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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.

President & CEO
M Sakuyama

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.
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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.

Corporate Ethics and Compliance Statement Poster

Portable Card

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System to Ensure Thorough Implementation of Compliance at the Global Level

Based on recognition that the promotion of compliance is inseparably linked with business promotion, the Mitsubishi Electric Group's compliance system has our business divisions and affiliates in Japan and overseas take the initiative in promoting compliance.

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.

Compliance Managers Meeting in Asia (Thailand)

Compliance staffs Meeting in China (Xian)


Mitsubishi Electric Group compliance promotion structures

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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 implemented between fiscal 2014 and fiscal 2017 for executives, sales and other departments, and has been attended by 3,326 employees to date. Practical training that reflects the characteristics of each business and affiliated company, has continued to be implemented beyond fiscal 2017, and ongoing education has been provided to both prevent the recurrence of incidents in violation of anti-trust laws and prevent previous violations from being forgotten.

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, the development of a framework, employee training and internal audits in each company. In fiscal 2017, we held educational workshops in China, South Korea, India, Europe, Brazil and Mexico, intended for ECAs (Export Control Administrators)in associated companies. In Japan, we provided e-learning courses that were taken by 35,001 Mitsubishi Electric Corporation employees and 19,704 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.

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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. Employees in all countries in which we operate take part in an educational program concerning the major relevant laws, respect for human rights, and the Group's concept of compliance, either through e-learning programs, group lessons, or distance learning. In fiscal 2017, as many as 104,837 employees in Japan (employees of Mitsubishi Electric and affiliated companies in Japan) participated in such programs. Overseas as well, some 7,607 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 2017, the Corporate Legal & Compliance Division of Mitsubishi Electric Corporation conducted approximately 233 compliance-related workshops throughout the Group, in which a cumulative total of 9,304 people participated.

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Compliance Audits

Based on the awareness that "ethics and compliance are fundamental preconditions for the Group's continued existence," each Mitsubishi Electric Group company and department appoints a compliance promotion manager, and carries out a compliance inspection of their company or department a multiple number of times a year by various means, utilizing check sheets and other tools that are specified for each area of corporate ethics and relevant laws and regulations. The results of these inspections are reported to the manager of each company or department, and if a problem has been found in an inspection, corrective action is taken voluntarily, such as by strengthening employee education and enforcement.

Mitsubishi Electric’s audit department carries out an audit of all Group companies regularly by visiting each company and department and checking whether there are any problems mainly in terms of compliance, and whether compliance awareness and initiatives are sufficient, from a subjective, professional perspective. If it is deemed that a correction is needed, an instruction is issued to formulate an improvement plan and to report the results of the improvement.

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Establishment of Internal and External Ethics and Legal Compliance Hotlines

Mitsubishi Electric has put in place "ethics and legal compliance hotlines" (internal reporting system), with the objective of promptly assessing fraudulent, illegal, and anti-ethical conduct and allowing a self-disciplinary mechanism to function against such types of conduct. This consultation service is available both inside and outside the company (law firms), and operates under clear internal regulations that provide for responses to anonymous informant, elimination of disadvantageous treatment of informant, and the confidentiality of all informant. Notification are also accepted from business partners and affiliated companies, with regard to transactions that have to do with Mitsubishi Electric.

The facts of each notification are verified by a group composed of members from a survey department, depending on the content of the notification. In cases where there is a possibility that the matter in question does not conform to relevant laws or internal regulations, efforts are made to promote and disseminate proper understanding through a review of rules and explanation meetings. If an illegal act or conduct that violates internal regulations is confirmed, the party concerned is subject to some form of discipline, or a remedial action is demanded of the relevant department.

Details of these "ethics and legal compliance hotlines" are provided in the booklet that is distributed to all employees and contains the Mitsubishi Electric Group Conduct Guidelines. Posters are also displayed in each department and office, as well as on the Group’s website, to thoroughly disseminate the service to all employees.

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