Compliance : Performance

Performance

Results of Compliance Training

MC conducts in-house training programs on a companywide basis according to each level in the organization. Compliance-related training is offered on individual topics as well such as antitrust laws, the Subcontract Act, prevention of bribery and corruption including anti-bribery laws, and labor management. Furthermore, tailored seminars are held for each Business Group and region. MC has also created an e-learning program related to the MC Code of Conduct based on the latest developments and case studies on topics such as harassment, bribery and whistleblowing systems. MC reviews the permeation and effectiveness of compliance based on the MC Code of Conduct by requiring all MC officers, employees, advisors, part-time employees, secondees and temporary staff to complete this e-learning program on an annual basis.

Compliance Discussions

In 2013, MC began holding compliance discussions in which small groups of employees in each workplace discuss compliance issues that could occur in the workplace as well as other day-to-day concerns. These discussions serve as a means of supplementing conventional training, which tends to be a one-way form of communication, and improving the compliance awareness of every officer and employee. By facilitating these types of discussions about familiar topics in each workplace, every employee will recognize that compliance is something that is connected to them personally, which will in turn gradually increase their compliance awareness. MC has been conducting the same discussions at least once a year, with the participation of essentially all employees at all levels of every internal organization, including overseas offices since 2013, and MC has also expanded this initiative to over 100 domestic and overseas subsidiaries.

Distribution of Handbook for Officers and Employees

In addition to providing training opportunities and the e-learning program, MC has created a Compliance Handbook that presents a collection of the latest case studies in a Q&A format. The aim of this booklet is to resolve any doubts about the compliance duties of officers and employees that they may have on a daily basis, and MC published the booklet to all officers and employees for their easy reference.

Number of Compliance Violations

The total number of violations at the Head Office, domestic and overseas branches and offices, and domestic and overseas subsidiaries and affiliated companies that were reported in FY2023 was 136. There were no compliance violations that had a significant impact on the management of the MC Group.

Provisions Concerning Legal Violations and Litigation

If MC presently owes debt (legal or constructive) as a result of past incidents, is likely to be required to pay such debt, and a reliable estimate of the amount of such debt (penalties, settlement amount etc.) can be made, MC must record provisions for such debt. In FY2023, there were no significant provisions requiring separate disclosure in its financial statements.

Tax Transparency

MC conducts tax affairs in accordance with the following basic principles.

  1. Compliance with laws and regulations
    MC is committed to comply with the Tax Laws, and not to pursue tax avoidance which deviates from the intention of the Tax Laws in the relevant jurisdictions.
  2. Transparency
    MC is committed to report and disclose the tax related information properly, in accordance with the Tax Laws, the accounting principles and the other applicable international rules (e.g. OECD Guidelines).
  3. Relationships with tax authorities
    MC seeks to maintain mutual understanding with the local tax authorities whenever necessary, so that MC and its subsidiaries should be subject to proper tax administration in the relevant jurisdictions where they operate.