Governance and Compliance
Operating with integrity is fundamental to who we are. We maintain rigorous standards for data protection, accessibility, risk management, and supply chain security — not just to meet regulatory requirements, but because it’s the right thing to do for our customers, employees, and partners.
Our commitment to responsible business practices strengthens trust and ensures we’re prepared for whatever challenges lie ahead.
Commitment to Compliance
Our comprehensive compliance program promotes ethical conduct at every level of the organization. We encourage employees to report concerns through multiple channels: speaking with a manager, human resources, the legal department, or using our anonymous third-party reporting system available via email, phone, or online portal.
Code of Conduct
In 2025, we implemented companywide Code of Conduct trainings designed to empower employees to navigate ethical situations in their day-to-day work.
Our trainings are interactive and employee driven. Small group discussions focus on issues selected by employee poll, while large group sessions — guided by members of our Legal team and HR Business Partners — allow employees to grapple with ethically challenging scenarios and hear practical advice.
Employees have shared that they appreciate the time and dedication taken to empower them to do the right thing, with some saying they now feel confident the company will listen and investigate issues reported.
Ethics and Compliance Week
We celebrated our second annual Ethics and Compliance Week in November 2025. The week featured interactive activities where employees answered compliance-related questions and received prizes for correct answers.
Employee participation increased across all available activities compared to the previous year, demonstrating growing engagement with our ethics and compliance culture.
Enhanced Reporting Tools
In 2025, we introduced a new hotline featured in our Code of Conduct booklets and available on the company intranet. We provided trainings on how to use the improved hotline for reporting potential issues, making it easier for employees to speak up when they see something that doesn’t seem right.
Enterprise Risk Management
Subaru Opportunity Annual Review
Subaru proactively manages risks that could impact our organization, employees, retailers, and customers. We identify potential enterprise-wide risks early, prepare thoroughly, and work to minimize impact and recover effectively when challenges arise.
The Subaru Opportunity Annual Review (SOAR) is how we identify, prioritize, and manage both strategic risks and opportunities across the organization. SOAR breaks down silos by bringing together teams from Finance, Operations, Compliance, Human Resources, Legal, Distribution, Marketing, and Risk Management. Each member contributes specialized expertise to ensure risk identification, assessment, and mitigation are thorough and effective.
The SOAR committee meets quarterly to review updates and discuss new and emerging risks. This cross-functional collaboration ensures we stay ahead of challenges and manage opportunities proactively rather than reactively.
Data Security and Privacy
Protecting customer data is a responsibility we take seriously. We strengthen our security through continuous system testing, ongoing employee training, and proactive vulnerability management.
All customers in the United States can exercise certain privacy rights through our online portal. In addition, we are committed to meeting or exceeding the automotive industry’s Consumer Privacy Protection Principles.
Digital Accessibility
Digital accessibility isn’t optional — it’s essential. Every Subaru employee completes digital accessibility training during onboarding, and our Customer Advocacy team receives updated training whenever new ADA compliance regulations are introduced.
Both Subaru and our third-party partners are held accountable for achieving WCAG 2.2 Level A and AA compliance.
Our ADA Digital Accessibility Team partners closely with the ADA Working Group to embed accessibility practices throughout our operations and foster a culture where accessibility is built into everything we do.
Supply Chain Security
Customs Trade Partnership Against Terrorism
Subaru works diligently to ensure accurate declarations for all parts and vehicles imported into the U.S. Our participation in the U.S. Customs and Border Protection’s Customs Trade Partnership Against Terrorism program strengthens our international supply chain security.
We consistently meet the Minimum Security Criteria for SOA’s Trade Compliance Program, maintaining our status as a Trusted Trader and enhancing supply chain security that benefits both retailers and customers.