Mitsubishi Corporation

Compliance

MC has long engaged in creating a framework to ensure that it continues to conduct proper and fair business activities, in addition to upholding legal and regulatory compliance. This long-standing commitment is based on the Three Corporate Principles, which encapsulate our corporate philosophy, and is stipulated in our Corporate Standards of Conduct.

In September 2000, we formulated a Code of Conduct, and we are obligated to make compliance our top priority and ensuring legal and regulatory compliance by each and every employee, as well as instilling an awareness of proper conduct that reflects social norms.

In another initiative, we introduced the Compliance Officer post and compliance officers have been appointed in all business groups and all regions in Japan and overseas. These people work to foster compliance in daily activities.

Compliance Framework

As of the fiscal year ended March 2010, all officers and employees have been required to take e-learning courses, which include case studies on the Code of Conduct and to sign an agreement stating that they understand and will adhere to the rules at all times. These protocols have since been introduced at MC's subsidiaries. Furthermore, we conduct various activities such as compliance-related in-house seminars, holding Compliance Discussions to encourage personnel to discuss compliance issues in each work place by using case studies (i.e. possible violations in view of the office operation), distributing "Compliance Case Study Q&A Booklets" and launching the Global Whistleblowing System so as to instill awareness of compliance in each and every officer and employee of MC and MC's subsidiaries.

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