Initiatives
Initiatives for Preventing Corruption
MC has established the “Code of Prohibition against Improper Payments or Other Types of Benefits” in order to prevent provision of improper benefits to domestic and foreign public officials, etc. (including persons who are deemed to be public officials under applicable laws, etc.), and prevent conducts from being seen as suspicious or untrustworthy by third parties. MC also complies with the anti-bribery laws and regulations of various countries, including Japanese criminal law and the Unfair Competition Prevention Act, the U.S. Foreign Corrupt Practices Act and the U.K. Bribery Act. The MC Code of Conduct stipulates definitions and compliance requirements for bribery, conflicts of interest, and other forms of misconduct. No bribery risks have as yet been assessed as high risk. Furthermore, MC has established a strict anti-corruption system and pre-approval process for provision of entertainment or gifts to public officials, appointment of agents/intermediaries, acceptance of internships for relatives of public officials, and donation to governments and their enterprises. In addition, MC has established internal anti-corruption regulations requiring detailed due diligence when accepting workplace experience training for relatives of public officials, etc., as well as providing donations to government and public officials. We have also introduced guidelines to conduct anti-corruption due diligence on our business and other partners. MC continuously and periodically reviews and improves its internal rules and regulations taking into account the trends of the enforcement and proceedings brought by anti-corruption regulators, and anti-corruption programs/measures taken by other companies.
In 2016, aiming to build a more effective anti-corruption system, MC conducted a thorough assessment by external experts regarding its entire anti-corruption systems. Utilizing the experts’ evaluations and recommendations, MC is committed to continuously improving its anti-corruption systems and ensure that they operate effectively. Moreover, in 2016, MC created the Anti-Corruption Handbook to provide accurate information about anti-corruption, including information about laws and regulations, and enforcement cases relating to the bribery and corruption in major countries. The handbook also explains MC’s programs, systems and other initiatives to prevent bribery and corruption. The handbook has been distributed throughout the MC Group.
In 2019, MC adopted a risk-based anti-corruption system that devotes appropriate attention and resources depending on the types and scales of transactions and the level of corruption risks in applicable countries, and revised relevant guidelines accordingly to build a system to prevent bribery/corruption on a consolidated basis. Through the implementation of these rules and guidelines, MC is working to deter compliance violations and limit opportunities for unethical behavior, such as prohibiting contact with related public officials, etc.
In FY 2023, there were no bribery or corruption cases which had a significant impact on the MC Group.
Initiatives in Selecting and Managing Agencies, Intermediaries, etc.
In addition to preventing corruption by officers and employees, MC established internal regulations to prevent corruption by any agents, consultants, intermediaries, etc. retained by MC (hereafter collectively referred to as “Agents”). The internal regulations require officers and employees to obtain prior approval from the relevant Compliance Officer to retain suitable Agents. From FY2019, MC introduced new internal approval procedures for retaining Agents on the basis of the risk based approach depending on the nature of the relevant services to be provided by the Agents, the size and purpose of projects, and the level of risks, including the level of the corruption risk of the relevant countries. In FY2023, MC further reviewed application forms as well as the approval procedure itself. These procedures are reviewed annually as described in the above.
- Agents are categorized into three categories based on the nature of the services to determine the level of due diligence on the Agents on the points below.
- Agents shall have no relationship with any public officials who would be able to influence on the business transactions and dealings which MC seeks, shall have good track record on the compliance matters in the past, have necessary qualifications and have capabilities to provide the services.
- The adequacy of the amount of remunerations for the services to be paid to Agents shall be thoroughly assessed.
- Contracts with Agents shall include clauses that prohibits the provisions of improper benefits to public officials, etc., by the Agents, and the Agents shall be made aware of MC Group’s Anti-Corruption Guidelines.
Mitsubishi Corporation Group’s Anti-Corruption Guideline
In 2015, MC established and published “Mitsubishi Corporation’s Anti-Corruption Guideline” in order to inform business partners of MC’s basic principles related to the prevention of corruption. In the Guideline, MC explains its anti-corruption policies and initiatives as "MC's commitment" and expects business partners to adhere to MC’s anti-corruption initiatives. In April 2019, in order to further strengthen its anti-corruption initiatives, MC expanded the scope of the Guideline to cover the entire MC Group and announced the new “Mitsubishi Corporation Group’s Anti-Corruption Guideline.” The new Guideline not only includes commitments of the MC Group, but also requests that all business partners and clients (including suppliers) of MC Group prohibit bribery, inform anti-corruption policies, and cooperate with investigations when there are concerns about violations.
Cases of Corruption
In FY 2023, there were no corruption cases detected in MC. As a result, no fines or financial penalties relating to the corruption were incurred.
Internal Whistleblowing System
MC has established internal whistleblowing systems, known as the “Meyasubako (Compliance Mail Box and Helpline)”. These systems are used to report or consult on any compliance-related questions or issues, including workplace misconduct and harassment, violations of laws and regulations, as well as bribery and corruption. Reports to the Meyasubako are sent directly to the Administration Office for the Compliance Committee. MC has also established whistleblowing reporting routes to the Internal Audit Dept. and the Audit & Supervisory Committee Members. In addition, MC has established a whistleblowing reporting route connecting to outside legal counsel (called the “Bengoshi Meyasubako (Outside Legal Counsel Compliance Mail Box and Helpline)” for officers and employees who wish to remain anonymous. While the outside legal counsel will confirm whether the informant is an officer or employee of MC, they will not reveal the informant’s name or the section to which the informant belongs to the Administration Office for the Compliance Committee without the informant’s consent. In addition to these internal whistleblowing systems, MC has another whistleblowing reporting route called the “MC Group Legal Counsel Compliance Mail Box and Helpline” for officers and employees of MC Group companies. Furthermore, MC operates a new whistleblowing system for anti-trust and corruption issues called “Let Us Know System (LUKS)”, which is available to officers and employees of MC and its domestic and overseas subsidiaries 24 hours/day and 365 days/year in multiple languages (Japanese, English, French, Spanish, Chinese, Thai, Indonesian, etc.).
Our internal regulations clearly stipulate that we will protect the anonymity and confidentiality of the informant and the report content, uphold the informant’s rights, and prohibit retaliation or disadvantageous treatment towards the informant. Violation of these regulations may result in disciplinary action. Moreover, when investigating the reported matters, MC is sure to avoid any conflicts of interest. MC has also established a system to comply with the whistleblower protection laws of each country, including the Whistleblower Protection Act in Japan.After receiving details of a whistleblowing report, the Administration Office for the Compliance Committee will share the information only with limited number of personnel who need to know the content to conduct the investigation and take related action. Every year, we invite outside instructors to provide training to those in charge of investigating and responding to whistleblowing reports on how to handle and investigate the reports and points to keep in mind. While we have set up multiple whistleblowing reporting routes as briefly described in the above, in FY2020, we engaged external experts to assess the effectiveness of our whistleblowing systems and their operation. In FY2022, in accordance with the revision of the Whistleblower Protection Act, MC revised its whistleblower standards, distributing a response manual to those in charge of investigating and responding to whistleblowing cases, and conducting video training for all officers and employees in Japan. MC’s whistleblowing reporting systems are reviewed continually as described in the above. With regard to management-level harassment training, MC conducts internal training aimed at general managers, team leaders and other levels. MC is working to prevent harassment by introducing case studies. Furthermore, each of the following is well-publicized internally: (1) the prohibition of harassment is stipulated in the Code of Conduct; (2) basic policies, pamphlets and other resources have been produced to prevent harassment; and (3) the Whistleblowing Systems as well as the Human Rights Consultation Desk in the Human Resources Department have been established.
In FY 2023, there were no whistleblowing reports which had a significant impact on the management of the MC Group.
Number of reports received through Whistleblowing Systems
In FY2023, MC received a total of 60 reports, including Whistleblowing Reports to MC Group companies, of which 31 were related to harassment and 29 were related to other issues (occupational health and safety, labor management, etc.).
In FY 2023, no reported cases had a significant impact on the management of the MC Group.
Please check the link below for data on Number of reports received through Whistleblowing Systems.
Supervision by the Board of Directors
Every year, the Board of Directors supervises the development of relevant internal rules and regulations including the Code of Conduct for Officers and Employees, the progress of various training programs compliance matters such as anti-corruption initiatives, the results and status of compliance violation cases, and the compliance programs and measures to be implemented in the current fiscal year. In addition, both Independent Directors and Independent Audit & Supervisory Committee Members receive reports twice a year regarding compliance activities, so that they can provide more effective supervision from their external perspectives.
pdf booklet “Mitsubishi Corporation Compliance Report”
Please also refer to our pdf booklet “Mitsubishi Corporation Compliance Report” for our compliance activities.