Mitsubishi Corporation

Corporate Disclosure Policy

Mitsubishi Corporation (MC) is committed to fair disclosure based on applicable laws and regulations. Disclosure-related matters are handled in accordance with the policy shown below.

1. Information Covered by This Policy

This policy covers "material information" as stipulated by applicable laws and regulations. This includes information related to corporate decisions and occurrence of material fact as stipulated by the Tokyo Stock Exchange (TSE) in accordance with its policies for timely information disclosure and financial statements to be disclosed in accordance with laws such as the Japanese Commercial Code and the Financial Instruments and Exchange Law of Japan, as well as similar types of information.

2. Basic Principles Regarding the Disclosure of Material Information

MC discloses material information based on the following five principles:

  1. Transparency:

    MC discloses information in a factual manner, regardless of the content.
  2. Timeliness:

    MC discloses information promptly, without delay, following occurrences that warrant disclosure.
  3. Fairness:

    MC disperses information fairly to our various stakeholders.
  4. Continuity:

    MC discloses information in a steady, continuous manner.
  5. Confidentiality:

    MC does not provide information to third persons before information has officially been announced by the company.

3. The Structure and Role of the Disclosure Committee

The Disclosure Committee is chaired by the Chief Financial Officer. Vice chairs are Corporate Functional Officers in charge of the Corporate Communications Department, the Corporate Administration Department and the Legal Department as well as the Functional Officer in charge of internal audit and internal control. Certain General Managers from the Corporate Staff Section are also assigned to the Disclosure Committee. When needed, at the committee chair's discretion, related business group departments may be asked to join. A secretariat has also been established within the Disclosure Committee.

This committee debates corporate disclosure policy and shares material and related information. The committee also deliberates and authorizes the appropriateness of content and confines of disclosure related to items such as financial statements, quarterly reports and internal control reports, which are submitted as specified by the Financial Instruments and Exchange Law.

4. Framework for Disclosure of Material Information

The internal framework for disclosing material information (as described above) is as follows:

  1. Timely Information Disclosure in Accordance with the Rules of the TSE

    At MC, the executive officer in charge of corporate communications is responsible for the timely information disclosure, and he or she designates the general manager of the Corporate Communications Department to be the person in charge of managing information on a day-to-day basis. The Corporate Communications Department, as the department in charge of timely information disclosure, works to promote awareness regarding the importance of timely disclosure inside the company. At the same time, each department consults with the Corporate Communications Department about any decisions or occurrences that are thought to have bearing on the decisions of investors.
    The general manager of the Corporate Communications Department proceeds to disclose information after discussion and deliberations with departments concerned regarding the necessity to disclose information and the content to be disclosed.
  2. Disclosure of Information Not Covered by the Rules of the TSE

    Apart from the timely information disclosure stipulated by the TSE (as described above), MC also provides information as required by applicable laws and regulations. Various types of material information, such as those outlined below, are determined by executive officers and individual departments in charge after discussion and deliberation with other relevant departments, and information is then disclosed in accordance with applicable laws and regulations.
    1. (1)Disclosure based on the TSE and listed security regulations (corporate governance report)
    2. (2)Disclosure based on the Financial Instruments and Exchange Law (financial statements, quarterly reports, internal control report, extraordinary reports, security registration statements and documentation related to issuances, etc.)
    3. (3)Disclosure based on the Japanese Commercial Code (business reports, account statements and consolidated account statements, and supporting schedules)
    4. (4)Disclosure based on regulations at overseas stock exchanges, etc. (annual reports, etc.)

5. Other

  1. Market Rumors

    In general, MC does not respond to inquiries regarding markets rumors. However in some case, MC may respond to a rumor when not responding could have serious ramifications for the company.

    Note 1:In provision 158 of the Financial Instruments and Exchange Law, the spreading of market rumors is forbidden when offering a security, conducting any trade in a security or when attempting to impact the market fluctuation of a security.

  2. Quiet Period

    MC does not make statements regarding its financial outlook three weeks prior to the announcement of financial results (quarterly, or annual). However, exceptions may be made when there are occurrences of material fact that should be disclosed in accordance with the TSE's rules for timely information disclosure or extraordinary reports.

    Note 2:During the quiet period, MC will refrain from attending to questions related to earnings, ensure fairness and prevent the leaking of earnings-related information. However, when there are events during the quiet period that may differ significantly from the company's announced earnings forecast, MC will disclose such information as appropriate. That said, MC will attend to questions during the quiet period regarding previously announced information.

  3. Corrections to this Corporate Disclosure Policy

    The Disclosure Committee must deliberate and authorize any corrections made to this Corporate Disclosure Policy. However, for minor corrections, the committee secretariat may make the corrections by attaining the approval of the Disclosure Committee chair.

(June 18, 2010)