Compliance: Performance

Performance

Results of Compliance Training

MC conducts in-house training programs on a company-wide basis according to organization levels. Compliance-related training is also offered on individual topics such as antitrust laws, the Subcontract Act, prevention of bribery and corruption (including anti-bribery laws), and labor management. Additionally, tailored seminars are held for each Business Group and region. MC has developed an e-learning program related to the MC Code of Conduct, incorporating the latest developments and case studies on topics such as harassment, bribery, and whistleblowing systems. To review the permeation and effectiveness of compliance based on the MC Code of Conduct, all MC officers, employees, advisors, part-time employees, secondees, and temporary staff are required to complete this e-learning program annually.

Compliance Discussions

Since 2013, MC has held compliance discussions in which small groups of employees at each workplace discuss potential compliance issues and day-to-day concerns. These discussions supplement conventional training, which tends to be one-way, and help improve compliance awareness among all officers and employees. By facilitating discussions on familiar topics, employees recognize that compliance is personally relevant, gradually increasing awareness. MC conducts these discussions at least once a year, involving nearly all employees at every organizational level, including overseas offices, and has expanded the initiative to over 100 domestic and overseas subsidiaries.

Distribution of Handbook for Officers and Employees

In addition to training and e-learning program, MC has created a Compliance Handbook featuring the latest case studies in a Q&A format. The handbook aims to resolve common compliance-related questions and is distributed to all officers and employees for 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 in FY2024 was 93. There were no compliance violations that had a significant impact on MC’s management.

Provisions Concerning Legal Violations and Litigation

If MC currently owes a 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 (penalties, settlement amounts, etc.) can be made, MC must record provisions for such debt. In FY2023, there were no significant provisions requiring separate disclosure in the 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 complying with tax laws and avoiding tax practices that deviate from the intent of those laws in relevant jurisdictions.
  2. Transparency
    MC is committed to properly reporting and disclosing tax-related information in accordance with tax laws, accounting principles, and other applicable international rules (e.g., OECD Guidelines).
  3. Relationships with tax authorities
    MC seeks to maintain mutual understanding with local tax authorities whenever necessary to ensure proper tax administration in the jurisdictions where MC and its subsidiaries operate.