Biodiversity: Structure

The Chief Stakeholder Engagement Officer (CSEO) oversees sustainability initiatives, including nature-related dependencies, impacts, risks, and opportunities, as well as MC’s responses to them. Basic policies and initiatives are deliberated by the Sustainability Committee and subsequently submitted to, or reported to, the Executive Committee, which serves as the Company’s primary management decision-making body. In accordance with the regulations of the Board of Directors, these matters are regularly submitted to, or reported to, the Board of Directors (approximately once a year), ensuring appropriate Board-level oversight of natural capital.

To further promote sustainability initiatives within each Business Group, the officers responsible for business strategy formulation in each group have been appointed as Group Chief Sustainability Officers. These officers are responsible for sustainability matters, including nature-related initiatives, thereby strengthening the integration of nature-related considerations in our business strategies and operations.

In addition, MC has established the Sustainability Roundtable as a forum for dialogue between external experts and the Group Chief Sustainability Officers on sustainability topics, including natural capital. Insights gained through these discussions are incorporated into policy formulation, business promotion, and internal decision-making processes.

With respect to decision-making for investment and financing proposals, the General Manager of the Sustainability Department serves as a member of the Investment Committee and provides input to ensure that deliberations reflect basic policies and key considerations related to natural capital. This framework enables the Company to make informed decisions grounded in specialized expertise.

Please refer to the following for details on the oversight and management process for natural capital in FY2026.

In addition, please refer to theVoting Results of 2024 Ordinary General Meeting of Shareholdersfor information on the Board Skills Matrix. For details on the consideration of sustainability factors in executive remuneration, please refer toGovernance (Remuneration for Directors, etc.).

MC believes that respect for human rights is fundamental to our business activities worldwide, and we promote initiatives to uphold human rights in accordance with ourHuman Rights Policy.
To identify and analyze potential negative impacts of our business activities on human rights and the environment, we conduct sustainability surveys of our subsidiaries and affiliates, as well as individual dialogues with stakeholders. These processes enable us to identify and assess issues related to the human rights and environmental conditions of stakeholders involved in our business and to ensure that identified impacts are addressed appropriately. Through these efforts, we are strengthening initiatives to respect human rights and protect the environment across the MC.

When reviewing new investment proposals, we conduct a comprehensive screening process that considers not only economic factors but also human rights and environmental perspectives. In addition, recognizing the potential impacts of business operations on the rights of Indigenous peoples, we engage in dialogue with relevant stakeholders from the business evaluation stage through to post-investment.

MC supports the United Nations Declaration on the Rights of Indigenous Peoples and the Indigenous and Tribal Peoples Convention (ILO Convention No. 169). In business operations conducted in regions where Indigenous peoples reside, we acknowledge their distinct cultures and histories and respect their rights in accordance with the laws and international frameworks of the countries and regions in which we operate. Furthermore, through the Mitsubishi Corporation Policy for Sustainable Supply Chain Management, we request that our suppliers respect human rights and give due consideration to local communities and ecosystems.

To identify and assess nature-related issues associated with our businesses, MC conducted a trial analysis from FY2022 to FY2023 based on the beta version of the TNFD framework, focusing on businesses with high dependencies and impacts on nature. The results of this analysis were disclosed accordingly. Following this trial analysis, we engaged in dialogue with stakeholders and received valuable feedback. Stakeholders requested that we incorporate financial impacts and conduct analysis and disclosure that enable a companywide evaluation.

Based on this feedback, beginning in FY2024 we identified the key assets and geographic locations of financially material subsidiaries and affiliates and evaluated the surrounding natural environment and disaster risks (Locate). We also conducted a heatmap analysis to assess materiality from a natural capital perspective, including dependencies and impacts on nature across the value chain (Evaluate). For businesses identified as having both financial materiality and materiality from a natural capital perspective, we identified and assessed risks and opportunities (Assess) and conducted hearings on countermeasures and target setting (Prepare).

MC recognizes the growing importance of treating sustainability information not merely as non-financial information, but as sustainability-related financial information. In selecting the scope of this TNFD analysis, and with reference to the sustainability disclosure standards of the Sustainability Standards Board of Japan (SSBJ), we identified Head Office businesses, subsidiaries, and affiliates that are financially material to the Company^*1 (hereinafter referred to as the "Target Businesses") from a financial materiality perspective.
Because financially material businesses tend to operate at a larger scale and generally have relatively greater impacts on nature, we believe that this approach is also consistent with the concept of impact materiality.

We identified the key assets and geographic locations (latitude and longitude) of the Target Businesses. Using TNFD-recommended tools to assess the surrounding natural environment, together with additional tools for evaluating climate-related physical risks, including heat stress, typhoons, storm surges, river flooding, and forest fires^*2, we assessed natural environmental conditions and disaster risks. Please refer to the following for the distribution map of key assets.

For the Target Businesses, we used TNFD-recommended tools such as ENCORE to assess dependencies and impacts on nature across the value chain and visualized the results in a heatmap. Specifically, dependencies on nature were evaluated across 25 types of ecosystem services, including water supply, climate regulation, and flood mitigation. Impacts on nature were assessed across 13 types of impact drivers, including water use and pollutant emissions. Each dependency and impact was scored using a six-level scale, enabling the identification of ecosystem services with high dependency and impact drivers with high impact. Based on this assessment, we identified key nature-related topics relevant to our subsidiaries.

The heatmap below presents the analysis results by Business Group. Given the diversity of our business, material nature-related issues vary across businesses and operating companies. However, through a holistic analysis of our financially material businesses and assets, we identified that MC has relatively high dependencies on water resources and natural disaster mitigation. We also identified the need to pay particular attention to our climate-related impacts, including GHG emissions, pollution, land-use change, and waste.

We identified Target Businesses that are susceptible to the nature-related topics identified in the Evaluate phase by combining the assessment results of key assets from the Locate phase with the dependency and impact evaluations from the Evaluate phase. These businesses were positioned as material from a natural capital perspective. Based on this positioning, we developed a longlist of general industry risks and opportunities by referencing TNFD sector guidance, peer disclosures, and actual cases of risk materialization identified through external tools^*3. The longlist comprised approximately 200 items across eight Business Groups, with roughly 20 to 40 items per Group. For each item on the longlist, we evaluated financial materiality and likelihood of occurrence using a five-point scale. Taking both factors into account, we then assessed the potential financial impact using a quantitative scoring methodology.
Subsequently, we screened and consolidated the longlist of general industry risks and opportunities from a financial impact perspective. This process was conducted in consultation with the relevant departments, subsidiaries, and affiliates of the Target Businesses. The resulting items were categorized in accordance with the European Sustainability Reporting Standards, which are highly interoperable with the TNFD framework, and compiled into a shortlist of financially material risks and opportunities.

In assessing financial impacts, we adopted a Business-As-Usual (BAU) scenario, defined as a scenario in which current conditions continue, as the assumed future state. While TNFD guidance on scenario analysis recommends considering multiple scenarios using a forecasting approach, MC’s business portfolio is highly diverse, and the relevant scenarios under a forecasting approach differ across Business Groups. In addition, the use of extreme scenarios may result in the overestimation or underestimation of risks and opportunities due to excessive reliance on scenario assumptions. Based on these considerations, we determined that the BAU scenario provides an appropriate foundation for enabling each Business Group to conduct assessments from a practical perspective, while reducing the risk of overlooking material risks and opportunities.

Short term:
Define as the period up to the next fiscal year. This time horizon is already reflected in strategic decision-making processes, including business planning, which is primarily conducted on an annual basis, and investment decisions. It is also incorporated into current financial planning.

Medium and long term:
Based on the Guidance on Nature Transition Plans published by TNFD in November 2025, MC recognizes the need to pursue a transition aligned with the Kunming-Montreal Global Biodiversity Framework (GBF). Taking into account the GBF’s objective to halt and reverse biodiversity loss by 2030 and to restore nature by 2050, we define the medium term as the period up to 2030 and the long term as the period up to 2050.

For the shortlist of 26 risk and opportunity items identified in the Assess phase, we reviewed the current management structures, responses, and initiatives implemented by each Target Business. As a result, we found that measures have already been implemented by 77 percent of subsidiaries for the identified risks and by 53 percent for the identified opportunities.
The responses to risks and opportunities identified through this process were categorized into the following action types: Transform, Restore and Regenerate, Reduce, Avoid, and Other. These categories are based on a framework^*4 that indicates the priority of actions for managing negative impacts on nature and maximizing positive contributions.

Based on this assessment, MC will continue to promote initiatives to address nature-related risks and opportunities as outlined below.

While many opportunities require decision-making that takes into account external conditions, MC is already pursuing a number of opportunity-driven initiatives through its existing businesses. We will continue to work in collaboration with our Business Groups to maximize such opportunities. Examples include seawater desalination projects at copper mines, as well as recycling and closed-loop business initiatives.
In addition, as part of our measures to expand opportunity creation efforts, MC is promoting the transition to a circular economy. To monitor external trends and take timely action through our networks, we participate in public-private partnership platforms such as Circular Partners and the Japan Partnership for Circular Economy (J4CE). Through initiatives including material recycling using new technologies, recycled PET manufacturing, and the secondary use of EV batteries, we aim to reduce our environmental footprint on natural capital.

As part of our risk mitigation measures, MC requires the assessment of environmental and social risks and opportunities when reviewing and making decisions on investment and financing projects. This assessment includes scenario analysis and carbon pricing impact analysis for businesses with significant potential impacts, as well as human rights and environmental due diligencefor applicable proposals.

In addition to the disaster risk analysis conducted through the TNFD analysis process described above, we also analyze the potential impacts of climate-relatedphysical riskson MC’s businesses. Where appropriate, we procure insurance coverage for natural disasters. For financially material businesses and sites, we establish and operate Business Continuity Management (BCM) frameworks and Business Continuity Plans (BCP) to enhance operational resilience.

Beyond self-assessments of businesses in which MC is directly involved, we also implement risk management measures across our supply chains, which support our business activities. From the perspective of sustainable supply chain management, MC works with external experts to identify products handled by MC that pose relatively higher environmental and social risks and designates them as products to be monitored. For suppliers of these products, we conduct an annualSustainable Supply Chain Surveyto confirm their level of compliance with the Mitsubishi Corporation Policy for Sustainable Supply Chain Management. This supply chain survey has long addressed not only human rights issues but also environmental matters, and it is also used as a tool for assessing environmental risks within the supply chain.

Through our TNFD analysis, we identified opportunities to strengthen MC's response to nature-related risks. For risks that have not yet been addressed, we will promote action through annual engagement with each relevant Target Business. We aim to achieve the initiation of risk response measures by 100% of subsidiaries by 2030 (FY2025: 77%).

Many of the risks identified in the Assess phase are related to climate change. Accordingly, MC will work in parallel to achieve the targets set forth in theClimate Changesection of our Sustainability Website.
In addition, the risks identified in the Assess phase include those related to ecosystems such as forests and oceans. The products handled by MC include soybeans, coffee beans, cacao beans, and tuna. Through engagement with stakeholders, we recognize the importance of implementing risk management not only for MC’s non-consolidated trading activities but also across the supply chains that support these business. In collaboration with suppliers, MC has therefore formulated individual procurement guidelines and established procurement targets for these products.

Please refer toSupply Chain Management : Policyfor details.

In addition, MC discloses selected TNFD Core Global Disclosure Metrics on this page and on our Sustainability Website. Please refer to the corresponding table below.

The general requirements for this disclosure are as follows: