September marks Compliance Awareness Month at Panasonic, a time when all of its employees in every corner of the world collectively reaffirm their commitment to live the company’s core values while management reinforces its efforts to strengthen compliance awareness. It’s a monumental, global effort, to say the least. In this one-on-one, we caught up with Ling-Ling Nie, chief compliance officer and assistant general counsel at Panasonic North America, who shares what innovative and creative initiatives Panasonic is taking to keep its employees focused and engaged.
First, tell us a little about Panasonic, generally.
Panasonic is a global technology company, headquartered in Japan, with about U.S.$65 billion in net sales a year. Next year is a landmark year, because Panasonic is going to be celebrating its 100th anniversary.
The company is structured by region, made up of 496 consolidated companies, with over 250,000 employees globally. There are regional headquarters in every area of the world. Panasonic North America, its principal U.S. subsidiary, is headquartered in Newark, New Jersey. There are also regional headquarters in Belgium for the European region; Panama, for the South America, Latin America, and Central America region; Singapore, for the Asia-Pacific region; and India for the Middle East, Africa, and India region. We also have an office in China that has a large market, as well.
What is your role as chief compliance officer and assistant general counsel at Panasonic North America?
I spend one hundred percent of my time on compliance. When you’re a chief compliance officer, you always have to take the pulse of the organization to understand current risks as well as what risks may be coming down the line. You have to understand the regulatory environment, the industry, the market, and make sure that everyone in the company understands where the company’s major priorities are … and what they specifically need to do to make sure they’re protecting the company and themselves.
I manage the compliance program itself. There are a lot of operational responsibilities—in having a training program; in having an awareness program and a hotline; and various activities throughout the year to make sure people are thinking about compliance regularly. Because I’m also an attorney, there is also a legal aspect to my job. I provide a lot of legal guidance on a whole host of issues—from antitrust and anti-corruption to privacy, conflict minerals, data protection, customs, and export compliance—that can cause problems for the company.
You mentioned that Panasonic has various compliance activities throughout the year. Wasn’t there a big one in September?
Yes, September is Panasonic’s Compliance Awareness month. It’s celebrated globally. Our parent company in Japan designated this as the annual time of the year when everybody reaffirms their commitment to do business the right way and to live our company values, and so September is the time of the year when we release a lot of new resource materials and put compliance on stage for everyone. We do that throughout the year, but September is when we do our big campaign.
“Compliance Awareness Month” is a very busy time. We do training. We do a lot of fun games. This year, we did an electronic scavenger hunt. Although compliance can be dry and it’s something we do have to prioritize and think about every day, it doesn’t necessarily have to be boring. We can make it fun.
Our parent company in Japan designated this as the annual time of the year when everybody reaffirms their commitment to do business the right way and to live our company values ...
We’ll also do a lot of onsite visits, where we set up compliance stations in the lobbies of our various offices to answer questions and hand out various resources and fun promotional items. We also administer a survey throughout the entire region to get feedback on how we can do better and what are some of the problems or concerns that they would like to bring to our attention, so there is a lot of activity in September. It’s been very busy.
May is another important time of year for us. We usually select the first or second week in May to highlight corporate ethics week. May focuses more on values, where September focuses more on the policies, our Code of Conduct, and things of that nature.
I want to hear more about Corporate Ethics Week, but before we get to that, what new materials did Panasonic release this year for Compliance Awareness Month?
For September of this year, our overall theme focused on leadership. Along those lines, we came out with the Manager’s Compliance Guide. This is a resource for managers to use to help them make compliance relatable to employees; what the guide essentially does is highlight their unique role in translating the executive message of compliance to their folks.
Managers a lot of times are gatekeepers when it comes to certain policies, like our gift policy or conflict-of-interest policy. They are the first point of contact for employees when they have questions or concerns. The guide helps them to understand, “Here are policies where you have a role in helping to make sure we are complying with them.” It stresses their leadership status and how what they do is going to be mirrored by employees. I always tell managers, “Employees are going to prioritize whatever you prioritize.”
The Manager’s Guide also has a checklist to walk managers through certain topics. One topic, for example, touches upon how to handle an employee concern, and what specific behaviors or points you want to make sure you’re communicating. We say things like, “Listen actively. Remain objective. You might want to take some notes. Ask open-ended questions.” The Manager’s Guide provides very specific advice for a manager that might need some guidance.
ABOUT LING-LING NIE
Ling-Ling Nie became chief compliance officer and assistant general counsel of Panasonic North America this year.
Prior to that role, since 2015, she was director of compliance and ethics and senior counsel at Panasonic North America, where she established a centralized compliance and ethics program for all employees in all divisions and subsidiaries in the Panasonic North America group, including overseas operations.
Nie joined Panasonic in 2012 as senior counsel, compliance and ethics at its subsidiary, Panasonic Automotive Systems Company of America. In that role, she established and managed a company-wide compliance and ethics program for Panasonic’s automotive supplier division with a focus on antitrust, anti-corruption, customs/export compliance, and EU data protection and privacy regulations.
Prior to her time at Panasonic, Nie was an attorney with the U.S. Department of Treasury, where she provided advice and counsel on various ethics and compliance rules and regulations.
For Compliance Awareness Month, we also released a Compliance Manager Executive Kit, addressed to the senior executives—our CEO, the chairman, and all our company presidents. The kit was essentially a package that had a compliance program T-shirt and button, with a note from me that said, “Please wear your shirt or button throughout the month of September to show your support for compliance.” For me, it’s important that executives show their personal and direct support and involvement for compliance.
What was on the compliance t-shirt?
The back of the t-shirt has our seven core values. The front has our slogan for the year: “PNA DNA” (PNA being the acronym for Panasonic North America). The slogan essentially means our company’s values are embedded in the way we do business.
Going back to what you touched upon earlier, what is Corporate Ethics Week all about at Panasonic?
The focus is really on our values. We did a company values video campaign a year ago, when we asked our executives to talk about a specific company value, and what it means to them. We have seven company values. One of them is “fairness and honesty,” so we asked our general counsel, Damien Atkins, to get on camera and talk about, “What does fairness and honesty mean to you?” He made a series of five or six videos that were about one minute long.
We launched the videos in May and played them on television screens throughout our offices. We had them sent them out through e-mail, as well. We have a YouTube channel with the videos. Again, the videos let people know, “We have values. Our company stands for something. We want to do business a certain way, and here are our leaders talking to you about how they embody those values in the day-to-day aspects of their jobs.”
Another example: I hired a couple of actors to do an improv show as part of our values training, in which they created scenarios of unethical business situations. Everyone in the audience got a red flag, and any time they sensed something was unethical or problematic or questionable in terms of behaviors or statements, they would have to wave their flag in the air. It was a way for employees to interact with the training.
As a third example, I enlisted a guy out of Ohio who had gone to jail for antitrust violations to come speak to our employees. I wanted him to focus on the human cost of a compliance violation: “What is it like to be investigated and prosecuted and have to go to prison? How does that affect you as a human being? What are the lasting effects of being a convicted white-collar criminal?”—the sort of things that people without a criminal history wouldn’t know.
How does Panasonic help managers and executives stay excited and committed to compliance training and awareness?
We do an awards program. When you think about the profile of an executive or a manager, those folks are usually very driven, ambitious, and competitive, and so one example of how we leverage that is that we have an awards program called “Leaders of the Pack,” in which we award the one company or department that has the highest level of compliance training completion. They get an award at the end of the year, and their employees get a pizza party or catered lunch, for example.
And the way we encourage executives and managers to get involved in the awards program is that every quarter I send out a bar chart of all the different companies and where their training completion rates are at in comparison to each other, so they can look to see how they stack up against the other companies. That was one way to really get them directly involved in telling their employees that training is important.
Where do you find inspiration for Panasonic’s ethics and compliance initiatives?
I learn from others, but I also look internally to myself and think, “What would resonate with our employees?” Just through that creative process, I’ve been lucky enough to come up with things that have been successful for our company.
What’s nice about the compliance profession is that it’s a hybrid of law, marketing, communication, and fun. There is this whole aspect of putting training together, putting games together, putting videos together. Because I like to be creative, it gives me that outlet and that opportunity to bring that into my core career, as well.
Something that doesn’t get talked about enough is the types of people who are running the compliance program itself. That’s a critical aspect to having a successful program. You have to hire people who like people. That means hiring people who are likeable, approachable, and relatable, because essentially you are advertising and marketing your program to employees. If you don’t have the right people doing that—if you can’t cast the right light on what the company is doing and why this is something they should pay attention to—then the compliance program won’t be successful.