In April 2008, the former Mitsubishi Plastics, Inc., Mitsubishi Polyester Film Corporation, Mitsubishi Chemical Functional Products, Inc., Mitsubishi Chemical MKV Company and the functional products businesses of Mitsubishi Chemical Corporation (MCC) were integrated to launch the new MPI. Positioning compliance as the highest priority among management policies, Mitsubishi Plastics will steadily address the accomplishment of CSR management.
Compliance Guideline
While we strove to strengthen compliance in each company before the integration, we seized upon the opportunity presented by the integration and creation of the new MPI to develop a Compliance Promotion Program including basic compliance regulations, a promotion system, an enlightenment and education program, an auditing and monitoring structure and a hotline. Based on the Mitsubishi Chemical Holdings Group Corporate Ethics and the Mitsubishi Chemical Holdings Group Compliance Code of Conduct, we formulated the Mitsubishi Plastics Group Compliance Promotion Regulations and we are strengthening compliance management.
In an attempt to make the compliance promotion program common knowledge, we created the Mitsubishi Plastics Group Compliance Guidelines, which were distributed in June 2008 to all personnel including executives, full-time and contract employees of all the Group companies in Japan. In December 2008, we created an English version of the guidelines that was distributed to our overseas Group companies.
The Chief Compliance Officer (CCO) elected by the Board of Directors oversees the development and management of the MPI Group compliance promotion program and provides guidance and support for Group companies. The CCO is required to report all Group compliance problems to the Board of Directors and the MCHC Group Chief Compliance Officer.
[ Mitsubishi Plastics Group Compliance Promotion System ]
Furthermore, we have instituted a Compliance Promotion Committee that offers proposals and counsel to the CCO regarding basic policies, management status, response in the event of a compliance violation, and formulation and any changes related to the creation and management of Mitsubishi Plastics Group Compliance Promotion Program upon deliberation.
In June 2007, the Japan Fair Trade Commission took administrative action against the former MPI for violating the Antimonopoly Law. As a result, a Pricing Committee was created in October 2007 with the CCO as committee chairman. The structure was created to strengthen the observance of antimonopoly laws when determining product and bidding prices.
In addition to strengthening the structures that prevent compliance violations, we are aware of the importance of the early detection of future violations and the creation of a system of corrective actions and prevention of recurrence. The MPI Group established a Compliance Hotline that employees can contact for problematic issues, but in a compliance awareness survey conducted in fiscal 2008, a large number of employees indicated that they were unaware of the hotline.
Using training facilities and message boards in an attempt to inform employees of the hotline, we changed the rule that required disclosure of an employee's name when reporting an incident to enable anonymous reporting in an effort to create a user-friendly environment.
A pervasive awareness of compliance among employees whose individual actions are in line with compliance regulations is the most important aspect of compliance management promotion. MPI regularly conducts training for new employees, employees recently promoted to managerial positions and employees in charge of compliance promotion in each department, implementing compliance education for use in daily business activities.
Lecture on Antimonopoly Law
In fiscal 2008, we held lectures at the Head Office and seven domestic branch offices on antimonopoly law for employees in the Sales and Marketing Function that were presented by an outside lecturer (lawyer). Also, we held lectures at our four main plants focused on inculcating awareness of compliance with rules that must be observed to prevent accidents.
In fiscal 2009, we will hold successive compliance training sessions for Group Companies and safety lectures at plants and manufacturing sites where no lectures were held in fiscal 2008.
Masanori Kondo
Senior Manager
Human Development
Section
Mitsubishi Plastics, Inc.
Naturally doing what is expected is the basis of compliance.
Compliance is the foundation of CSR, and I think that naturally doing what is expected is important for the promotion of compliance. As a lecturer conducting training and education seminars for employees, I try to instill compliance by encouraging employees to reflect on their daily business and activities and ask themselves, "Do I observe laws and regulations? Do I respect human rights."
In June 2007, the Japan Fair Trade Commission took administrative action against the former MPI, which found that it had violated the Antimonopoly Law in setting prices for polyethylene pipes and fittings for gas. In July of the same year, MPI had also been the subject of a compulsory investigation by the Japan Fair Trade Commission concerning the determination of selling prices for PVC pipes and other related products with other manufacturers. (MPI has requested a trial in response to the Japan Fair Trade Commission's administrative actions regarding its PVC pipes and fittings after examining the contents of the administrative action. At the time of this writing, trial procedures were still pending).
Given this state of affairs, the President of MPI and the Compliance Promotion Committee Chair have instructed all employees in the MPI Group to redouble their compliance efforts, and on August 1, 2007, established a third-party investigation committee chaired by attorney and former public prosecutor Yuichi Suzuki. The purpose of this committee was to perform a thorough investigation into whether or not there were any compliance violations, and in particular, violations concerning the Antimonopoly Law, as well as to recommend detailed measures to prevent recurrence. In July 2008, the committee completed its approximately 10-month-long investigation and presented its report and recurrence prevention recommendations. MPI is now acting on the findings of that report and implementing recommendations based on the Compliance Promotion Committee's review.
