Mitsubishi Corporation

Approaches to Internal Control System

The Board of Directors strives to construct an internal control system for increasing corporate value by conducting appropriate, valid and efficient business execution in conformity with laws, regulations and the Articles of Incorporation. Each year, the Board checks on the implementation of the internal control system and makes ongoing improvements and enhancements. Specific activities include establishing a compliance system, ensuring the reliability of disclosure of financial information and other information, forming a rational organization and clarifying the organizational chain of command to ensure systematic management execution, and upgrading risk management systems etc.

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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