Data protection and privacy policy

Use of EARS is entirely voluntary.

You are encouraged to report possible violations directly to your supervisor or manager, or to a representative of the Human Resources, Legal Departments, relevant functional teams, or other local channels, depending on the nature of the possible violation. Please see the information made available to employees through regional or local Intranets or similar channels, as well as under Q9 below.

You can also use this service to make your report.

This service is a confidential reporting system that allows you to report suspected violations of law or company policies, as well as other concerns you may have, to PAS Group. Reports may be accepted for any violation of law, regulations, or internal policies.

In certain countries, applicable legislation only allows PAS Group to accept reports through EARS that relate to certain matters, such as financial, accounting, auditing, bribery, competition law, discrimination and harassment, environment, health, hygiene, and safety matters, and other suspected serious misconduct. Purely private matters should not be reported through EARS.

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 PAS Group through EARS, you will need to contact any of the other channels for reporting available to you as described above and also in Q9 below.

Please be aware that the information you supply about yourself, your colleagues, or any aspect of the company’s operations may result in decisions that affect others. Therefore, we ask that you only provide information that you believe is true. You will not be subject to retaliation or any disadvantageous treatment from PAS Group for any report of a suspected violation that is made in good faith, even if it later turns out to be factually incorrect. Please be aware, however, that knowingly providing false or misleading information may result in disciplinary action and will not be tolerated.

EARS can be used to report all issues connected with work at the PAS Group as relates to all employees, directors/officers, vendors, suppliers and business partners of the PAS Group.

In some countries, the categories of persons who can be reported may be limited to persons in key positions or managerial roles in a company. Should this be the case, you will need to contact any of the other channels for reporting available to you as described above and also in Q9 below.

EARS captures the following personal data and information that you provide when you make a report:

1. your name and contact details (unless you report anonymously) and whether you are employed by PAS Group;
2. the name and other personal data of the people you name in your report if you provide such information (i.e., description of functions and contact details);
3. a description of the alleged misconduct as well as a description of the circumstances of the incident; and
4. your location and the location where the alleged misconduct took place so that any applicable local laws can be applied in gathering information and undertaking any investigation.

We encourage you to identify yourself so we can follow up with any questions we may have. Anonymous reports will be accepted in accordance with applicable law. We respect the confidentiality of whistleblower reports and will maintain confidentiality to the fullest extent permitted by law. The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or in order to conduct an investigation, in which case the information will be handled sensitively.

Unless strictly necessary to make a report, please do not share any sensitive personal data through EARS, such as data regarding racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning health, genetic information, biometric information, or data concerning a natural person’s sex life or sexual orientation. Processing such sensitive personal data requires special handling and, when included in a report, will be processed only to the extent necessary for the investigation. For individuals in the United States, California and other states provide additional protections for sensitive personal information, including the right to limit its use and disclosure.

PAS, along with your employing company, either solely or jointly with other companies within the PAS Group, are responsible for the personal data collected. For EU, EEA and UK, the PAS Group operate the whistleblower system as joint controllers in accordance with Art. 26 EU General Data Protection Regulation (GDPR) and United Kingdom General Data Protection Regulation (UK GDPR). For individuals in the United States, any service providers processing your information on our behalf are contractually obligated to implement appropriate safeguards and comply with applicable privacy laws, including requirements for cross-border data transfers where applicable.

Further information can be obtained from the relevant contact in your region, see Q9 below, or region-specific information about EARS made available to employees through regional or local Intranets or similar.

PAS Group will process the above personal data for the purposes of ensuring compliance with applicable legislation and internal policies, managing PAS Group’s own defense in case of legal claims and ensuring the well-being of personnel of the PAS Group. This data will be processed on the basis of our need to comply with our legal obligations, including an obligation to maintain whistleblower hotlines, and our legitimate interest to investigate reports of alleged misconduct and infringements of laws and internal policies to enable PAS Group to pursue the above purposes as well as to comply with any legal obligation to which PAS Group is subject. For individuals in the United States, we will not use your personal information for purposes materially different from those disclosed at collection without providing notice and, where required by applicable law, obtaining your consent.

For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used on a need-to-know basis by the relevant personnel of PAS Group, including Human Resources, Finance, Internal Audit, Legal, management, and external advisors (e.g. legal advisors). Those individuals may be located in Japan, the United States, the United Kingdom, Europe or elsewhere. If you are based in Europe, information will be shared only with personnel in Europe and Japan. In addition, information may be processed in limited circumstances by technical staff at NAVEX on behalf of PAS Group for administrative services and, for translation purposes, by translators/interpreters at NAVEX, its subsidiaries, including NAVEX’s call center in Portugal, or subcontractors. Those staff may be in the United States, the United Kingdom, in the EU/EEA or elsewhere. For individuals in the United States, you have the right to know the specific categories of third parties to whom we have disclosed your personal information in the preceding 12 months, and the right to opt-out of the sale or sharing of personal information, although we do not sell personal information collected.

The personal data and information you provide in the report will be stored in a database located on servers hosted in Germany and Netherlands and operated by NAVEX UK Limited with its principal place of business in the United Kingdom, a subsidiary of NAVEX. NAVEX has entered into contractual commitments with PAS to secure the information you provide in accordance with applicable law. NAVEX is committed to maintaining stringent privacy and security practices including those related to notice, choice, onward transfer, security, data integrity, access, and enforcement. All subcontractors used by NAVEX to provide the Hotline must be pre-approved by PAS and NAVEX must impose equally stringent privacy and security measures on its subcontractors.

Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities in accordance with applicable law. The relevant bodies that receive and process personal data may be located in the US or another country that may not provide the same level of data protection as the EU. For individuals in the United States, where we make such disclosures, we will implement appropriate safeguards as required by applicable law.

Where we transfer your personal data outside the country in which you are based, we will ensure that suitable safeguards are put in place to ensure that the recipients provide an adequate level of protection to your personal data in accordance with applicable law.

You may request additional information on this matter and obtain a copy of the relevant safeguards in place by sending a request to the relevant contact for your region, see Q9 below.

The personal data you provide will be kept as long as necessary to process your report, or, if applicable, as long as necessary to initiate sanctions, until the reported offences (if any) are time-barred or to meet our legal, judicial or financial needs. We will not retain your personal data for longer than necessary for the purposes for which it was collected, and in accordance with specific retention periods set by applicable legal requirements and internal policies.

Your report will be kept confidential and shared only as necessary for proper follow-up or to comply with local laws.

In some regions, PAS Group may have a legal obligation to notify any person who is the subject of a report to EARS, except where notice must be delayed to ensure the integrity of the investigation and the preservation of relevant information.

With some exceptions, the subject of the report may, also in some regions, access information concerning the report and request correction of personal data that is inaccurate or incomplete in accordance with applicable law. If the subject of the report is given access in accordance with applicable law, PAS Group will not disclose your identity (if you have provided it) unless required by local law.

PAS Group will not tolerate retaliation by any PAS Group employee against persons who make a report of a suspected violation in good faith. Employees who attempt retaliation will be subject to disciplinary action, up to and including dismissal.

Similarly, with some exceptions, Reporters may also access information about the report and request corrections of their personal data subject to the conditions and limitations set out in the applicable law.

Further information can be obtained from the relevant contact for your region, see Q9 below.

If you are based in Europe, your rights under the General Data Protection Regulation (“GDPR”) or other applicable data protection legislation include the right to access your personal data and obtain a copy thereof, the right to request the correction or update of any inaccurate personal data and the right to object to or restrict the processing of your personal data under the conditions set out in the GDPR. You also have the right to request the erasure of your personal data under certain conditions. In addition, you also have the right to data portability in certain cases. This is the right to request the return of the personal data you have provided to us in a structured, commonly used and machine-readable format and to request its transmission to a third party, where technically feasible, without hindrance from us and subject to your own confidentiality obligations.

If you wish to exercise any of the above rights, you may contact us at:

Our EU Representative:
Panasonic Europe B.V. Zweigniederlassung Deutschland Wiesbaden Office
Hagenauer Strasse 43, 65203 Wiesbaden, Germany
e-mail: Data_Protection@eu.panasonic.com

Our UK Representative:
Panasonic Europe B.V. (UK branch)
UK Legal department
Maxis 2, Western Road,
Bracknell, Berkshire,
RG 12 1RT
UK
e-mail: Data_Protection@eu.panasonic.com

You can also contact the PAS Group entity you are or were employed with or are doing business with.

We will respond to your request without undue delay, and no later than one month from receipt of the request, unless a longer period is permitted under applicable data protection laws.

In addition to your rights outlined above, you may raise issues with your local data protection officer (if any) if you are not satisfied with how we process your Personal Data. Please refer to your company’s privacy notice for details of the local data protection officer (if there is one) and your local data privacy authority. Alternatively, we will provide you with the contact details, where applicable, immediately upon request by contacting at our EU or UK Representative above.

You may also file a complaint with the competent supervisory authority:

• EEA/EU authorities: Members | European Data Protection Board (europa.eu)

United Kingdom (UK): Make a complaint | ICO

Further information can be obtained from the relevant contact for your region, see Q9 below.

You may contact us with any questions relating to this policy or this service, or to exercise your privacy rights.

Global contact:

PAS Cross-functional Team, Panasonic Automotive Systems Co., Ltd.
e-mail: am_compliance_issue@ml.jp.panasonic.com

US contact:

PASA toll-free telephone number: +1-844-607-0068
PASA e-mail: PASA.Privacy@panasonicautomotive.com

For inquiries related to this policy, those based in Europe may contact our EU or UK representative.

Our EU Representative:

Panasonic Europe B.V. Zweigniederlassung Deutschland Wiesbaden Office
Hagenauer Strasse 43, 65203 Wiesbaden, Germany
e-mail: Data_Protection@eu.panasonic.com

Our UK Representative:
Panasonic Europe B.V. (UK branch)
UK Legal department
Maxis 2, Western Road,
Bracknell, Berkshire,
RG 12 1RT
UK
e-mail: Data_Protection@eu.panasonic.com

In accordance with the Act on the Protection of Personal Information in Japan, the following items are disclosed. PAS may, jointly with specific parties, utilise the personal information of the Reporter and that of any person related to a report in accordance with the following conditions.

1. Scope of the joint users: The PAS Group
2. Purpose of joint use of parties: Review and investigation of the report
3. Items of personal information used jointly: The Reporter’s name, telephone number, etc., personal information contained in the report, and other personal information necessary to achieve (ii) above
4. The name of the individuals or business operators for the control of personal information to be used jointly: 4261 Ikonobe-cho, Tsuzuki-ku, Yokohama City, Kanagawa 224-8520, Japan Panasonic Automotive Systems Co., Ltd. Representative Hisayoshi Nakao

For individuals in the United States, as applicable under the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and the privacy laws of other states, your rights include:

(1) Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share information;

(2) Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions;

(3) Right to Correct: You may request correction of inaccurate personal information;

(4) Right to Opt-Out: You may opt-out of the sale or sharing of your personal information;

(5) Right to Limit Use of Sensitive Personal Information: You may limit our use of sensitive personal information to purposes necessary to perform services or provide goods reasonably expected;

(6) Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights. To exercise these rights, please contact us using the methods for the Global Contact as specified above.

For requests from individuals in the United States, we will respond within 45 days of receipt, with a possible extension of up to 45 additional days where reasonably necessary, as permitted by applicable state privacy laws.

By submitting this report, you acknowledge that we will process your personal information as described in this policy. However, you retain all rights under applicable law, including the right to request access to, deletion of, or correction of your personal information, subject to applicable legal exceptions for whistleblower and investigation-related information. You may exercise these rights at any time by contacting us through the methods for the Global Contact as specified above.