Corporate Disclosure Policy

In accordance with its core corporate philosophy, the “Three Corporate Principles”, Mitsubishi Corporation (MC) is committed to the fair disclosure of information in accordance with the policy set forth below.

1. Information Covered by This Policy

This policy covers information that is subject to disclosure under applicable laws, regulations, and ordinances (hereafter "applicable laws"). This includes the timely disclosure of information required by the Tokyo Stock Exchange (TSE), as well as disclosures made in accordance with the Financial Instruments and Exchange Act, the Companies Act, and the regulations of both domestic and international stock exchanges.

2. Basic Principles Regarding the Disclosure of Material Information

MC discloses material information in compliance with applicable laws based on the following five principles:

  1. Transparency:

    MC shall disclose information in a factual manner, regardless of the content.

  2. Timeliness:

    MC shall disclose information promptly, without delay, following occurrences that warrant disclosure.

  3. Fairness:

    MC shall distribute information fairly to our various stakeholders.

  4. Continuity:

    MC shall maintain continuity in the content of information disclosures.

  5. Confidentiality:

    MC shall not provide information to third-parties before it has made an official disclosure.

3. The Structure and Role of the Disclosure Committee

MC has established a Disclosure Committee as a subcommittee under the Executive Committee. The Disclosure Committee deliberates and submits opinions regarding MC’s disclosure policies, including the content and scope of disclosures, and shares relevant information regarding the disclosure of information that requires careful consideration.

The Disclosure Committee is chaired by the Chief Financial Officer (CFO), with the Chief Stakeholder Engagement Officer (CSEO) as vice-chairman. The head of the corporate strategy & planning department and the head of the corporate staff section are committee members, and there is also a committee secretariat. When needed, and at the committee chair's discretion, representatives from relevant company departments may be asked to join committee meetings as appropriate.

4. Framework for Disclosure of Material Information

The framework for the disclosure of information in accordance with applicable laws is as follows:

  1. Timely Disclosure of Information

    At MC, the Chief Stakeholder Engagement Officer (CSEO) is responsible for the timely disclosure of information, and he or she designates the head of the corporate communications department to be the person in charge of managing such information on a day-to-day basis. As the department in charge of the timely disclosure of information, the corporate communications department shall promote internal awareness regarding the importance of timely disclosures. Each company department shall promptly report to, or consult with, the corporate communications department regarding any information within their organization or affiliated subsidiaries that they believe qualifies as information requiring timely disclosure. The head of the corporate communications department shall confirm whether the information reported requires timely disclosure, and proceed with the necessary disclosure as appropriate.

  2. Other Disclosures

    Specific executive officers and departments are responsible for the disclosure of the information listed below. The lead department shall, in consultation and discussion with other relevant departments, make necessary disclosures in accordance with applicable laws.
    1. Disclosures based on the listed security regulations set by the TSE.
    2. Disclosures based on the Financial Instruments and Exchange Law.
    3. Disclosures based on the Japanese Commercial Code.
    4. Disclosures based on regulations at overseas stock exchanges, etc.
    5. Disclosures based on other applicable laws.

5. General Rules for Disclosure of Information

  1. Market Rumors

    In general, MC shall not respond to inquiries regarding market rumors. However, this rule does not apply if it is determined that there could be serious ramifications on the company, in which case appropriate measures will be taken.
    • Note 1:
      Article 158 of the Financial Instruments and Exchange Law prohibits the spreading of market rumors for the purpose of a public security offering, conducting any transaction of securities, or for the purpose of causing the market fluctuation of a security.

  2. Quiet Period

    MC shall not provide any comments on inquiries regarding its earnings, future outlook, and shareholder returns during the three weeks prior to the announcement of its earnings results (quarterly or annual). However, this rule does not apply in cases where the disclosure of information is required by applicable laws, such as when an event occurs that is the subject of a timely disclosure of information, or if an extraordinary report is required by the TSE.
    • Note 2:
      During the quiet period, MC shall refrain from responding to those questions to ensure fairness and prevent the leakage of earnings-related information. However, MC shall respond to questions regarding information that has already been made public during the quiet period.

  3. Prohibition of Selective Disclosure

    Selective disclosure is the disclosure of material, non-public information to an individual or group prior to its public release. MC prohibits selective disclosure unless the people or groups to whom the non-public information is disclosed are covered by confidentiality or non-disclosure agreements.

  4. Revisions to this Corporate Disclosure Policy

    Any revisions to this Corporate Disclosure Policy must be deliberated and authorized by the Disclosure Committee. However, minor revisions may be proposed by the committee secretariat and submitted to the Disclosure Committee chair for approval.

(Revised on April 1, 2025)