Compliance

Compliance

Based on our Philosophy and Principles, we have established the Corporate Standards of Conduct and are committed to complying with laws and regulations and to building organizational frameworks for ensuring the continuity of appropriate and fair business activities.
Furthermore, we have formulated the Code of Conduct to ensure that each officer and employee not only complies with laws and regulations but also behaves appropriately in light of social norms. In addition to implementing initiatives that place the highest priority on compliance, we have introduced a compliance officer system, under which a compliance manager is appointed in each department to reinforce compliance in daily operations.

Compliance Framework

Note: We have also established channels for receiving reports from external parties and a framework for responding to any breaches (or potential breaches) according to the nature of each case.

Compliance Initiatives

Internal Regulations

In order to enhance the effectiveness of compliance and to clarify the compliance philosophy, various internal rules and regulations related to compliance have been formulated under the Three Corporate Principles, the Corporate Standards of Conduct, and the Code of Conduct. These internal rules and regulations are revised regularly in response to amendments in laws as well as changes in the business environment surrounding the Group.

Ongoing Initiatives

• Message to employees from management (the Company’s President and Chief Compliance Officer) (annual)
• Meeting of the Compliance Committee (held twice a year and on an ad hoc basis)
• Publication of a compliance newsletter (published four times a year and on an ad hoc basis)
• Compliance discussion for officers and employees on designated themes (annual)
• Compliance training and e-learning (annual)
• Compliance training and related activities conducted through visits to plants and branch offices (annual)
• Establishment, awareness raising, and operational review of the Basic Compliance Rules and related rules (as needed)

Strengthening Collaboration with Subsidiaries and Enhancing the Group-wide Compliance Foundation

We have a scheme in place for addressing any compliance-related issues that may arise at our domestic or overseas subsidiaries, involving reporting of the issue to the Company’s Chief Compliance Officer, investigating its root causes, and formulating and implementing measures to prevent recurrences in a reliable manner. Additionally, through opportunities such as the Subsidiary Compliance Managers’ Liaison Meeting, compliance information concerning the entire Group is shared, and compliance initiatives are rolled out to subsidiaries. Through these efforts, the compliance foundation is strengthened across the Group.

Whistleblowing System (Establishment of Compliance Helpline)

We have established six confidential channels that facilitate the reporting of any compliance violations (or potential violations) and consultations on related issues.

• Compliance Helpline
• Harassment Helpline
• Audit & Supervisory Board Member Hotline
• MCLS Outside Legal Counsel Helpline
• Mitsubishi Corporation Group Outside Legal Counsel Compliance Mailbox and Helpline
• Mitsubishi Corporation’s global whistleblowing system (“LUKS”) dedicated to breaches related to antitrust laws and anti-bribery laws