Compliance

The SUBARU Group has established the Risk Management and Compliance Committee as an organization designed to promote compliance. The Chief Risk Management Officer (CRMO), appointed by the Board of Directors, serves as chair of this committee, with the Risk Management and Compliance Office serving as its secretariat. Under the chair’s direction, the committee conducts comprehensive oversight of compliance and executes global and Group-wide compliance initiatives. In addition, the committee is responsible for the formulation of various policies, etc., and deliberating and deciding on important compliance matters, such as the status of Group-wide compliance activities and the operation of the internal reporting system, as well as for information exchange and liaison. The content of the committee's activities is deliberated and reported on at the Board of Directors' meetings.

We also employ a PDCA cycle, with each department creating its own compliance program each fiscal year to enhance compliance. This involves consistent, structured independent actions for legal compliance management and to foster employee compliance awareness, as well as subsequent verification of compliance status.

Compliance System

Compliance Hotline

When regular or temporary employees of SUBARU and its Group companies in Japan detect a problem related to compliance in the Group, they can consult with our Internal Reporting Desk by using the Compliance Hotline.
The Internal Reporting Desk is staffed by employees designated as engaged persons under the Whistleblower Protection Act, who investigate and respond to reports received by telephone, websites, mail, and other methods. We have established a desk outside the Company staffed by external third-party specialists who have no conflict of interest to increase the hours in which service is available and to increase the confidentiality and security of those contacting the desk. Furthermore, we provide consultation services in four languages (English, Chinese, Portuguese, and Spanish) for foreign workers.
Consultations received through these channels are thoroughly examined by the Risk Management and Compliance Office General Manager, following our internal rules, to ensure swift resolution. Also, the Internal Reporting Desk reports to the proper management members and the Risk Management and Compliance Committee, working toward preventive measures. Moreover, we have established a mechanism that enhances the reliability and effectiveness of the internal reporting system by conducting third-party evaluations, led by legal experts, on reported cases and the subsequent actions taken.
Through initiatives to raise awareness of this system, SUBARU has improved awareness of compliance and fostered an atmosphere where employees can consult even about trivial matters. This has resulted in an increasing trend in the number of consultations over the previous five years. Since more than 80% of consultations are interpersonal relationship or labor-related, this system also contributes to corporate culture reforms as a desks for taking up and resolving workplace issues.
In FYE March 2024, we received 317 consultations. Of these, there were 34 suspected violations or violations of compliance, but none of these constituted serious violations. In addition, eight of the 34 consultations involved conduct that was identified as harassment, such as abuse of power. There were no cases of violations of the Labor Standards Act.

Compliance Hotline (Consultation and resolution procedure)

Breakdown of Compliance Hotline Consultations and Trend over Time

Training

In enforcing thorough compliance, we believe that initiatives in which the entire SUBARU Group acts in concert are necessary. We conduct compliance training, training for legal affairs in practical business, and other programs for all employees of SUBARU and its Group companies in Japan organized by our Legal Department, Risk Management and Compliance Office, and human resource and education departments.
In FYE March 2024, we conducted video-based training specifically on harassment for all SUBARU employees, and have also conducted such training at some of our Group companies in Japan.
In addition, to promote the understanding of key laws and regulations, the Legal Department leads training for legal affairs in practical business for SUBARU and employees of Group companies in Japan. In FYE March 2024, we conducted such training within nine programs covering topics that included various national security trade controls, the Act on the Protection of Personal Information, the Subcontract Act, and anti-monopoly laws outside Japan. In addition, to complement compliance enlightenment training, study groups are held at each department and affiliated company based on their compliance program, covering critical and important laws and regulations related to their work. These include export controls, the Act on the Protection of Personal Information, the Antimonopoly Act, the Political Funds Control Act, and harassment prevention.

Compliance Implementation Support Tools

In order to promote compliance in everyday work, we create and provide various implementation support tools other than the Compliance Manual, such as in areas of specialization at affiliated companies.
To make knowledge of the Compliance Hotline common, we distribute cards containing information on the framework of the system and the contact address for consulting services, and also put up posters in all workplaces. We have designed the information cards and posters to deliver a message that encourages employees to proactively use the system even for things that feel only slightly suspicious.
In addition, we are making efforts for the timely report of highly urgent information and to call all Group entities in Japan's attention to such matters.

Bribery Prevention

At SUBARU, we consider the prevention of bribery in connection with our businesses as an important issue. We have established company-wide Bribery Prevention Rules and the following standards of conduct in the Compliance Guidelines, which are also implemented across our Group companies in Japan. We are committed to ensuring that specific actions are rigorously communicated and enforced through the Compliance Manual.

• Prohibition of providing, offering, or promising improper entertainment, gifts, favors, or other economic benefits to public officials or persons in similar positions, whether in Japan or abroad
• Prohibition of providing or receiving an amount in excess of socially accepted norms in dealings with business partners and customers who do not constitute public officials or similar persons
• Prohibition of receipt of personal gain as a result of using information obtained in the course of business, establishing boundaries between public and private life

To supplement the Compliance Guidelines and Company-wide Risk Management and Compliance Rules, SUBARU has also established the company-wide Bribery Prevention Rules, which clarify prohibited and non-prohibited acts when dealing with public officials. Furthermore, SUBARU has established the Political Funding Company-wide Rules, which aim to ensure proper operation and execution of donations related to political activities by SUBARU in compliance with related laws and regulations, in order to control such donations. SUBARU Group companies overseas have also established guidelines on anti-bribery in consideration of local laws and regulations to clarify the conduct required of employees and executives. In China, taking into consideration unique social conditions, we created the Bribery Prevention Guidelines (with a Chinese translation included). It is distributed throughout our Chinese subsidiaries and forms the official rules of the relevant companies. Also, anti-corruption is identified as an important issue in the Compliance Manual (available in Japanese, English, and Chinese) issued to Group companies in Japan and overseas. We not only require proper conduct regarding bribery to government workers but also pursue thorough fairness in transactions with private-sector customers and partners.
Under the monitoring system for bribery prevention, SUBARU collects information to ascertain the presence of cases that may constitute compliance violations through company-wide fact-finding investigations. It also strives to detect cases early via business audits conducted by internal audit departments. Furthermore, SUBARU has established a system to report high-risk cases to the Risk Management and Compliance Committee and the Board of Directors, in an effort to strengthen oversight.
In FYE March 2024, there were no fines, penalties, or settlement payments related to violations of anti-corruption laws and regulations within the SUBARU Group, and no individuals were subject to disciplinary dismissals for such violations.

Security Trade Control

SUBARU, seeking to preserve the peace and safety of the international community, performs independent export control in accordance with the Foreign Exchange and Foreign Trade Act so that consumer products and technology that could be repurposed for military use, including weaponry, do not fall into the hands of countries developing weapons of mass destruction or terrorists (non-state entities). We have regulations for the purpose of appropriate management of the Group. Also, the Export Control Committee is a body that meets at least once a year to deliberate on Group-wide initiatives. It is comprised of executives from all departments involved in exports, chaired by the director in charge of the Legal Department.
With the goal of improving the level of its management, SUBARU also promotes PDCA cycles, including review of related rules, with a focus on the following initiatives.

• Regular training sessions for management, including members of the Export Control Committee, and practitioners led by external experts and internal instructors (Legal Department employees)
• Export controls utilizing IT systems (regular system enhancements are made to improve controls)/Training sessions to familiarize employees with the relationship between company-wide rules and systems
• Utilization of proprietary checklists in accordance with relevant regulations and on-site voluntary inspections (continuously improving inspection accuracy)
• Checking compliance with not only the Foreign Exchange and Foreign Trade Act but also U.S. Export Administration Regulations and implementing measures for proper management

Enactment of the Tax Policy

The SUBARU Group enacted its Tax Policy in June 2020. This basic policy sets forth our posture and way of thinking toward the tax laws we should comply with when paying the appropriate amount of tax.
In promoting tax strategy and risk management, SUBARU’s Finance & Accounting Department reports on these matters to the Chief Financial Officer (CFO), who must approve them before submission to SUBARU’s Executive Management Board Meeting and the Board of Directors. Such matters are also reported to the accounting auditors during their audits and to the Board of Corporate Auditors upon request by the respective parties as appropriate.
SUBARU received a "Good" rating from the National Tax Agency for 2023 in relation to efforts to promote the enhancement of corporate governance on tax matters^*.

*

Regarding the National Tax Agency's policies for efforts to promote the enhancement of corporate governance on tax matters (in Japanese only):
https://www.nta.go.jp/taxes/tetsuzuki/shinsei/shinkoku/hojin/sanko/cg.htm

Tax Policy

Established in June 2020

Political Donations

No SUBARU employee shall make donations related to political activities to anyone other than political parties and political funding organizations. When providing support for activities of political funding organizations, we will respond appropriately in accordance with the Political Funds Control Act, the Public Offices Election Act, and other relevant laws and regulations.