Governance and Compliance

Practicing the highest standards of ethics and integrity is a core tenet that makes us More Than a Car Company^®. We ensure all colleagues are aware of and have access to our corporate policies and procedures. We make a variety of different channels available for submitting comments, questions, and concerns, including anonymously. Subaru believes in inspiring others with our actions that assure integrity and respect while creating safe and reliable vehicles.

Data Security and Privacy

We take the responsibility of protecting data seriously. To start, Subaru of America, Inc. (Subaru) has committed to meet or exceed the Consumer Privacy Protection Principles for Vehicle Technologies and Services, a privacy framework established by the automotive industry to help protect personal information collected through in-car technologies. These principles, first developed in 2014, are reviewed regularly to make sure that they remain relevant and robust.

Subaru also continues to update its data privacy/security practices. We regularly test our systems and our colleagues; we have implemented new training programs; we work to eliminate potential new vulnerabilities; and we continue to look at new opportunities around data governance to ensure that Subaru remains a good steward of its customers’ data. This year, our parent company, Subaru Corporation (SBR), formalized its Global Security Policy, which applies to all SBR subsidiaries, including Subaru of America, Inc.

We also remain committed to transparency regarding these privacy practices. We have taken steps to further inform customers of our practices through our websites and other customer touchpoints, including owner information kits and vehicle window stickers.

Accessibility

We continue to review and modify internal processes to improve accessibility for all users within our digital platforms. In 2021, we launched mandatory employee training focused on digital accessibility awareness and best practices to take our content and platforms to the next level. We also added an accessibility statement on Subaru.com, providing information and contact options for users, and created a customer support process to address digital accessibility-related inquiries.

We continued working with our third-party partners this year to improve digital accessibility and ongoingly review procedures.

Cross-Functional Collaboration

At Subaru, we adopted a cross-functional compliance program to hold ourselves accountable. We are taking a holistic view that works closely with all business units to monitor compliance and to mitigate risk. Some of the cross-functional teams and approaches that have been created and utilized are:

Subaru Opportunity Annual Review (SOAR)

Fosters a collaborative means of recognizing, analyzing, and managing risks and opportunities. This enterprise risk management process encourages colleagues to recognize, assess, and prepare for risks, while developing opportunities in our business operations.

Corporate Responsibility Working Group

Provides a forum to share both opportunities and accomplishments related to all the subject areas that are a part of Corporate Responsibility.

Vendor Due Diligence Program

Developed to help ensure that our vendors not only deliver the high-quality product or service we expect, but deliver it in a legally appropriate, financially sound, and ethical manner.

Contract Management System

We are eager to launch our cross-functional digital tool in 2022 to automate and standardize the contract renewal process.

Customs Trade Partnership Against Terrorism

Prior to distributing internationally manufactured parts and vehicles to our retailers, Subaru must ensure they are properly declared and cleared upon entry into the U.S. We are a proud member of the U.S. Customs and Border Protection’s Customs Trade Partnership Against Terrorism (CTPAT) Program, which establishes processes to help ensure the safe and secure flow of our country’s supply chain.

Through our participation at the highest-rated, tier-three level, Subaru has been designated as a Trusted Trader with U.S. Customs, a status given to those partners with active, regular, and detailed reporting. This designation acknowledges that our monthly and annual import volume calculation accuracy rates remain at 95% or better. We take our Trusted Trader role very seriously, allowing us to keep our supply chain secure and provide an ample inventory of vehicles and parts to our retailers and our customers.

Compliance Hotline

Feedback is always welcome at Subaru. To provide a clear pathway for comments, we have developed the Compliance Hotline. Our Compliance Reporting System is run through a third-party organization, Integrity Counts, which acts as a built-in barrier between employees and management to help ensure employees feel comfortable submitting concerns. There are multiple ways that colleagues can report, including in person, by email, by phone, and through a website portal, making sure there is an option for everyone. We would like to thank our colleagues who participate, as they help us to continue on our journey to be More Than a Car Company^®.

For more on our product governance, see the Safety & Quality section.

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