments

information collected is managed, and where responsibility
the progress of each case at any time using a reporting key
and password assigned to their submission.
Moreover, employees have other methods for reportingor making grievances. We have an Equal Employment
Opportunity Office in Japan that provides consultation on
fair treatment in the workplace, sexual harassment, andpower harassment, as well as an Auditor Reporting System
for assessing the legality of duty execution and investigating
fraud perpetrated by directors and executive officers.
Establishing the above hotlines and contact points does notpreclude employees from using other reporting and grievancemechanisms.

Rules on April 1, 2022, further defining the whistleblowing andinvestigation system and related responsibilities and runninga Groupwide awareness campaign to improve the system.
We will continue to review the reporting system appropriately
in light of the internal and external environment and issues.
In FY2023, we received approximately 890 reports andrequests for consultation, with 75% of those coming throughMarketing Japan Co., Ltd.; “PCMC”) was installing air
conditioners, TV antennas, and other household appliancesof May 31, 2023). Furthermore, all reports and consultations

under contract with Panasonic’s local home appliance

we receive through the Global Hotline are investigated instores. However, it was found to have failed to assign

cooperation with the relevant departments in accordance

chief engineers to jobs as business operators licensed

with internal rules, and we address issues, preventto perform construction work, among other violations.

recurrence, and handle confirmed cases as necessary.

Health and safety 3%

whistleblowers is strictly forbidden, and their confidentiality

Accounting / Auditing

Tax Policy

is assured through anonymous reporting. To clarify ourContent (FY2023)

regulations, including the non-assignment of chief engineers

Asset misuse andappropriation 1%

4%

for more than 20,000 construction projects. The causesof the violations included insufficient understanding of theConstruction Industry Act, an attitude that trivialized theviolations, and inadequate internal controls. The violations
then continued due to Panasonic’s erroneous assumptions

Prohibition of Retaliatory Behavior Against Whistleblowers

Business
Integrity*

27%

regarding appliance store activities and insufficient or
diminished awareness of the problems among those involved.

Workplaceissues65%

Based on the recommendations of the external investigationcommittee, the Group implemented measures such as
identifying and reaffirming compliance with the laws andregulations applicable to not only the construction industry

In addition, we have established the Internal Reporting andinvestigating, addressing, and reporting such issues to

An investigation by an external committee that began on
May 26, 2022, confirmed multiple violations of laws andstance, Panasonic Group has adopted Rules on theas the frameworks necessary for appropriately receiving,monitoring.

substantiated (excludes anything still under investigation as

good faith to raise a compliance concern.” Retaliation againstfor compliance issue reporting and notification, as wellthese items. The results of these audits are also subject toaudits by an outside auditing authority as part of Groupwide

Panasonic Consumer Marketing Co., Ltd. (now, PanasonicTrade Compliance

Investigation Rules, which stipulate and administer a system

obtained; and checks are made regarding the status of

workplaces (refer to the chart below). Of all the reports anddiscriminates against or disadvantages anyone who acts inoperations in our whistleblowing systems.

written pledges regarding the observance of the Code arerequests received in FY2023, approximately 29% were

does not tolerate any retaliation or other action thatinvestigations, and investigation teams, ensuring proper

Education and training are conducted regarding the Code;▪Serious Violations and Corrective
Measuresthe abovementioned global hotline. Of all the reports andEnsuring Transparency of
Political Contribution Funds

external whistleblowers, employees, those participating in

At each Group company, an executive officer is appointed
to ensure observance of the Code of Ethics & Compliance.

requests received, roughly 65% were related to issues in

The Code of Ethics & Compliance stipulates that “Panasonicand Others. The Rules prohibit retaliation against internal/

Performance Evaluation* Ethical behavior includes concerns related to violation of internal
regulations, Conflict of Interest, Bribery, Violation of Laws, Vendor/
Customer issues, Fraud, etc.

but also each of the Group’s businesses and strengthening
cooperation between the legal governance, legal, andinternal audit departments. Regarding those buildings whereconstruction work was managed by someone other than

Sustainability Data Book 2023 139

Business Ethics

a chief engineer, quality verification is being performed at
PCMC under the guidance of the investigation committee.
If Panasonic becomes aware of any serious violation oflaws or corporate regulations, we will cease the violation

Policyimmediately and, after sufficiently investigating facts andResponsible Executive andFramework

matters to the Board of Directors as necessary and consider

Internal Communication andTraining
Whistleblowing System
Performance Evaluation
Compliance Programs
Compliance Risk
Assessments

causes, consider countermeasures. We report on suchcountermeasures of the violation swiftly and across the entire
Group.

– approximately 140,000 in attendance
FY2022: “Economic Sanctions Law,” “Data Privacy” –approximately 130,000 in attendance
FY2023: Approximately 150,000 employees have taken
the Code of Ethics & Compliance course. (Weprovide separate offline training for employees
who cannot take the e-Learning course.)
We also publish a quarterly compliance newsletter for theheads of each business division.
• Global Hotline operations: As described in the

In the past three years, we had no violations subject to fines,

Whistleblowing Systems section above, we immediately

sanctions, or disciplinary actions against employees resulting

conduct internal investigations when potential violations

from anti-corruption violations.

are identified through hotline reporting, audits, andthe like. After confirming the facts surrounding illegal

Compliance Programs

activities through these internal investigations, PanasonicPanasonic Group is carrying out Groupwide compliance

immediately addresses the violations while analyzing

programs that implement measures for mitigating risks suchtheir root causes, implementing measures to preventas competition law violations, bribery, and corruption. In fiscal

recurrences, and taking disciplinary actions against

Basic Policies
We have established the following basic policies to prevent
cartels, collusive bidding, and other such violations:• Contact with competitors is allowed only in cases inwhich it is absolutely necessary, and it is subject to priorapproval.
• Agreements and exchanges of information withcompetitors regarding prices, quantities, and othercompetition-related matters are strictly prohibited.
• Anyone who encounters behaviors that may give rise tosuspicions of cartels must make an objection, leave theroom, and file an internal report.
• We have established a whistleblowing system and aninternal leniency system to improve our ability to selfregulate and conduct appropriate monitoring based on risk
assessment, thereby maintaining an effective anti-cartel
system.

2023, we put forward the following initiatives to strengthen

relevant parties.

our compliance infrastructure worldwide:• Strengthening our investigational function: On July

Rules Concerning Activity and Relationship with
Competitors• Executive-level participation: Each member of the

1,2019, we updated our Groupwide whistleblowing andIn 2008, we established the Rules Concerning Activity andmanagement team, consisting of the Group CEO,investigation systems with new global policies: Internal

Relationship with Competitors, which apply to all GroupOperating Company Presidents, and the business division

Reporting and Investigation Rules, and Rules on Prohibition

employees, for the purpose of preventing behaviors that

Trade Complianceheads, issued compliance memoranda to employees

of Retaliatory Behavior. (For details, see the section on

could lead to cartels or bid rigging, or raise suspicion of such

under their management. Moreover, the Board of Directors

Whistleblowing Systems.)

activities. These rules include items such as the following:

Tax Policy

and other management meetings regularly hear reports▪Preventing Cartels• Prohibition of agreements or exchanges of informationon compliance efforts and conduct discussions orinvestigations as necessary.

Panasonic Group takes extremely seriously the fact that our

specifications that may raise suspicions of cartels or bid• Compliance awareness and culture: We focused oncompany has been implicated in multiple international cartel

rigging

educating and informing all Global officers and employees

incidents. We are working to prevent any further association• Prior approval system under which contact with

about the Code of Ethics & Compliance, revised on April 1,

with cartelization activities. We take thorough and detailed carecompetitors requires the prior approval of the head of theto re-emphasize compliance. We also included questions

to prevent any such involvement, as it would have a variety

business group and the person in charge of legal affairs

about compliance awareness and culture in the Awarenessof negative impacts on our business. If Panasonic were to• Responses to inappropriate activities

Survey distributed to all employees worldwide. In FY2023,

become involved in the creation of a cartel, we would not only

• Duty of reporting possible violations

we received approximately 150,000 survey responses.

lose the trust of our customers but also be required to pay• Measures taken in response to violations• Training and awareness building: Panasonic offeredhuge amounts of penalties and compensation for damages,• Internal leniency system

Groupwide e-Learning on compliance worldwide.

and we could lose our designation in public procurement.

Ensuring Transparency of
Political Contribution Funds

regarding product pricing, quantities, performance, or

FY2021: “Conflict of Interests,” “Accounting Wrongdoing”

Sustainability Data Book 2023 140

Business Ethics▪Preventing Bribery and Corruption
In addition to preventing the bribery of public officials,

Any situation in which directors’ or employees’ personal

ethics. To strengthen the global prevention of bribery andCompliance Programs
Compliance Risk
Assessments
Ensuring Transparency of
Political Contribution Funds
Trade ComplianceTax Policy

assessment and risk mitigation for new transactions whilekind—regardless of whether they occur as entertainment, gifts,

Responsible Executive andFramework

Performance Evaluationin relation to public officials or business partners.

Rules on Conflicts of Interest

or in any other form—or receiving any personal benefits in any

Whistleblowing System

Anti-Bribery/Anti-Corruption. Specifically, we conduct risk

Panasonic Group, has prohibited offering benefits of any

PolicyInternal Communication andTraining

entertainment, including meals, hospitality, and travel costs,

situation in which these would be in violation of laws or social
corruption, on July 1, 2019, Panasonic adopted the following
four global regulations that now apply to all Panasonic Group
employees and executives.

Global Anti-Bribery / Anti-Corruption Policy
Adopted to effectively prevent, discover, investigate, andcorrect acts of actual corruption or acts deemed to becorrupt with regard to the bribery of public officials andinterests or outside activities interfere or appear to interfere,
directly or indirectly, with the interests of Panasonic Group, or
influence or appear to influence, in any way, the directors’ or
employees’ business decisions, actions, objectivity, loyalty, orability to perform their jobs are defined as “conflicts of interest”
in these rules. In addition to the rules regarding prevention,

A Clean Procurement Declaration was also released
in 2004 in procurement divisions. Its aim is to build
healthy relationships with business partners to makesure transactions are fair. Panasonic then conducts its
procurement following its Declaration. For more details, referto the chapter “Responsible Supply Chain” (P102).

specific examples of actual or potential conduct that may

Panasonic Group has established the “Guidelines for Anti-create conflicts of interest.

Bribery and Anti-Corruption (For Business Partners)” that

Furthermore, to reduce the risk of indirect bribery and corrupt

Panasonic Group’s business partners are required topractices, we have introduced a risk due diligence tool andSpecifically, the Policy defines and prohibits facilitationintermediaries and outsourcing partners in accordance within connection with political contributions, donations, orrisk-level-based cycle.

identification, management, and correction, the rules also offer

corruption related to business partners.

payments and acts considered to be bribery or corruption

also conducting periodic risk assessments and reviewing risk
mitigation measures for existing business partners using arisk screening process we use for transactions with sales

follow, with regard to compliance with anti-corruption laws,
which prevent bribery, corruption, or other improprieties inconnection with Panasonic Group business.

Rules on Third-Party Intermediary Risk Management forsponsorships; lobbying; hiring and recruitment; and mergers,
acquisitions, and joint ventures. The Policy also specifies

For Business Partners <Regarding Anti-Bribery and Anti-Corruption>

procedures for preventing bribery and corruption.

Panasonic Group is committed to preventing bribery and corruption in its global operations. (For details, refer to “Preventing

Rules on Third-Party Intermediary Risk Management
for Anti-Bribery / Anti- Corruption
These rules are meant to mitigate the risks of bribery andother forms of corruption regarding sales intermediaries orBribery and Corruption” above.)
Panasonic Group has established the “Guidelines for Anti-Bribery and Anti-Corruption (For Business Partners),” which explain
Panasonic Group’s expectation that business partners will comply with all anti-corruption laws and will not engage in bribery,corruption, or other improprieties in connection with Panasonic Group’s business.

administrative service providers, and to prevent, discover,

The cooperation of Panasonic Group’s business partners is essential to the success of Panasonic’s compliance with anti-corruption

investigate, and correct actual or potential problems related

laws. We ask that all our business partners take the time to thoroughly understand these Guidelines and put them into practice.

to these risks. They define the basic rules for screening these

PDF

business partners.

https://holdings.panasonic/jp/corporate/sustainability/pdf/Guideline%20of%20Anti-bribery%20and%20Anti-Corruption_jp.pdf

Rules on Gifts and Hospitality for Anti-Bribery /Anti-Corruption
These rules describe prohibited conduct and specificprocedures to prevent the risks of bribery and corruption.

PDF“Guidelines for Anti-Bribery and Anti-Corruption (For Business Partners)” – JAPANESE (PDF file)“Guidelines for Anti-Bribery and Anti-Corruption (For Business Partners)” – ENGLISH (PDF file)https://holdings.panasonic/jp/corporate/sustainability/pdf/Guideline%20of%20Anti-bribery%20and%20Anti-Corruption_en.pdf
PDF“Guidelines for Anti-Bribery and Anti-Corruption (For Business Partners)” – CHINESE (PDF file)https://holdings.panasonic/jp/corporate/sustainability/pdf/Guideline%20of%20Anti-bribery%20and%20Anti-Corruption_cn.pdf

These risks involve the provision or receipt of gifts or

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Business Ethics

Compliance Risk Assessments
The Panasonic Group annually selects business sites forcompliance audits based on bribery and corruption risks.

fairness and transparency by requiring that specific lobbying

The Group contributes to the development of society and theactivities must not be reasonably perceived as inappropriate,

resolution of issues through its business activities by paying

by Transparency International, an international NGO—isunethical, or corrupt.

its fair share of taxes in communities where we operate andTrade Compliancein accordance with the tax laws of each country and other

The Group has also stipulated global trade compliance rules

as the OECD. See below for details.

low, our Compliance Auditing divisions conduct audits on arotating basis.

Ensuring Transparency of PoliticalContribution Funds

in the Code of Ethics & Compliance. We also have Rules

Panasonic Group makes political donations as a part of

to ensure compliance with each country’s trade-related

its corporate social responsibilities. It abides by the Japan
Business Federation’s policy which states that: “Costs

Compliance Risk
Assessments

maintaining democratic politics. Political donations

Trade ComplianceTax Policy

promote participation in the AEO framework in China.

Bribery / Anti-Corruption Policy defines lobbying and requires

where the Corruption Perceptions Index—published annuallyCompliance Programs

Ensuring Transparency of
Political Contribution Funds

Partnership Against Terrorism (C-TPAT), while we actively

connection with policy recommendations, our Global Anti-risks, such as those doing business in countries or regions

Responsible Executive andFramework

Performance Evaluation

public policy through industry associations. For lobbying in

Tax Policy

For any business sites where we anticipate having higher

Whistleblowing System

Panasonic North America takes part in the Customs-Tradecompliance with relevant laws and regulations, and ensures

PolicyInternal Communication andTraining

As a general rule, we encourage the development ofcommensurate with the task are essential to properly
by companies are a crucial part of companies’ social
responsibilities.”
When making donations, we comply with the Political Funds
Control Act and all other relevant legislation, as well as
strict internal rules including the abovementioned global
Groupwide rules for preventing bribery and corruption andprohibits any conduct that could lead to suspicion of briberyon the part of public employees or that amount to corrupt
practices. We also have regulations in place concerning
political contributions, including the reporting and confirming
by multiple responsible executives, such as the executive
officers in charge of Government and External Relations,
Accounting(CFO), and HR & GA(CHRO), and obtaining
agreement and approval.
Political donations in FY2022: JPY 28.5 million (onedonation in Japan)* The amount of the one FY2023 political donation in Japan will be
disclosed by the Ministry of Internal Affairs and Communications(Japan) in November 2023.

on Global Trade Restrictions & Sanction Law Compliancetax guidelines published by international organizations such
WEB Panasonic Group Tax Policy
https://holdings.panasonic/global/corporate/sustainability/
governance/fair-practices/tax_policy.html

regulations, including security export controls and sanctions
laws. Moreover, we set standards meant to help us maintainand improve corporate value through the fulfillment of oursocial responsibility by respecting and following not only
laws but also business ethics in our execution of logistics
work in the Logistics Operating Standards and Customs Law
Compliance Standards. Through these efforts, we ensure
trade compliance, including adherence to import/export
regulations and trade-related laws and regulations in all
countries.
In Japan, the Authorized Economic Operator (AEO) systemprovides simpler, expedited customs procedures for business
operators that have established cargo security management
and legal compliance frameworks. Panasonic Operational
Excellence Co., Ltd. has received customs administration
certification as “Authorized Exporter” in the AEO system. We
strive to ensure the safety of our international logistics byselecting companies that provide physical, personnel, andinformation security, not only for our own operations but also
for those of our contractors.
At a global level, we promote our participation in AEO
frameworks in all regions. For instance, our US subsidiary

Sustainability Data Book 2023 142