Anti-Bribery & Anti-Corruption-Statement

Introduction:

Panasonic Europe Ltd. is committed to ensuring that each Panasonic company, branch or operation ("Company") in the European region meets its legal obligations and prevents, detects and eliminates corrupt practices, and cooperates to reduce opportunities for bribery and corruption.

Panasonic requires all staff at all times to act honestly and with integrity and to safeguard the resources for which they are responsible. Bribery is an everpresent threat to these resources and therefore must be a concern to all members of staff.

Panasonic Europe Ltd. does not tolerate any form of corruption (including the giving and receiving of bribes) within the organisation and takes the most serious view of any attempt to commit corrupt practices by members of staff, contractors, agents and business partners. Cases of suspected corruption will be properly investigated and appropriate action taken, including reporting to the appropriate authorities, disciplinary action, prosecution and active pursuit of recovery.

All management and staff are actively encouraged to report all cases of suspected corruption either to their line manager, to another member of management or via the Panasonic Hotline.

This Policy has been adopted and endorsed by Panasonic Europe Ltd. senior management and is to be communicated to everyone in our business to ensure their commitment to it. Our senior management attaches the utmost importance to this Policy and as stated above will apply a "zero tolerance" approach to acts of bribery and corruption by any of our employees or by business partners working on our behalf, including advisors, agents or contractors.

Panasonic also expects that all third parties dealing with Panasonic apply the highest ethical standards in their business relationships and that they have an appropriate anti-bribery and anti-corruption compliance programme in place.

Any breach of this Policy will be regarded as a serious matter and is likely to result in disciplinary action.

What is Bribery & Corruption?

For the purpose of this document by "bribery" and "corruption" we mean as follows:

Bribery:

includes, but is not limited to, the promising or granting or the requesting or receiving of benefits in money or money’s worth to a person with the aim of influencing that person in order to obtain business improperly or to gain an improper advantage. It is the offer, promise, giving, demanding or acceptance of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. The most obvious form of inducement is the giving / offer of money, goods or an advantage, but it can include the promise of favours in the future.

Corruption:

is the misuse of public office or power for private gain; or misuse of private power in relation to business outside the realm of government.

Application of the Policy:

This Policy is not intended to prohibit hospitality practices which are proportionate, properly recorded and lawful in the jurisdiction where they are carried out. Practices that are aimed at establishing/strengthening relationships with suppliers and customers and promoting Panasonic products and services, must be carried out in moderation, be transparent and not place any expectation on the recipient to reciprocate either by performing, or failing to perform, any other task in return.

Panasonic Europe Ltd. makes no distinction between facilitation payments (small payments, sometimes known as "grease" payments) and bribes. Both are expressly prohibited, even if the payment is small or totally acceptable according to local custom and tradition.

Employee Responsibility:

Each person within our organisation has a duty to speak out against suspected acts of bribery or corrupt practices. Everyone has a responsibility to help prevent, detect and report instances of suspected bribery and wrong doing.

Panasonic believes that it is essential to create an environment in which everyone feels that they can raise any matters of genuine concern without fear of disciplinary action being taken against them or fear of reprisal. We will ensure that all cases of suspected bribery are dealt with consistently and whether or not an investigation shows bribery exists, there will be no retaliation against or adverse consequences for the person reporting the possible case of bribery.

Further, no employee will suffer any retaliation or adverse consequences for refusing to pay a bribe.

We have a number of channels that employees can go through in order to speak to someone about any concerns in confidence:

  • the European "whistle-blowing" Hotline
  • the line managers
  • the HR managers
  • the Legal managers
  • the local Finance Directors