As a 100% subsidiary of Mitsubishi Corporation, we engage in fair, sound business practices based on our Philosophy and Principles—including the Three Corporate Principles ("Sankoryo") that have served as the corporate Credo of Mitsubishi Corporation since its founding. To realize our Philosophy and Principles, we have established Corporate Action Guidelines to guide our corporate conduct, and a Code of Conduct for Corporate Officers and Employees which sets forth rules to be followed by every officer and employee.

Management Philosophy

Value

Represent the Three Corporate Principles of MC

In addition to the Three Corporate Principles of Mitsubishi Corporation, we adopt the following values as our guiding principles.
① Value relationships with people
② Have a broad perspective
③ Challenge ourselves to reach heights

Three Corporate Principles

The Three Corporate Principles (“Sankoryo”) of the Mitsubishi Group were formulated in 1934 as Action Guidelines of the former Mitsubishi Trading Company, based on the 1920 teachings of Koyata Iwasaki, the fourth President of Mitsubishi. The same spirit and values remain alive today, having been passed down through a history of more than 150 years, and guide the activities of the Mitsubishi Group.

The Sankoryo of Koyata Iwasaki

Corporate Responsibility to Society "Shoki Hoko"

Resolve to contribute to society

Strive to enrich society, both materially and spiritually, while contributing towards the preservation of the global environment.

Integrity and Fairness "Shoji Komei"

Insist on fairness and integrity

Maintain principles of transparency and openness, conducting business with integrity and fairness.

Global Understanding through Business "Ritsugyo Boeki"

Be globally minded

Expand business, based on an all-encompassing global perspective.

(The modern day interpretation of the Three Corporate Principles, as agreed on at the Mitsubishi Kinyokai meeting of the companies that constitute the so-called Mitsubishi group in January 2001.)

Corporate Action Guidelines

To realize our Management Philosophy, we shall conduct our business activities in accordance with the following six principles, both in Japan and overseas.

1. Purpose of Corporate Activities

   Through our business activities, we shall strive to realize a fruitful society both physically and mentally, not only enhancing our corporate value, but also continuously and consistently providing and creating useful products and services for society, earning society’s trust.

2. Business Conducted with Integrity and Fairness

   We shall conduct business with sincerity, fairness, transparency, and integrity, and maintain sound and proper relationships with political and administrative bodies.
   In carrying out our corporate activities, we strive for promotion of social responsibility throughout our value chain, complying with domestic and international laws and regulations and with international agreements, as well as acting responsibly in line with social norms.
   We shall also respond resolutely to antisocial forces that pose a threat to the order and safety of civil society.

3. Respect for Human Rights and Employees, Ensuring Healthy and Safe Workplace Environments

   In all our business activities, we shall respect fundamental human rights, and we shall not be complicit in discriminatory practices, child labor, or forced labor. We shall also respect the diversity, character, and individuality of our employees, work to maintain and improve our corporate vitality through human resource development, and; thereby, ensure a safe and healthy working environment.

4. Disclosure of Information to Stakeholders and Information Management

   We shall be fully committed to fair and transparent management, disclose corporate information in a timely and appropriate manner, and be accountable for our actions. We shall also ensure thorough protection and management of all types of information, including personal information and customer information.

5. Consideration for the global environment

   We recognize that a company that does not care for the global environment cannot survive, and thus we shall strive to protect the global environment and pursue sustainable development in every aspect of our business activities.

6. Harmony with Society and Local Communities

   As a member of society, we shall contribute to the development of communities through our business activities in order to realize a better society. We shall also actively participate in social contribution activities as a good corporate citizen.

Code of Conduct for Corporate Officers and Employees

To realize our Management Philosophy and ensure sustainable development of both society and our company, we hereby set forth the following guidelines and standards that all officers and employees must observe in the performance of their daily duties.

1. Purpose of Corporate Activities

   We shall strive, through our business activities, to enhance our corporate value and help realize a prosperous society.

   1. ① We shall always respond sincerely to the views of business partners.
   2. ② We shall take into account the needs of our business partners in every country and region, and devise and provide safe and secure products and services.
   3. ③ By continuously and consistently providing and creating socially-beneficial products and services, we shall earn society’s trust and work toward realizing a society rich in both physical and mental aspects.

2. Business Conducted with Integrity and Fairness

   We shall uphold high ethical standards and promote fair business practices.

   1. 1） Antitrust laws (including subcontracting laws)
      1. ① We shall comply with domestic and international laws and regulations, make decisions with common sense and responsibility as members of society, and engage in fair business transactions.
      2. ② We shall not, whether among competitors or through industry associations, engage in agreements or arrangements on matters such as prices, quantities, production facilities, sales areas, or customer allocation (i.e., cartels), bid-rigging, dumping, or any other improper trading restrictions that hinder free competition. We shall also refrain from unfair trade practices such as maintaining resale prices, boycotts, or tie-in sales.
      3. ③ We shall not engage in any conduct that unfairly harms the interests of subcontractors.

      Relevant Laws and Regulations, etc.	Act on Prohibition of Private Monopolization and Maintenance of Fair Trade; Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors
      Relevant Internal Rules	Standards for Prevention of Anti-monopoly Act Violations, Guidelines for Handling Information Related to Anti-monopoly Act, Guidelines for Subcontracting Act and Logistics Special Designation
      Contact for Inquiries	Legal and Compliance Department

   2. 2） Improper Granting of Benefits
      1. ① We shall not, domestically or internationally, grant improper benefits to public officials or to persons in an equivalent position. We shall also refrain from making any payments where it is the case that, or there is a risk that, through agents, consultants, or other intermediaries engaged by our company, a portion of our payments may be used to grant improper benefits to public officials or to persons in an equivalent position.
      2. ② Regardless of whether the other party is a public official, we shall offer gifts, entertainment, and the like only within the bounds of the law and within the scope of what is reasonable by prevailing social standards. We shall also refrain from accepting excessive gifts or hospitality.

      Relevant Laws and Regulations, etc.	Criminal Law; Unfair Competition Prevention Act (Anti-bribery Regulations), National Public Service Ethics Act; National Public Service Ethics Code; United Nations Global Compact
      Relevant Internal Rules	Standards on the Prohibition of Improper Granting of Benefits; Standards on Entertainment and Gifts, etc.; Guidelines on Entertainment, Gifts, etc., and External Income; Guidelines on the Appointment of Agents and Consultants, etc.; Guidelines on Entertainment and Gifts for Public Officials, etc.
      Contact for Inquiries	Legal and Compliance Department

   3. 3） Antisocial Forces and Money Laundering
      1. ① We shall respond resolutely to antisocial forces and shall neither provide nor accept any benefits from them.
      2. ② We shall not engage in any transactions with antisocial forces or with business partners that have ties to such forces.
      3. ③ To avoid complicity in money laundering, we shall carefully review remittances to third countries and third parties in accordance with internal rules.

      Relevant Laws and Regulations, etc.	Organized Crime Punishment Act; Tokyo Metropolitan Ordinance on the Exclusion of Organized Crime Groups; Act for Prevention of Transfer of Criminal Proceeds; United Nations Convention against Transnational Organized Crime
      Relevant Internal Rules	Standards on Remittances to Third Countries and Third Parties; Standards on the Prohibition of Improper Granting of Benefits; Supply Chain Management Standards; Supply Chain Management Guidelines
      Contact for Inquiries	General Affairs Department, Legal and Compliance Department

   4. 4） Trade (Including Import/Export Procedures) and Industry-Related Laws
      1. ① We shall comply with import/export procedures. We shall not deal in prohibited goods.
      2. ② To maintain international peace and security, we shall carefully assess the permissibility of export transactions of strategic goods and other specified freight or technologies, or the provision of services and the like (specific trade transactions), in accordance with our internal self-management rules on security trade. In doing so, we shall also take international considerations into account.
      3. ③ We shall understand the domestic and international laws and regulations applying to the products and services we handle, and shall ensure that all procedures such as obtaining permits/approvals and filing notifications are completed without omission.

      Relevant Laws and Regulations, etc.	Foreign Exchange and Foreign Trade Act; Act on the Regulation of Manufacture and Evaluation of Chemical Substances (Kashinhou); Act on the Assessment of Releases of Specified Chemical Substances in the Environment and the Promotion of Management Improvement (Kakanhou, PRTR Law); Poisonous and Deleterious Substances Control Act; Act on Special Measures concerning Promotion of Proper Treatment of PCB Wastes; Fire Service Act; Industrial Safety and Health Act; Commodity Derivatives Transaction Act; other laws and regulations in foreign countries equivalent to the above (REACH, RoHS, TSCA, etc.)
      Relevant Internal Rules	Security Trade Management Standards; Security Trade Management Guidelines; Trade Procedure Management Standards; Trade Procedure Management Guidelines; Permit, Approval, and Notification Management Standards; Chemical Substance Related Management Standards; Guidelines for Management of Chemical Substances Contained in Products; Standards for Prevention of Market Misconduct in Commodity Trading; Sanctions Management Standards; Sanctions Management Guidelines
      Contact for Inquiries	Legal and Compliance Department

   5. 5） Unfair Trading of Stocks and Other Securities (Insider Trading)
      1. ① When we become aware of any “material facts” (insider information) concerning our company or another company that may significantly affect investment decisions, we shall not engage in the purchase or sale of stocks or other securities of our company or the relevant other company until such facts are publicly disclosed.
      2. ② We shall not disclose insider information of our company or other companies, learned in the course or as a result of work, to anyone other than those deemed to need it for business purposes.

      Relevant Laws and Regulations, etc.	Financial Instruments and Exchange Act
      Relevant Internal Rules	Standards for Management of Insider Trading Regulations
      Contact for Inquiries	Accounting and Finance Department, Legal and Compliance Department

   6. 6） Separation of Public and Private Matters and Acts Contrary to the Interests of the Company
      1. ① We shall not blur the line between public and private matters, and we shall not engage in any conduct contrary to the interests of the company.
      2. ② We shall not make improper use of the company’s tangible or intangible assets.
      3. ③ We shall not make improper use of or damage the company’s trade name, status, reputation, or other business credibility.
      4. ④ We shall not receive any improper money, goods, or other benefits in connection with our duties.
      5. ⑤ We shall not use the company’s assets or expenses for personal purposes.
      6. ⑥ We shall not make improper use of the company’s internal information systems.
      7. ⑦ We shall not engage in any other occupation without the company’s approval.
      8. ⑧ We shall return company assets upon resignation.
      9. ⑨ We shall not engage in personal activities unrelated to our duties, such as political or religious activities, in the workplace.
      10. ⑩ We shall not drive under the influence of alcohol.

      Relevant Laws and Regulations, etc.	Unfair Competition Prevention Act; Criminal Law; Road Traffic Act
      Relevant Internal Rules	Work Regulations; Information Security Rules; Information Device and Media Usage Standards; Electronic Portable Media and Other PC Peripheral Device Usage Guidelines; Email Usage Guidelines; Guidelines for Preventing Misdelivery of Emails to External Recipients; System Development, Maintenance, and Operation Guidelines
      Contact for Inquiries	General Affairs Department, Human Resources Department, Information Systems Department

3. Respect for human rights and employees, Ensuring healthy and safe workplace environments

   In all aspects of our work, we shall respect fundamental human rights and shall not engage in discrimination or harassment.

   1. ① We shall respect each individual’s diverse values, individuality, and privacy, and shall not discriminate on any grounds, including race or ethnicity, skin color, thought or creed, religion, sex, gender identity, sexual orientation, nationality, age, place of origin, physical or mental disability, or illness.
   2. ② We shall not engage in, allow, or tolerate harassment. We shall speak up with courage in order to create an open and welcoming workplace.
   3. ③ We shall be aware that we are members of the international community, learn about each country’s culture, customs, and history, and correctly understand and recognize human rights issues.
   4. ④ We shall take care to avoid being complicit in forced labor, child labor, or other inhumane treatment at our business partners and within our supply chain.
   5. ⑤ We shall strive for and respect work–life balance, and a workstyle with a clear demarcation between work and personal time.

   Relevant Laws and Regulations, etc.	Labor Standards Act; Industrial Safety and Health Act; Act on Equal Opportunity and Treatment between Men and Women in Employment; Act to Facilitate the Employment of Persons with Disabilities; Act on Securing the Proper Operation of Worker Dispatching Businesses and Protecting Dispatched Workers; Act on the Welfare of Workers Who Take Care of Children or Other Family Members Including Child Care and Family Care Leave; Act on Stabilization of Employment of Elderly Persons; Labor Union Act; Universal Declaration of Human Rights; International Covenants on Human Rights; Ten Principles of the United Nations Global Compact; United Nations Guiding Principles on Business and Human Rights and Conduct Principles on Business and Human Rights (2020–2025); OECD Guidelines for Multinational Enterprises on Responsible Business Conduct; UK Modern Slavery Act; Sustainable Development Goals (SDGs); US Dodd-Frank Act (relating to conflict minerals); other laws and regulations in foreign countries equivalent to the above
   Relevant Internal Rules	Human Rights Policy; Work Regulations; Supply Chain Management Standards; Guidelines on Preventing Harassment
   Contact for Inquiries	Human Resources Department, General Affairs Department, Legal and Compliance Department

4. Disclosure of information to stakeholders and information management

   We shall strive to disclose corporate information to stakeholders in a timely and appropriate manner and shall conduct proper information management.

   1. 1） Records and Reports Relating to Financial Accounting
      1. ① We shall always ensure the accuracy of our financial reporting and carry it out in a timely and appropriate manner.
      2. ② We shall not make any false or misleading entries in account books.
      3. ③ We shall not maintain any off‑the‑books funds or assets, except for those which have been recorded as expenses.

      Relevant Laws and Regulations, etc.	Companies Act; Financial Instruments and Exchange Act; Tax Law; Various accounting standards
      Relevant Internal Rules	Basic Accounting Rules; Account Heading Management Standards; Accounting Practice Standards; Guidelines on MINTS Entry and Accounting Processing; Operating Expenses Practice Standards; Operating Expenses Handling Guidelines; Tax Practice Standards; Transfer Pricing Guidelines; Finance Practice Standards; Budget and Settlement Practice Standards; Basic Rules for Internal Booking of Foreign Exchange; Management Standards for Internal Booking of Foreign Exchange
      Contact for Inquiries	Accounting and Finance Department

   2. 2） Information Management
      1. ① We shall manage the company’s confidential information appropriately and strictly according to its level of importance, and shall not allow it to leak or use it for purposes other than business.
      2. ② We shall take precautions against the loss or theft of information and communication devices on which the company’s confidential information is stored.
      3. ③ We shall exercise due care regarding suspicious emails and targeted attack emails when using email.
      4. ④ We shall, when it is necessary for business purposes to disclose the company’s confidential information to external parties, conclude a confidentiality agreement in advance.
      5. ⑤ We shall not infringe the intellectual property rights of other companies or individuals, through actions such as making unauthorized copies of third‑party works or computer software.
      6. ⑥ When sending emails, we shall take care to check addresses and implement measures to ensure there are no mistakes in recipients.
      7. ⑦ We shall not allow leakage or make private use of the company’s confidential information even after leaving the company.

      Relevant Laws and Regulations, etc.	Unfair Competition Prevention Act; Act on Prohibition of Unauthorized Computer Access; Copyright Act; Act on the Protection of Personal Information
      Relevant Internal Rules	Document Handling Rules; Document Handling Standards; Information Security Rules; Information Device and Media Usage Standards; Electronic Portable Media and Other PC Peripheral Device Usage Guidelines; Email Usage Guidelines; Guidelines for Preventing Misdelivery of Emails to External Recipients; System Development, Maintenance, and Operation Guidelines
      Contact for Inquiries	Information Systems Department, General Affairs Department, Legal and Compliance Department

5. Consideration for the Global Environment

   We shall strive to protect the global environment and aim for sustainable development.

   1. ① We shall, in addition to complying with environmental laws and regulations domestically and internationally, always conduct our business activities with due consideration for their environmental impact.
   2. ② We shall correctly understand climate change and energy issues, consider the balance between sustainable economic development and global environmental protection, and take appropriate action.
   3. ③ We shall strive to ascertain accurate information on chemical substances contained in our products, and shall communicate this to our business partners.
   4. ④ We shall consider business that contributes to energy conservation and the realization of a recycling-oriented society.
   5. ⑤ We shall not neglect efforts that can be done in ordinary situations such as energy conservation, waste separation, and the use of recycled paper.

   Major Related Laws and Regulations, etc.	Basic Act on the Environment; Secondhand Goods Business Act; Basic Act on Establishing a Sound Material-Cycle Society; Act on Waste Management and Public Cleaning (Waste Management Act); Act on Recycling of Specified Kinds of Home Appliances (Home Appliance Recycling Act); Act on Promotion of Recycling of Small Waste Electrical and Electronic Equipment (Small Equipment Recycling Act); Act on Recycling of End-of-Life Automobiles (Automobile Recycling Act); Act on Rationalizing Energy Use (Energy Conservation Act); Act on the Regulation of Manufacture and Evaluation of Chemical Substances (Kashinhou); Act on the Assessment of Releases of Specified Chemical Substances in the Environment and the Promotion of Management Improvement (Kakanhou, PRTR Law); Poisonous and Deleterious Substances Control Act (Poison Law); Fire Service Act; Industrial Safety and Health Act; United Nations Framework Convention on Climate Change (Kyoto Protocol, Paris Agreement); Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal (Basel Convention), etc.
   Relevant Internal Rules	Sustainability and CSR Basic Rules; Sustainability and CSR Organization and Operations Standards; Mitsubishi Corporation RtM Japan Environmental Policy; Environmental Management Rules; Environmental Management Guidelines; Chemical Substance Related Management Standards; Guidelines for Management of Chemical Substances Contained in Products; Supply Chain Management Standards; Supply Chain Management Guidelines; CSR Conduct Policy in the Supply Chain; Green Procurement Policy; Industrial Waste Disposal Contractor Management Practice Standards; Guidelines on Procedures for Industrial Waste Disposal where Our Company Is the Waste Generator
   Contact for Inquiries	General Affairs Department, Legal and Compliance Department

6. Harmony with Society and Local Communities

   We shall value dialogue with all stakeholders, actively identify issues faced by our business partners and society, and work to resolve them through our business.

   1. ① We shall value dialogue with a wide range of stakeholders, including our business partners.
   2. ② Through creativity and ingenuity, we shall build sustainable new business models that contribute to solving challenges faced by our business partners and society.
   3. ③ We shall listen to diverse opinions and even negative information, and respond with sincerity.
   4. ④ We shall take into account the issues and needs of the societies and communities related to our corporate activities, and strive to engage in social contribution activities that promote their cultural and economic development.

   Relevant Laws and Regulations, etc.	Sustainable Development Goals（SDGs）
   Relevant Internal Rules	Key Issues for Sustainability (Materiality); Sustainability and CSR Basic Rules; Sustainability and CSR Organization and Operations Standards; Donation Handling Standards
   Contact for Inquiries	General Affairs Department

7. Reporting, notification, consultation

   If we become aware of any compliance violating conduct, we shall promptly report and consult on the matter and make every effort to ensure that it is corrected, regardless of our own involvement.

   1. ① We shall always maintain high ethical standards and shall take action with courage.
   2. ② If we are uncertain whether a situation constitutes a compliance violation, we shall consult with the Legal and Compliance Department or the relevant hotlines.
   3. ③ No one shall suffer any disadvantage as a result of reporting a case of violation, and if such a situation occurs, it shall be reported immediately to the Legal and Compliance Department or the relevant hotlines.

   Relevant Laws and Regulations, etc.	Whistleblower Protection Act
   Relevant Internal Rules	Compliance Basic Rules; Compliance Organization and Operations Standards; Compliance Reporting Guidelines; Standards on Internal Reporting
   Contact for Inquiries	Legal and Compliance Department