Compliance

For Mitsubishi Chemical Group and its subsidiary companies (“the MCG Group”), the word “compliance” is a broad term covering corporate ethics and general social norms, not only basic adherence to laws.
We regard compliance as one of the most important management issues for ensuring that we continue to exist as a company and be trusted by the society. Accordingly, we take various measures to foster a culture of compliance throughout the entire the MCG Group.

Compliance promotion structure

The Chief Compliance Officer (CCO), who is appointed by the Board of Directors, is responsible for compliance promotion, and the Compliance Promotion Department at Internal Control Division supports the CCO.
To manage compliance promotion globally, the MCG Group has established the Global Compliance Promotion Regulations and implemented the Global Compliance Promotion Program aimed at standardizing and enhancing the quality of compliance promotion activities in each region (the world is divided into five regions). Based on this Program, each region implements global consistent measures such as training and perception survey as well as promotional activities customized to the local culture and characteristics of each region. We verify the contents of the implemented activities and strengthen the PDCA cycle for promoting compliance. These compliance promotion activities are deliberated and reported at the compliance promotion meeting which is composed of executive officers.
If the compliance violation is foreseen or occurs, the respective incidents are reported to the CCO via the compliance promotion department in each region. Then, the relevant departments and the compliance promotion department, etc., take appropriate preventive or corrective actions and measures to avoid recurrence of the incidents.

Compliance system diagram: “Mitsubishi Chemical Holding Corporation Board of Directors” gives instructions and makes requests to CCOs with respect to operating companies and receives reports from CCOs.
Each operating company has a “Board of Directors,” “Chief Compliance Officer (CCO),” “Compliance Promotion Committee (Chairperson: CCO),” and “Compliance promotion structure.”
“Board of Directors” appoints and receives reports from “Chief Compliance Officer (CCO),” and controls/supervises and receives reports from “Compliance promotion structure.”
“Chief Compliance Officer (CCO)” organizes and receives recommendations/advice from “Compliance Promotion Committee (Chairperson: CCO).”
“Mitsubishi Chemical Holding Corporation Board of Directors” appoints and receives reports from “MCG Group Chief Compliance Officer (Group CCO).”
“MCG Group Chief Compliance Officer (Group CCO)” makes reports to and receives recommendations/advice from “Management Committee” and controls/supervises and receives reports from “MCG Chemical Holdings Group Corporation compliance promotion structure.”

［Global Compliance Promotion Program］

Initiatives for Fair Business Practices

We established the MCG Group Global Anti-Bribery Policy and the MCG Group Global Antitrust Policy in 2014, and drew up the guidelines to supplement the Global Anti-Bribery Policy for China in 2015 and for Asia in fiscal 2016. As a result of these initiatives, there were no major violations of relevant laws and regulations during fiscal 2016.
Going forward, we will continue to take measures to ensure not only to prevent bribery and violations of antimonopoly law from a global perspective and to also ensure legal adherence in each country.

Disclosure of Compliance Violations, etc.

The compliance violations, etc., in the MCG Group, which deems necessary are disclosed at the news releases on this website.

Whistleblowing Systems

The MCG Group operates whistleblowing systems, in each region, with compliance promotion departments of each region or external lawyers or specialized organizations as contact points. In fiscal year of 2022, total of 334 allegations were reported globally as shown in the chart below. The compliance promotion departments handled these allegations and, upon confirming any issues, took the corrective actions promptly in line with the MCG Compliance Hotline Operation Rules under the direction of CCO. At the same time, we strive for prevention of recurrence through the compliance training and other measures.

”Contact Points” pie chart: “External lawyers” account for just under 1/4 of total, and “Internal control promotion departments” account for just over 3/4 of total. “Areas of concern” pie chart: “Working environment” account for at least half, “Treatment/personnel affairs” account for around 10%, “Laws/regulations/rules” account for just under 20%, and “Others” account for just under 20%

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