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SAFEGUARDING OUR COMPANY

The resources we use each day, our brand and the creative ideas we develop in our work are what allow our business to thrive. We treat all of our assets as we would our own and only use them to further the interests of our Company.

Mazda Europe headquarters

USE OF COMPANY ASSETS

Our resources are essential to the efficient and effective operation of our business. We count on you to use them responsibly and protect them from loss, theft, fraud and misuse.

Our assets include:

Physical property - such as office supplies, equipment, funds, money or credit.
Technology resources - including email, internet access, computer hardware, software and phones.

Digital devices on a table

Handle our assets with care. Be good stewards of our resources and use them not only responsibly, but in line with Company policies. Keep valuable assets, like laptops, physically and electronically secure. Notify your manager if any of our assets are damaged, defective or in need of repair.

Use our technology responsibly. Our technology and electronic communication systems are valuable resources that are important for our work. We depend on you to use them according to our policies:

  • Never use our resources to send harassing, obscene or discriminatory communications.
  • While occasional personal use of our resources is allowed, you must never use them to support secondary employment, outside business ventures or political activities.

Secure our network. We rely on you to protect our network from viruses, downtime and unauthorized access. Follow our policies, keep passwords private and only use approved software.

BRAKING POINT

Practice good security and be good stewards of our resources. Use our assets appropriately and only for business purposes.

THIS WAY TO OUR POLICIES

Test your knowledge

Question:

I am leaving town next week and want my colleague to work on my SAP stuff to release purchase orders while I am out of the office. Can I give her my password and reset it when I get back?

Choose the correct option (Yes/No)

 Sorry, wrong answer!

You must keep your password private. If someone needs to take over your responsibilities while you are away, set up an appropriate stand-in.

 That’s right!

You must keep your password private. If someone needs to take over your responsibilities while you are away, set up an appropriate stand-in.

PROTECTING COMPANY INFORMATION

Innovation is key to our success. Everyone at Mazda works hard to develop proprietary technologies and strategies. If your work exposes you to sensitive information, protect it from misuse or unauthorized disclosure.

Know what information is sensitive. Sensitive Company information is any information that’s not available to the public that could benefit our competitors or harm Mazda or customers if it is exposed. This includes information about:

  • Our Company — including product research, designs, budgets, forecasts, acquisition information or trade secrets.
  • Third parties — such as information about contract terms, pricing and other sensitive information about our business partners.
  • Personal data of our employees, customers and third parties.
Do not take pictures sign

Keep it safe. We depend on you to handle sensitive information with care, access only the information you need to do your job and take measures to prevent unauthorized disclosure. Even if you leave Mazda, you still have an obligation to protect our Company’s information.

When working with sensitive information, remember:

  • Classify, manage and protect it according to Mazda’s policies.
  • Access and store it on approved devices.
  • Dispose of it properly, according to our policies.
  • Do not view, discuss or work with it in a non-secure setting.
  • Never share it on social media or in public.
  • Be aware that personal data requires a higher standard of care — make sure you comply with the data privacy requirements outlined in the Data Privacy section of the Code.

Respect intellectual property. Our ideas, patents, logos and even our name are all examples of intellectual property. Use our intellectual property only for business purposes and never disclose it without Company approval. Remember to also respect the intellectual property rights of others and never infringe or misuse their intellectual property.

BRAKING POINT

Maintain sensitive Company information and handle it with care. If you suspect that any of our sensitive information has been disclosed, speak up.

Test your knowledge

Question:

A friend of mine wants me to share confidential product data about some of the topics I work on here at Mazda because she’s interested in the automotive industry. Can I share that information with her?

Choose the correct option (Yes/No)

 Sorry, wrong answer!

You should not disclose confidential product data, and you have a duty to protect it (even after you leave the Company!).

 That’s right!

You should not disclose confidential product data, and you have a duty to protect it (even after you leave the Company!).

DATA PRIVACY

We place a high priority on protecting the data privacy of our employees, customers, prospects and service providers. Whenever collecting or processing personal data, we must comply with the EU General Data Protection Regulation (GDPR) requirements and all supplementary data privacy laws and principles.

What is personal data? The scope and definition of personal data is broad and includes:

  • Any information that can be used to identify a specific person
  • Any “identifier” information that, directly or indirectly, can be combined to identify a specific person

Examples of personal data include:

  • Contact details (name, address)
  • Personal details (date of birth, family status, profession)
  • Vehicle data (vehicle identification number, license plate, service history)
  • Technical data (IP address, device ID)
Laptop on someone knees showing a data privacy message

Understand your obligations. You have a responsibility to comply with data privacy laws (including the EU GDPR and the related Data Protection Principles) in your work.

The most relevant Data Protection Principles include:

  1. Purpose Limitation - Personal data may only be processed for specific, explicit and legitimate purposes, for which they have been collected.
  2. Data Minimization - The processing of personal data must be adequate, relevant and limited to what is necessary given the purpose for which the data have been collected.
  3. Storage Limitation - Personal data may not be kept any longer than is necessary, given the purpose for which the data is processed.
  4. Integrity and Confidentiality - Personal data must be processed in a manner that ensures appropriate security of the data using appropriate technical and organisational measures.
  5. Lawfulness, Fairness and Transparency - All processing must be lawful, fair and transparent.

Report privacy breaches. If you believe that the privacy of people’s personal data may be compromised, immediately contact your local Data Breach Emergency team. This includes instances where there is loss of data or data carriers, unintentional disclosure or infiltration of Mazda IT systems.

BRAKING POINT

Protect the personal data of our customers, employees and partners. Disclose it only to those who are authorized to have it. Report any suspected privacy breaches immediately.

Test your knowledge

Question:

As the responsible manager for our CRM (Customer Relationship Management) database, I noticed that some improperly defined merging process has caused the loss of data from the CRM database. Even though the purpose of the merging was to cleanse the CRM database, it ended up deleting some personal data. Do I need to report this?

Choose the correct option (Yes/No)

 That’s right!

An accidental loss of access to or destruction of personal data must be reported immediately to your local Data Breach Emergency team, following the established procedures.

 Sorry, wrong answer!

An accidental loss of access to or destruction of personal data must be reported immediately to your local Data Breach Emergency team, following the established procedures.

INSIDER TRADING

Our duty to protect inside information is something we take seriously. If you have access to inside information as part of your job, never use it for your own financial gain or share it with others.

Understand your obligation. As part of your job, you may be exposed to nonpublic inside information about our Company or information belonging to one of our suppliers, competitors or customers. Buying or selling shares, etc., based on this information is called “insider trading” and is illegal.

Trading chart on mobile screen

Examples of inside information include:

  • Changes in executive leadership
  • New product plans
  • Financial results
  • Planned mergers or acquisitions
  • Sale of Company assets or subsidiaries
  • Significant transactions

Don’t disclose inside information. Sharing inside information or providing advice to anyone to buy or sell securities based on it is also a form of insider trading. Never share inside information with others — even if you do not intend for them to act on the information.

Wait until it’s public. After information is officially released to the public, you may use it to invest or advise others to invest, as permitted by law. Information can be released through a press release, government filing or some other form of official communication. Always ask for help if you’re ever unsure.

BRAKING POINT

Even if you do not think someone will use the information you gave them, you still may be engaging in insider trading if you have shared inside information with that person.

THIS WAY TO OUR POLICIES

Test your knowledge

Question:

My sister asked me if she should buy stock in our Company. I know we will be releasing a new product soon that is expected to increase the value of our stock, but it hasn’t been publicly announced yet. Can I share this information with her?

Choose the correct option (Yes/No)

 Sorry, wrong answer!

Do not share any information about the product or other inside information that could influence her decision to purchase the stock. Doing so would be considered an illegal disclosure of inside information. Wait until the information has been made public, then it’s permitted under the law for you to share it before advising her to buy our stock.

 That’s right!

Do not share any information about the product or other inside information that could influence her decision to purchase the stock. Doing so would be considered an illegal disclosure of inside information. Wait until the information has been made public, then it’s permitted under the law for you to share it before advising her to buy our stock.

ACCURATE RECORDKEEPING AND
FINANCIAL REPORTING

One of our duties as a publicly traded Company is to maintain books and records that accurately represent our business and our financial position. Whenever you record or handle our business and financial records, do so honestly and with care.

Be accurate and truthful. Providing inaccurate or incomplete business records puts our Company at risk. Business and financial records include things like invoices, expense reports and timesheets. If you create or handle these records, make sure that the information they contain is correct and complete.

Woman working on diagrams

Protect the integrity of our records:

  • Record transactions honestly.
  • Protect them from unauthorized alteration or destruction.
  • Cooperate with audits and investigations.
  • Make sure that public disclosures and filings comply with legal requirements and accounting principles.

Watch out for suspicious entries. Stay alert to and report any suspicious activity, such as signs of potential bribery, fraud or money laundering. Be aware of things like false entries, misleading statements or recorded information that hide the true nature of any transaction. Speak up if you have any concerns about any of our records.

Manage records properly. We’re committed to managing our records appropriately and keeping the records needed to support our tax, financial and legal obligations. Follow our policies and properly maintain supporting documentation.

BRAKING POINT

Ensure that our books and records are accurate and protect them from unauthorized alteration or destruction. Report suspicious activities.

Test your knowledge

Question:

My manager asked me to change some information on an invoice, but I never received any supporting documentation. Should I still make the changes she requested?

Choose the correct option (Yes/No)

 Sorry, wrong answer!

You are obligated to record transactions ethically and honestly. Ask her to provide supporting documentation and if she does not provide it, report it following Mazda’s Speak-up process.

 That’s right!

You are obligated to record transactions ethically and honestly. Ask her to provide supporting documentation and if she does not provide it, report it following Mazda’s Speak-up process.

SPEAKING ON BEHALF OF OUR COMPANY

The public expects us to provide reliable information. We only authorize certain people to speak on behalf of Mazda because we want to deliver a consistent message, ensure that confidential information is protected and provide accurate information about our Company. In doing so, we ensure we are communicating responsibly and protecting our reputation.

Refrain from speaking on behalf of Mazda. Though your intentions might be good, you could harm Mazda by speaking on behalf of the Company. What you say may be misunderstood, or worse, you may accidentally reveal sensitive information or violate our Code of Conduct.

Forward questions. If you receive a question from the media or anyone else outside our Company about a business issue, don’t answer it unless you are authorized to do so. Obtain the name of the person asking the question and refer the person and the question to the Public Relations (PR) representative in your business. The same process applies to requests for us to publish articles, contribute to blogs or speak publicly on Mazda’s behalf.

TV camera filming an event

You might receive requests for information about:

  • New products or processes
  • Our financial position
  • Marketing strategies

Use social media responsibly. We respect your right to use social media, but please do so in accordance with our policies. Make sure that people know that your views are your own and not the opinion of Mazda. Be careful when posting anything online and protect sensitive information of our Company, our partners and your colleagues.

With social media, you’re in the driver’s seat:

  • Use good judgement.
  • Never post anything that could be seen as aggressive or discriminatory.
  • If it is not something you would share at work, then don’t share it online.
  • Be respectful of others.
  • Know that you are responsible for anything that you publish.

BRAKING POINT

Make sure that you never speak on our behalf unless you are authorized to do so. Remember to forward questions from the media to the PR representative in your business.

THIS WAY TO OUR POLICIES

Test your knowledge

Question:

A reporter asked me about one of our new products. I am not authorised to speak on behalf of our Company but I know the answer to the question. Can I answer the reporter?

Choose the correct option (Yes/No)

 Sorry, wrong answer!

You should not respond to the reporter and should refer all media questions to your company’s PR representative.

 That’s right!

You should not respond to the reporter and should refer all media questions to your company’s PR representative.