You should report any potential violation of law, regulations, our Code of Ethics & Compliance, or company policy – though this may depend on the country where you are based.
Once you have chosen your region and country, you will be given a list of matters that can be reported.
If your concern pertains to a matter that under local law, may not be accepted by Panasonic through the Hotline, you will need to use any of the other reporting channels made available to you, such as your supervisor or local management or a representative of the Human Resources, Legal or Corporate Compliance Departments or to the Compliance team in Panasonic’s Headquarter in your region.
Some EU/EEA entities may also have local Hotlines, you will find more information on your Company’s Intranet.
Panasonic is committed to secure that also our suppliers and vendors comply with applicable law, regulations and social standards, including (i) to take due consideration of (a) the environment, (b) human rights and (iii) health and safety of their personnel and of their suppliers’ personnel and (ii) to maintain the confidentiality of important information.
We have established Supply Chain CSR Promotion Guidelines and require our suppliers to comply with these Guidelines. This includes an obligation for suppliers to make their employees aware of the possibility of reporting possible violations to the Panasonic Global Compliance Hotline.
If you have information that one of Panasonic’s business partners (including any suppliers or vendors in our supply chain) are not complying with applicable law, our Supply Chain CSR Promotion Guidelines or other standards, you can submit a complaint via the Global Compliance Hotline. You can also make a report to the relevant business partner directly or to any joint initiatives Panasonic is a member of such as JaCer. Where you do not know how a supplier is related to Panasonic or the supplier is working with multiple manufacturers, this will likely lead to a quicker investigation and resolution of the case.
Reports on the Panasonic Global Compliance Hotline are entered directly to a NAVEX secure server to prevent any possible breach in security. NAVEX makes these reports available only to specific individuals within Panasonic who are charged with evaluating the report, based on the type of violation and location of the incident.
Once the report has been examined, it may be followed up directly or forwarded to another responsible department for further investigation. Each of these report recipients, as well as any other employee or person subsequently tasked with following up your report, are impartial, subject to specific confidentiality obligations and have the necessary training to professionally and confidentially handle reports. Employees who may have a conflict of interest in the report or follow-up shall be excluded from follow-up of reports.
External advisors may be brought in to assist with the follow-up as relevant.
The company may contact you with follow-up questions or to discuss your report.
Panasonic does not tolerate retaliation of any kind. Anybody who makes a report in good faith, i.e. in the belief that the facts reported are correct even if later they turn out not to be true, will be fully protected against retaliation.
Where you have disclosed your identity in the report, we will only disclose this on a strict need to know basis and as permitted by law.
In some regions, Panasonic may have a legal obligation to notify any person who is the subject of a report to EARS, except where notice needs to be delayed to ensure the integrity of the investigation and preservation of relevant information. More generally, Panasonic will follow up reports in an impartial way and will, where necessary, also hear the employees implicated by a complaint or report.
All reports are taken seriously and will be assessed to see if there is sufficient information to follow-up the matter. In some case, it may not be possible to follow-up the report without additional information. If such additional information is not received from the Reporter, we may have no choice but to abandon the investigation, in particular if we cannot specify the subject of an investigation and where it is too difficult to investigate a report. The Reporter will be informed should this be the case.
The individuals tasked with following up the reports, may conduct additional fact-finding through reviewing relevant documents, speaking with witnesses and affected parties and, if necessary, analysing data or documents (whether electronic or physical data). Any fact-finding shall be conducted in an impartial and un-biased manner, in full compliance with applicable law and internal procedures and respecting any rights of employee representatives or work councils.
Following the fact-finding, the results will be summarised in a report, which also may include recommendations for further follow-up, consideration of disciplinary sanctions or remedial measures. The reports will be shared with the necessary stakeholders in Panasonic.
The identity of the Reporter will be protected at all stages of handling a Report and any follow-up.
The Panasonic Global Compliance Hotline uses the NAVEX system. The NAVEX system does not generate or maintain any internal connection logs with IP addresses; no information linking your PC to the NAVEX system is available. In fact, NAVEX is contractually committed not to pursue a reporter's identity.
If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café, the library, at a friend's house, etc.) through the Panasonic Global Compliance Hotline NAVEX secure website. Many people choose this option, as NAVEX's data shows that fewer than 12% of reports generated during business hours.
Every reasonable precaution, consistent with the needs of conducting a thorough and fair investigation, is taken to keep your identity confidential.
In addition, it is possible to report anonymously through the Panasonic Global Compliance Hotline except where legally restricted from doing so. The Panasonic Global Compliance Hotline uses the NAVEX system which is designed to protect you. In fact, NAVEX is contractually committed not to pursue a reporter's identity. To further ensure your anonymity, you—as a reporting party—need to be careful not reveal any identifying details as part of your report. For example, "from my cube next to Jan Smith…" or "in my 33 years…"
Finally, Panasonic supports all employees in raising issues or concerns in good faith and is committed to maintaining a retaliation-free workplace. Anyone who violates that trust and retaliates will face disciplinary action.
The Panasonic Global Compliance Hotline uses the NAVEX system. This system and report distribution protocols are designed so that the implicated parties are not notified about or granted access to reports in which they have been named.
Panasonic has a strict no-retaliation policy and will protect your identity, see also above.