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 and regulations.
We regard compliance as one of the top management priorities 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 MCG Group.

Compliance promotion structure

The Chief Compliance Officer (CCO), who is appointed by the Board of Directors, has overall responsibility for compliance promotion, and under the direction and supervision, a compliance promotion structure is established in each business group and each corporate function unit.
To manage compliance promotion globally, the MCG Group has established the Global Compliance Promotion Regulations and has divided the world into five regions (Japan and Korea, Americas, EMEA, Asia Pacific and China) and implemented the Global Compliance Promotion Program aimed at standardizing and enhancing the quality of compliance promotion activities in each region. 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 and improve the contents of the implemented activities each time and strengthen the PDCA cycle for promoting compliance. The details and progress of 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］

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.
In fiscal year of 2023, there was 1 serious compliance violation.

Whistleblowing Systems

The MCG Group operates whistleblowing systems, in each region, with compliance promotion departments of each region or external lawyers or specialized service providers as contact points. In fiscal year of 2023, total of 423 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 applicable 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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