Compliance: Initiatives
Initiatives
Initiatives for Preventing Corruption
MC has established the “Code of Prohibition Against Improper Payments or Other Types of Benefits” to prevent the provision of improper benefits to domestic and foreign public officials, etc. (including persons deemed public officials under applicable laws, etc.), and to avoid conduct that could appear suspicious or untrustworthy to third parties. MC also complies with anti-bribery laws and regulations in 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 defines and sets compliance requirements for bribery, conflicts of interest, and other forms of misconduct. To date, no bribery risks have been assessed as high risk. Furthermore, MC has implemented a strict anti-corruption system and pre-approval process for activities such as providing entertainment or gifts to public officials, appointing agents or intermediaries, accepting internships for relatives of public officials, and making donations to governments or their enterprises. Internal anti-corruption regulations also require detailed due diligence when accepting workplace training for relatives of public officials, etc., or providing donations to government entities. In addition, MC has introduced guidelines for conducting anti-corruption due diligence on business and other partners. MC continuously reviews and improves its internal rules and regulations, taking into account enforcement trends, proceedings by anti-corruption regulators, and measures adopted by other companies.
In 2016, to build a more effective anti-corruption system, MC conducted a comprehensive assessment of its anti-corruption framework by external experts. Based on their evaluations and recommendations, MC remains committed to continuous improvement and effective operation of its systems. That same year, MC created the Anti-Corruption Handbook, which provides accurate information on anti-corruption laws, regulations, enforcement cases in major countries, and MC’s own programs and initiatives. The handbook has been distributed throughout MC.
In 2019, MC adopted a risk-based anti-corruption system that allocates resources according to transaction types, scales, and corruption risk levels in applicable countries. Relevant guidelines were revised to strengthen consolidated measures for preventing bribery and corruption. Through these rules and guidelines, MC works to deter compliance violations and limit opportunities for unethical behavior, including prohibiting inappropriate contact with public officials, etc.
In FY2024, there were no bribery or corruption cases that had a significant impact on MC.
Initiatives in Selecting and Managing Agencies, Intermediaries, etc.
In addition to preventing corruption by officers and employees, MC has established internal regulations to prevent corruption by any agents, consultants, intermediaries, etc. retained by MC (hereafter collectively referred to as “Agents”). These regulations require officers and employees to obtain prior approval from the relevant Compliance Officer before retaining suitable Agents. Since FY2019, MC has introduced new internal approval procedures for retaining Agents based on a risk-based approach, considering factors such as the nature of services to be provided, project size and purpose, and the level of risks, including corruption risk in the relevant countries. In FY2023, MC further reviewed application forms and the approval procedure itself. These procedures are reviewed annually as described in the above.
- Agents are categorized into two groups based on factors that include the nature of their services and the relevant country to determine the level of due diligence required, focusing on the following points.
- Agents must have no relationship with public officials who could influence business transactions or dealings sought by MC, must have a good compliance track record, possess necessary qualifications, and demonstrate capability to provide the services.
- The adequacy of remuneration for services provided by Agents must be thoroughly assessed.
- Contracts with Agents must include clauses prohibiting the provision of improper benefits to public officials, etc., and require Agents to be informed of MC Group’s Anti-Corruption Guidelines.
Mitsubishi Corporation Group’s Anti-Corruption Guideline
In 2015, MC established and published the “Mitsubishi Corporation’s Anti-Corruption Guideline” to inform business partners of MC’s basic principles for preventing corruption. The Guideline explains MC’s anti-corruption policies and initiatives as "MC's commitment" and expects business partners to adhere to these principles. In April 2019, to further strengthen its anti-corruption efforts, MC expanded the scope of the Guideline to cover the entire MC and announced the new “Mitsubishi Corporation Group’s Anti-Corruption Guideline.” This updated Guideline not only includes MC’s commitments but also requests that all business partners and clients (including suppliers) prohibit bribery, communicate anti-corruption policies, and cooperate with investigations when concerns about violations arise.
Cases of Corruption
In FY2024, no corruption cases were detected at MC. As a result, no fines or financial penalties related to corruption were incurred.
Internal Whistleblowing System
MC has established internal whistleblowing systems, known as the “Meyasubako (Compliance Mailbox and Helpline)”. These systems allow reporting or consultation on compliance-related questions or issues, including workplace misconduct, harassment, violations of laws and regulations, and bribery or 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 Department and the Audit & Supervisory Committee Members. In addition, MC provides a whistleblowing route connecting to outside legal counsel, called the “Bengoshi Meyasubako (Outside Legal Counsel Compliance Mailbox and Helpline),” for officers and employees who wish to have more anonymity. While outside legal counsel confirms whether the informant is an MC officer or employee, they do not disclose the informant’s name or section to the Administration Office without consent. For subsidiaries in Japan, there is an additional route called the “MC Group Legal Counsel Compliance Mailbox and Helpline.” Furthermore, MC operates a whistleblowing system for anti-trust and corruption issues called “Let Us Know System (LUKS)”, available to officers and employees of MC and its domestic and overseas subsidiaries 24 hours a day, 365 days a year, in multiple languages (Japanese, English, French, Spanish, Chinese, Thai, Indonesian, etc.).
Our internal regulations clearly stipulate protection of informant anonymity and confidentiality, uphold informant’s rights, and prohibit retaliation or disadvantageous treatment. Violations of these regulations may result in disciplinary action. Investigations are conducted to avoid conflicts of interest, and MC complies with whistleblower protection laws in each country, including Japan’s Whistleblower Protection Act. After receiving a report, the Administration Office shares details only with personnel who need the information to investigate and take action. MC invites external instructors to train those responsible for handling whistleblowing reports on proper investigation practices. In FY2020, MC engaged external experts to assess the effectiveness of its whistleblowing systems. In FY2022, following revisions to the Whistleblower Protection Act, MC updated its whistleblower standards, distributed a response manual to investigators, and conducted video training for all officers and employees in Japan. These systems are continuously reviewed. Regarding management-level harassment training, MC provides internal training aimed at general managers, team leaders, and other levels, using case studies. Furthermore, MC publicizes internally that: (1) the prohibition of harassment is stipulated in the Code of Conduct; (2) basic policies, pamphlets, and other resources have been created to prevent harassment; and (3) whistleblowing systems and the Human Rights Consultation Desk in the Human Resources Department are available for support.
In FY2024, there were no whistleblowing reports that had a significant impact on MC’s management.
Number of reports received through Whistleblowing Systems
In FY2024, MC received a total of 59 reports, including those submitted to operating companies. Of these, 27 were related to harassment and 32 concerned other issues (occupational health and safety, labor management, etc.).
In FY2024, none of the reported cases had a significant impact on MC’s management.
Please refer to the ESG Data at the link below for data on the number of reports received through whistleblowing systems.
Supervision by the Board of Directors
Each year, the Board of Directors supervises the development of internal rules and regulations, including the Code of Conduct for Officers and Employees, the progress of various compliance training programs, anti-corruption initiatives, the results and status of compliance violation cases, and compliance programs and measures planned for the current fiscal year. In addition, Independent Directors and Independent Audit & Supervisory Committee Members receive reports twice a year on compliance activities, enabling them to provide more effective oversight from an external perspective.
PDF booklet “Mitsubishi Corporation Compliance Report”
Please also refer to our PDF booklet “Mitsubishi Corporation Compliance Report,” for details on our compliance activities.