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CSR - Compliance

Message from Top Management

The Mitsubishi Electric Group regards "ethics and compliance" as the foundation of corporate management, and issues the following message to all employees as part of its efforts to establish even stronger relationships of trust with society, customers, and stakeholders.

The operating environment continues to undergo dramatic changes. What must continue regardless of how the times may change is respect for corporate ethics and compliance.

Mitsubishi Electric Group formulated "the Mitsubishi Electric Group Corporate Ethics and Compliance Statement" as our basic guideline for compliance, pledging to society that "We will never establish a target, nor make a commitment, that could only be achieved with conduct that would violate applicable laws or business ethics or practices."

Looking toward the upcoming 100th anniversary of our foundation and even the next 100-year milestone, in order to continue to be a corporate group which earns the confidence of society and our customer, I request each and every one of you to be aware again that adherence to ethics and compliance forms the basis for the company to remain in business.

And you must always remember that each and every one of you has a responsibility to ensure that as a good corporate citizen we conduct our business in compliance with applicable laws and high ethical standards in all endeavors: you should have pride in our high level of business ethics.

Our Concept of Compliance

With the Mitsubishi Electric Group Corporate Ethics and Compliance Statement formulated in 2001 as our basic guideline for compliance, the Mitsubishi Electric Group recognizes the importance of ethics and absolute compliance with legal requirements as a fundamental precondition for the Group's continued existence. Based on this awareness, we are attempting to perfect a compliance system which promotes compliance in the broadest sense, encompassing the perspective of corporate ethics, rather than merely focusing on following the letter of the law. At the same time, we are working to educate our employees in this area.

The Corporate Ethics and Compliance Statement

Compliance with the Law We will conduct ourselves always in compliance with applicable laws and with a high degree of sensitivity to changes in social ethics or local practices. We will never establish a target, nor make a commitment, that can only be achieved with conduct that would violate applicable laws or business ethics or practices.
Respect for Human Rights We will conduct ourselves always with a respect for human rights. We will not discriminate based on nationality, race, religion, gender, disability, or any other reason prohibited by applicable laws nor will we violate international laws providing protection for individual and human rights or any treaties providing such protection to which the country where any of our companies is located is a party.
Contributing to Society Concurrently with the pursuit of a reasonable profit, we will conduct ourselves always with an awareness of our corporate social responsibility in order to further the progress of society as a whole.
Collaboration and Harmonization with the Community As a good corporate citizen and neighbor, we will support civic and charitable organizations and activities in the communities where we reside or work that in our view contribute to community development.
Consideration of Environmental Issues As part of our goal to achieve a recycling-oriented society, we will pay attention to and respect the global environment in every aspect of our business.
Awareness of Personal Integrity We will conduct ourselves with the highest integrity, making a proper distinction between public and private matters, and we will use company resources—including money, time, and information—for legitimate business purposes. We will use company computers and various networks and online services, including e-mail and Internet access, primarily for company business.

The Mitsubishi Electric Group Conduct Guidelines

Mitsubishi Electric Group Conduct Guidelines is a uniform code of conduct in which laws and regulations and social norms to be complied with and respected by each employee of Mitsubishi Electric Group in executing company business and performing his/her duties are put together and summarized, and is intended to serve as guidelines for our day-to-day conduct.
These Guidelines were first established in 1990, and became what they are now through multiple revisions based on revisions of relevant laws and regulations, changes to people’s perceptions of social norms and other relevant factors. The version presented here is the most recent revision, published in April 2017.

In addition to the Japanese language, the Code of Conduct is published in English, Chinese, and Thai, and offers identical content for each country and region in which we operate, presenting norms to which every Mitsubishi Electric Group employee should conform.

Ensuring that Employees are Familiar with Our Compliance Policy

The top management of the Mitsubishi Electric Group, including the President, takes every opportunity to directly address employees on the subject of compliance in a diverse range of situations, ensuring that an awareness of the importance of compliance and our stance on it takes root throughout our organization.

To raise awareness even further, we also display posters of the Mitsubishi Electric Group Corporate Ethics and Compliance Statement in our workplaces and distribute cards printed with the Statement to each of our employees.

We distribute the "Mitsubishi Electric Group Conduct Guidelines" to all Mitsubishi Electric Group employees, including overseas employees. Employees in Japan receive a booklet containing the conduct guidelines, which summarizes points that employees should be aware of in relation to compliance as they conduct their work duties.

System to Ensure Thorough Implementation of Compliance at the Global Level

Based on the recognition that the promotion of compliance is inseparably linked with business promotion, the Mitsubishi Electric Group's compliance system is made up of (1) independent compliance systems established in each of our companies and business divisions, and (2) systems which provide support for each specific organization.

We renamed the Legal Division to the "Corporate Legal & Compliance Division" as of October 2012, in order to promote group-wide compliance. Moreover, in each business group of Mitsubishi Electric Corporation, we established a "Compliance Department" whose purpose is to enhance implementation of group-wide compliance measures and conduct inspections of the state of compliance in that respective group. Furthermore, in order to further strengthen and expand previously established overseas compliance systems and ensure thorough compliance at the global level, a special department was established in the Corporate Legal & Compliance Division in April 2014.

1. Independent compliance systems established in each company and business division

The independent compliance systems established in each of our companies and business divisions are systems which function to advance compliance by clarifying the roles of management and every individual affiliated with that company or division, and ensuring that each individual is aware that they are responsible for the promotion of compliance based on the recognition that "the promotion of compliance is inseparably linked with business promotion". In concrete terms, based on a company policy, the management of each company and division guides and supervises staff members and establishes a compliance promotion system in that company or division. To this end, the management implements measures, including the establishment of a Compliance Promotion Committee, to formulate concrete initiatives for the advancement of compliance in that company or division. In addition, each staff member promotes compliance within the scope of his or her particular work duties. Furthermore, each business group in Mitsubishi Electric has its own Group Compliance Department which is responsible for promoting compliance within their respective business groups, based on company-wide compliance initiatives.

2. Systems which provide support for each specific organization

The Corporate Compliance Committee and Compliance Managers are examples of systems which provide support.

The Corporate Compliance Committee formulates comprehensive guidelines for compliance and standards of employee conduct for the Mitsubishi Electric Group as a whole. The Corporate Compliance Committee was established in 1991, the year in which the Japan Business Federation (Nippon Keidanren) formulated its Corporate Conduct Charter. The Corporate Compliance Committee is chaired by an executive officer responsible for legal affairs and holds regular meetings twice annually and extraordinary meetings as required.

A system is in place for details of discussions held by the Corporate Compliance Committee to be disseminated to each company or division of Mitsubishi Electric by Compliance Managers—who are responsible for assisting the management of each company or division—through channels including the Compliance Information Liaison Conference.

Compliance Managers are appointed for specific companies, divisions, or levels, and their particular roles and the details of their activities are explicated in in-house regulations.

Overseas, in addition to the systems of assistance discussed above, we have also established systems to provide assistance spanning entire regions. Regional Compliance Officers ("RCOs") responsible for assisting affiliates in their specific region are assigned in the United States, South and Central America, Europe, Asia, China (including Hong Kong), Taiwan, and Korea, and work to improve the level of compliance by means of Regional Compliance Committees ("RCCs") and others. We are also working to establish similar systems in other regions, depending on the specific circumstances of the region in question.

Initiatives against Major Compliance Risks

Fair competition (preventing the violation of anti-trust laws)

The Mitsubishi Electric Group deeply regrets its experience of having received an administrative penalty for violating anti-trust laws in Japan and overseas. Out of this regret, we uphold anti-trust laws as one of the most important laws that we must abide by, and make ongoing Group-wide efforts to both prevent any recurrence of such incidents and prevent previous incidents from being forgotten.

In addition to formulating and operating internal regulations that govern Mitsubishi Electric and its affiliated companies in Japan and overseas, we have also strengthened internal audits that specialize in anti-trust laws, and place importance on employee training through a combination of e-learning and classroom programs. 
Between fiscal 2014 and fiscal 2016, company-wide intensive training was implemented 241 times with the participation of 11,248 employees. In affiliated companies, training was begun in fiscal 2014 for executives, sales and others departments, and has been attended by 3,556 employees to date. Training has been provided on anti-trust laws overseas as well, through classroom training and e-learning programs. Such programs that have been commonly provided in each region alone have been attended by 9,315 employees in fiscal 2016.

We will continue to make greater efforts to prevent similar incidents from occurring and previous incidents from being forgotten, through regular monitoring of the status of daily business activities and internal regulations, practical employee training that matches actual transaction situations, and other such initiatives.

Corruption prevention (preventing bribery)

The Mitsubishi Electric Group takes measures to prevent bribery involving Japanese and overseas public officials, such as enhancing internal rules, providing employee education, requiring self-inspections, and conducting internal audits.

On April 1, 2017, our Group has established "Mitsubishi Electric Group Anti-Bribery Policy" to reiterate, to people in and outside the group, our policy that, among other things, our group companies, their officers and employees do not offer bribes and do not pursue profits if such profits can be realized only by offering bribes.

In the light of the current global situation where anti-bribery regulations are becoming increasingly tighter, we will continue to enhance measures in each region, and take effective and efficient measures by selecting countries and transactions with particularly high risks of being involved in bribery, to respond to the expansion of our business at a global level.

Support and responses to political activities

The Mitsubishi Electric Group provides support to political activities only upon full consideration of its social standing as defined in its corporate mission, and in compliance with relevant laws and regulations in each country.

For example, when making a political donation in Japan, the Corporate Administration Division screens all cases in detail in accordance with the Political Fund Control Law, and ensures adherence to all internal procedures. Additionally, in public elections, we make every effort neither to infringe on the Public Offices Election Act nor deviate from sound social morals.

Export control

To maintain international peace and security, Mitsubishi Electric Corporation has established and abides by the Corporate Security Export Control Regulation. Based on the regulation, all transactions are closely checked for any inclusion of export controlled items and security concerns related to destination, customers, end-use, and transaction conditions, and are strictly managed pursuant to relevant laws and regulations. Furthermore, to ensure all associated companies in Japan and overseas also take proper action in line with the Group’s policies, we distribute the Security Export Control Standard Regulations of the Mitsubishi Electric Group (in Japanese, English, Chinese, and Thai) to all associated companies, and provide guidance for the establishment of regulations, for the development of a framework, and for employee training in each company. In fiscal 2016, we held an educational workshop in China, Europe, Taiwan, and Thailand intended for ECAs (Export Control Administrators)in associated companies. In Japan, we provided e-learning courses that were taken by 33,722 Mitsubishi Electric Corporation employees and 28,322 employees of associated companies. For overseas associated companies, we have English, Chinese, and Thai e-learning materials for the implementation of training programs in each company.

Disassociation with anti-social groups

The Mitsubishi Electric Group adheres to the following three provisions that are clearly set forth in the Mitsubishi Electric Group Conduct Guidelines.

We will not have any relationship with anti-social groups, and will deal with such groups with a firm attitude.
When engaging in a new transaction, we will make certain that the transaction partner is not related in any way to an anti-social group.
Transaction contracts shall include an article on the "elimination of crime syndicates and other anti-social groups," and provide for the termination of the contract in the event a transaction partner is found to be related to an anti-social group, even if the transaction with the partner has already begun.

Furthermore, as a Group-wide measure against unreasonable demands from anti-social groups, an unreasonable demand prevention officer as stipulated in the Anti-Organized Crime Law is assigned to each business office and affiliated company. If a transaction partner is found to be an anti-social group, we make every effort to promptly disassociate ourselves with the company with the cooperation of the police, external specialist institutions (the National Center for the Elimination of Boryokudan and the Special Violence Prevention Measures Association (Tokubouren) under the control of the Metropolitan Police Department, the National Center for the Elimination of Boryokudan, etc.), and lawyers.

Compliance Education by Diverse Means

The Mitsubishi Electric Group works to ensure that employees are aware of the Group's concept of compliance and of the laws that are essential to the conduct of our business activities, using a variety of tools including workshops, e-learning programs, the distribution of manuals, and screen displays when employees log in. In using these tools, we carefully consider and provide the optimum content for different businesses, job levels, job categories, and regions (overseas).

In addition to educational activities conducted independently by each of the Group's affiliated companies and business divisions, we also carry out Group-wide educational initiatives. For example, Mitsubishi Electric Group employees in all of the countries in which we operate take part in an educational program concerning the major relevant laws and the Group's concept of compliance, either through e-learning programs, group lessons, or distance learning. In fiscal 2016, as many as 114,415 employees in Japan (employees of Mitsubishi Electric and affiliated companies in Japan) participated in such programs. Overseas as well, some 6,698 employees overseas have participated in compliance-related e-learning programs that have been uniformly implemented in the Southeast Asia and Oceania regions, for example. Compliance Managers also distribute materials concerning improper conduct to supervisors at Mitsubishi Electric and our affiliates in Japan in order to help us prevent such conduct from occurring.

We also conduct workshops at our various bases (branch offices and production sites) for personnel responsible for compliance at affiliates located in those regions. These workshops seek to foster a thorough awareness of compliance and a deeper understanding of key legislation at our affiliates, in addition to promoting closer cooperation with Mitsubishi Electric.

In fiscal 2016, the Corporate Legal & Compliance Division of Mitsubishi Electric Corporation conducted approximately 342 compliance-related workshops throughout the Group, in which a total of 16,340 people participated.