Panasonic Global Compliance Hotline
Frequently Asked Questions

About the Panasonic Global Compliance Hotline and the NAVEX System

What is the Panasonic Global Compliance Hotline?
The Panasonic Global Compliance Hotline is one of many channels for employees to speak up. Depending on the country where you are based, you can ask questions, seek help, and/or report potential violations of laws, regulations, our Code of Ethics & Compliance, or company policies.
What is the NAVEX System?
Panasonic has partnered with NAVEX to provide the Panasonic Global Compliance Hotline. The NAVEX System is a comprehensive reporting tool that provides you with a way to report by either phone or internet.
Why do we have the Panasonic Global Compliance Hotline?
We cannot improve or correct problems, if we don't know they exist. When you first notice that something looks wrong, feels wrong, or sounds wrong, you must apply our Company's core values and quickly report it. The Panasonic Global Compliance Hotline is one of many channels that employees or impacted stakeholders can use to make a report.

Reporting — General

May I report using either the Internet or the phone?
Yes, the Panasonic Global Compliance Hotline uses the NAVEX system to provide you with a way to file a report either by phone or on the Internet.
What type of situations should I report?

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.

Can I report issues also related to non-compliance by Panasonic business partners, such as suppliers or vendors?

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.

If I see a violation, shouldn't I just report it to my manager or human resources and let them deal with it?
When you first notice that something looks wrong, feels wrong, or sounds wrong, you must apply our Company's core values and quickly report it. You have many official channels for speaking up. You can go to our manager; the next higher manager; the HR Department; the Legal or Compliance Department. When you are not comfortable reporting an issue through these other channels, you also have the Panasonic Global Compliance Hotline.
Does management really want me to report?
We cannot improve or correct problems, if we don't know they exist. We need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on Panasonic and our people.
EU/EEA: information on external reporting possibilities?
For matters covered by the EU Whistleblowing Directive and national implementation laws, Reporters also have the possibility to make external reports to appointed local authorities. You can find a list of the competent authorities who can receive whistleblowing reports here.

PANASONIC RULES FOR HANDLING REPORTS

Does Panasonic have rules in place for handling reports?
Yes, all Panasonic companies have to follow internal rules of procedure as described here. All reports will be handled in line with this, as well as respecting all applicable laws.
Where do these reports go?

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.

Will I be protected if I make a 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.

How will reports be followed up?

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.

Will I receive any feedback on my report?
Yes, you will receive an initial confirmation that your complaint has been received. In some cases we may also contact you with follow-up questions or to discuss your report.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every website my PC connects with; won't this log identify me as a report originator?

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.

Can I file a report from home and remain anonymous?
A report from home, a neighbor's computer, or any Internet portal will remain secure and anonymous, where permitted by local laws. An Internet portal never identifies a visitor by screen name and the NAVEX system strips away identifying information, such as an IP address, so that anonymity is maintained. Plus, NAVEX is contractually committed not to pursue a reporter's identity.
What if I am concerned that the information I provide to the Panasonic Global Compliance Hotline will ultimately reveal my identity.

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.

What if I want to be identified with my report?
There is a section in the report where you may identify yourself, if you wish. Providing this information may help us thoroughly investigate the report.

Tips & Best Practices

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?
When you first notice that something looks wrong, feels wrong, or sounds wrong, you must apply our Company's core values and quickly report it. One only has to consider what happened in recent corporate scandals to see the disastrous effects a seemingly harmless lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, quickly report it.
I am not sure if what I have observed or heard is a violation of company policy or involves unethical conduct, but it just does not look right to me. What should I do?
You should report this in good faith through one of the channels available to you. We would rather you report a situation that turns out to be harmless than let possibly unethical behavior go uninvestigated.
What if my boss or other managers are involved in a violation? Won't they get the report and start a cover-up?

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.

What if I remember something important about the incident after I file the report?
When you file a report with the Panasonic Global Compliance Hotline, either using the NAVEX System's Internet or phone system, you are given a unique report key and are asked to select a password. With this report key and password, you can return to the Hotline again, either by Internet or phone, and access the original report. At that point, you can add more details.
What if you have questions for me concerning my report?
The Panasonic Global Compliance Hotline uses the NAVEX system which provides functionality to enable Panasonic representatives to post questions to you, even if you report anonymously. When you receive your report key, you will be provided with the amount of time we expect for the report to be processed. When that time has passed, we strongly suggest you use the report key and password to return to the Hotline either by internet or phone to see if any questions have been posted. If we need additional information and receive no replies to our questions, we may have to abandon the investigation.
What should I do if the telephone number is not working?
If the telephone number listed above is not functioning, please make your report online through this web site. Please indicate in the report that the telephone number did not work.
What should I do if the country I am in is not listed above?
If there is no service for your location, please make your report online through this web site. Please indicate in the report that dialing instructions were not available for the country you are located in.