Governance and Compliance
Subaru of America, Inc. believes all colleagues deserve a place where high standards of ethics and integrity are prioritized in our work culture. This core commitment helps make us More Than a Car Company and drives our mission to inspire others through our actions. We ensure all colleagues can submit anonymous comments, questions, and concerns to help set a better course for our future.
Data Security and Privacy
Subaru launched its Data Trust and Enablement initiative this past year. This initiative fosters the Subaru culture by protecting the integrity of our customer, company, and colleague data. Our goal is for customers to trust that Subaru has their personal information secure and uses it in responsible ways. Our cross-functional team led by Legal and IT ensures the management of data and has put forth practices and procedures regarding the handling of data throughout the business. As part of this commitment, we’ve pledged to meet or exceed the Customer Privacy Protection Principles for Vehicle Technologies and Services established by the automotive industry in 2014 to protect personal information being collected through in-car technologies. These standards are regularly reviewed to ensure effectiveness.
Not only does Subaru exceed industry standards, but we also prioritize updating our own data privacy and security policies. This involves testing our own systems, implementing new training programs, working to eliminate new vulnerabilities, and looking for opportunities to grow our data governance and security. This includes further informing our customers of our existing practices through a variety of customer resources, including owner information kits and vehicle window stickers.
In addition, the consumer privacy rights provided to California residents by the California Consumer Privacy Act as amended by the California Privacy Rights Act (the “CCPA”), have been extended to all consumers in the United States. In 2020, the CCPA provided California residents with certain privacy rights in their personal information. This year, Subaru decided that these privacy rights should no longer depend on where you live. But all Subaru customers and prospective customers should have those same rights in their personal information.
Subaru believes in making sure digital users have access to all our robust content. This includes having all employees participate in a mandatory employee training program focused on digital accessibility and offering a customer support process to address accessibility concerns on our Accessibility webpage. We also updated our logos to be ADA compliant and are actively working with our third-party partners to ensure our digital accessibility policies remain effective.
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 mitigate risk. Some of the cross-functional teams and approaches that have been created and utilized are:
ADA Working Group
The ADA Working Group mission is to support the Subaru Love Promise by providing equal opportunities to interact with our digital platforms. This group focuses on incorporating accessibility practices in both design and development by ensuring legal ADA regulation compliance, governing policies and standards at Subaru and our partners, and communicating compliance metrics to senior leadership and legal teams. The group fosters an accessibility culture at Subaru and communicates the importance and value of accessibility across the company.
Subaru Opportunity Annual Review
Subaru has implemented an enterprise risk management process, Subaru Opportunity Annual Review (SOAR). SOAR’s purpose is to ensure that SOA’s strategic opportunities and risks are being identified, prioritized, evaluated, and managed appropriately and effectively. In addition to addressing emergency situations when they arise, minimizing damages, and purchasing the proper insurance coverages and limits for SOA’s insurable exposures, SOAR proactively addresses the various opportunities and risks that have an impact on SOA’s strategic goals. This is done through interviewing stakeholders to identify risks and opportunities, ranking those risks and opportunities on frequency, severity, and ongoing efforts, and reporting to the organization’s leadership. SOA uses SOAR to collaborate and make more informed decisions to improve our strategic, financial, and operational performance.
Corporate Responsibility Working Group
This working group provides a forum to share opportunities and accomplishments related to all the subject areas that are a part of our work to be More Than a Car Company. The group offers colleagues a platform to highlight opportunities and accomplishments in the Corporate Responsibility space, some of which are documented throughout this report, as well as elevate areas of opportunity.
Contract and Vendor Management Process
In 2022, we continued to develop processes 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.
Customs Trade Partnership Against Terrorism
Subaru works to ensure that all internationally manufactured parts and vehicles are properly declared upon entry into the United States. Subaru is a member of the U.S. Customs and Border Protection’s Customs Trade Partnership Against Terrorism program to help establish a safe and secure national supply chain.
Subaru has been listed as a Trusted Trader with U.S. Customs and was designated at the highest-rated tier-three level. This designation acknowledges a 95% or better monthly and annual import volume accuracy rate. Our role as a Trusted Trader helps secure our own supply chain to benefit our retailers and customers.
Subaru always welcomes feedback from colleagues to ensure that we are maintaining an ethical working environment. The company expectation is that all employees will report known or suspected ethical concerns either to their manager or management, the Human Resources department, or the Legal department. In addition, Subaru has also made available to all employees a third-party compliance reporting system that provides employees another avenue to report their concerns. Colleagues can submit complaints by email, phone, or through a website portal. The compliance reporting system provides employees with an option to report concerns anonymously, ensuring that everyone’s voice can be heard in whatever manner they feel most comfortable. Our colleagues who participate in the Compliance Hotline program help us be a better Subaru and allow us to continue on our journey to be More Than a Car Company.
See the Safety & Quality section for more on our products.