• Hold Compliance Committee meetings (regularly held twice a year and special meetings)
• Publish compliance magazine
• Hold compliance discussions for officers and employees (every year)
• Hold e-learning sessions (every year)
• Hold seminars on various themes

We have established four helplines that maintain confidentiality.

• Legal and Compliance Department Helpline
• Corporate Auditor Helpline
• Mitsubishi Corporation Group External Attorney Helpline
• For violations related to antitrust laws and anti-bribery regulations, we use the global internal reporting system (commonly known as “LUKS”) introduced by Mitsubishi Corporation.

We have established various rules and guidelines relating to improper granting of benefits, and put in place a preliminary review system to prevent improper granting of benefits. We have also established a Sustainable Procurement Policy as part of supply chain management.

Our company has introduced a dedicated system for security trade control. We have also filed our internal rules with the Ministry of Economy, Trade and Industry, and we are implementing strict export control.

As company policy, we regularly conduct seminars and e-learning for officers and employees. We have also established Standards for Prevention of Antitrust Law Violations and defined matters that should be noted to avoid engaging in cartel activities and prevent suspicion of such activities.

• Chemical-related industry laws

  We use the chemical substance management system ExESS (provided by LISAM Systems, Japan agent: EMORI Infotech Co., Ltd.) which employs data from Japan Chemical Database Ltd.’s 32 major domestic laws and regulations, to confirm the applicability of chemical-related industry laws—including the Act on the Regulation of Manufacture and Evaluation of Chemical Substances, the Act on the Assessment of Releases of Specified Chemical Substances in the Environment and the Promotion of Management Improvement, and the Industrial Safety and Health Act—pertaining to the products we handle.

• Derivatives regulations

  To respond to major countries’ derivatives regulations (Commodity Derivatives Transaction Act, EMIR, Dodd Frank), we collaborate with Mitsubishi Corporation to monitor transaction records and regularly confirm whether these regulations apply to our company.

• Other industry laws and regulations

  In addition to the chemical-related industry laws mentioned above, our business is related to various industry laws including the Commodity Futures Trading Act, Waste Management and Public Cleansing Law, Container and Packaging Recycling Law, Energy Conservation Law, and ordinances related to metal scrap established by some prefectures. Our company uses the legal management system Legal FOCUS provided by Daiichi Hoki Co., Ltd. to monitor revision status of industry laws related to our business activities, thereby responding to revisions of various industry laws.

Our company conducts the following initiatives (checks) to appropriately protect information assets for which we bear management responsibility and ensure the necessary information security.

• We have established rules and guidelines regarding information security and regularly disseminate these to executives, employees, and contractors through training, e-learning, and other approaches, along with various laws and regulations related to information security. (④⑤)
• To prevent unauthorized access and information leakage, we implement the necessary security measures for information assets. We also set and regularly review appropriate access permissions for information assets. (②③)
• We have established a company-wide management system, and information asset owners in each department take responsibility for managing information assets under their control and managing their staff members. (①②)

－ Check items －

• ① System (reporting, communication, consultation, etc.)
• ② Employee initiatives (conducting training and drills)
• ③ Handling of confidentiality and important documents, etc.
• ④ Legal and regulatory compliance
• ⑤ Accident prevention