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