Subaru of America, Inc. (Subaru), prioritizes high ethical standards and integrity in its governance and corporate culture. This fundamental tenet demonstrates Subaru's commitment to being a good corporate citizen to our team members, retailers, and customers.
Subaru takes data security and privacy seriously. Subaru is continuously enhancing its data security practices through rigorous testing of systems, new training programs, and active measures to eliminate vulnerabilities. We inform customers through resources such as owner information kits and vehicle window stickers.
Subaru's privacy practices exceed what is required by law. In 2023, California, Colorado, Connecticut, and Virginia had state privacy laws that provided customers with certain privacy rights. We voluntarily extended those same rights to all customers in the United States, regardless of their location. We inform customers of our data collection practices and their privacy rights through owner information kits, vehicle window stickers, and easy-to-access online resources. In addition, Subaru pledged to meet or exceed the automotive industry's Customer Privacy Protection Principles for Vehicle Technologies and Services. Subaru regularly reviews its vehicle data collection practices to exceed these principles.
Last year, Subaru initiated the Data Trust and Enablement initiative to safeguard customer, company, retailer, and employee data. Our primary goal is to build trust with all of our stakeholders, assuring them that their data is secure, accurate, and responsibly managed. Led by a cross-functional team, this initiative establishes and enforces data-handling practices across the company. The team guided Subaru's approach to employee use of Artificial Intelligence (AI) and provided training to employees on the responsible use of AI.
We are committed to ensuring that digital users have access to all content. To achieve this, all employees are required to undergo a mandatory employee training program focused on digital accessibility upon employment start. Additionally, Customer Advocacy employees are required to complete refresher training when any new ADA compliance regulations are published and a customer support process has been implemented to address any accessibility concerns. Subaru holds itself and its third-party partners responsible to strive for the WCAG 2.2 level A and AA to ensure policy effectiveness.
In 2023, Subaru created an ADA Digital Accessibility Team that partners with Subaru's ADA Working Group to help ensure equal opportunities on digital platforms, integrate accessibility practices, and adhere to the ADA regulations. The team leader communicates compliance metrics to senior leadership and legal teams, fostering an accessibility culture across Subaru.
Subaru is serious about managing risks that may have an impact on our colleagues and customers. Our commitment to mitigating these risks involves preparing for emergency situations and taking steps to minimize damage when risks emerge.
The Subaru Opportunity Annual Review (SOAR) initiative is our enterprise risk management process. SOAR identifies, prioritizes, and manages strategic opportunities and risks at Subaru. SOAR collaborates to address emergencies, minimize damage, and enhance our strategic, financial, and operational performance. SOAR seeks to promote cross-functional communication and reports on the risks and opportunities to avoid managing in silos.
Subaru helps ensure proper declarations for all our globally manufactured parts and vehicles entering the U.S. We contribute to establishing a secure international supply chain by actively engaging in the U.S. Customs and Border Protection’s Customs Trade Partnership Against Terrorism.
Earning the status of Trusted Trader from U.S. Customs, Subaru maintains an impressive monthly and annual import volume accuracy rate of 95% or higher. This recognition enhances our supply chain security, benefiting both retailers and customers.
Our commitment to compliance oversight is reflected in our comprehensive compliance program, designed to instill accountability across our company. We encourage colleagues to report concerns through various channels, including through managers, HR, or the Legal Department. We also offer a third-party compliance reporting system, allowing anonymous submissions through email, phone, or a website portal, fostering a collaborative effort towards a more promising future.
Subaru has also created a new investigations policy that advises employees of their obligations to report, in good faith, any potential ethical violations from employees, vendors, contractors, and/or third parties. This policy further identifies our employee’s roles and responsibilities to cooperate in an investigation.
Subaru maintains a rigorous system of compliance, governed and enforced by the Compliance Committee. The Committee chairperson is the President and COO, the Vice Chairperson is the General Counsel, and the remaining committee members are comprised of the President’s direct reports, each of whom is responsible for compliance over their respective departments. This approach reflects Subaru's unwavering commitment to compliance.
