Mitsubishi Corporation

Internal Control System

The demands on companies seeking to fulfill their corporate social responsibilities are growing amid major changes in the business environment such as globalization and rising interest in the natural environment. In light of this, Mitsubishi Corporation is continuously working to improve and strengthen its management system (internal control system) so as to ensure business activities are conducted properly to raise its corporate value and to fulfill its social responsibilities.

Specifically, Mitsubishi Corporation has built a system for ensuring that business operations are conducted properly and efficiently (systematic management execution, formation of a rational organization, clarification of the organizational chain of command, risk management, etc.) while ensuring the reliability of corporate information disclosure (financial reporting) and adherence to laws and regulations and social norms (compliance). Mitsubishi Corporation monitors the status of operation of this system every year and the Board of Directors verifies improvements.

The internal control system is increasing in importance for management of the Mitsubishi Corporation Group because of the larger number of business investees, diversifying business models and other factors. In this context, the Executive Vice President in charge of Audits and Internal Control is working together with the corporate auditors, independent auditors and other parties to develop an internal control promotion system for ensuring proper business conduct.

BCP (Business Continuity Plan)

MC engages in rigorous crisis management on a consolidated basis, including individual MC Group companies, in light of the increasing diversity and complexity of risk that accompanies business expansion.

BCP refers to an action plan formulated in advance with the aim of preventing the stoppage of important company operations or restoring and restarting them in as little time as possible if they are interrupted by the occurrence of an unexpected event such as a natural disaster or incident. MC has formulated BCPs for different types of crisis such as natural disasters, new infectious diseases, international or political problems, and incidents. MC will immediately initiate its BCP in the event of such a crisis and work to ensure the continuity of important operations at the very least and to quickly restore operations.

Compliance

Compliance Framework

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 all officers and employees are required to carry a booklet containing this code. In addition, every year all officers and employees are required to sign a written commitment to this Code after completing an e-learning program in which they study examples related to the Code of Conduct. Through these measures, we are 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. We conduct various activities so as to instill awareness of compliance issues in each and every officer and employee of MC and MC's subsidiaries and affiliated companies. For example, in July 2012, we brought together the managing directors of MC's subsidiaries and affiliated companies for a compliance seminar.

The compliance activities of all officers and employees are the basis upon which we conduct all our corporate activities, as well as one of the most important strategies for raising corporate value on a consolidated basis. From the base of the compliance activities conducted thus far, we will continue to upgrade and reinforce compliance initiatives that are effective.

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