Mitsubishi Chemical HoldingsTHE KAITEKI COMPANY

Compliance

The MCHC Group recognizes the word “Compliance” as a broad term covering corporate ethics and general social norms, not only basic legal adherence.
We regard compliance as one of the most important managerial issue to achieve continuing existence as a company that merits the trust of the public, and we take measures to embed a compliance culture in the entire Group.

Compliance Promotion Structure

The Chief Compliance Officer (CCO) of the Group is appointed by the Board of Directors of MCHC. The Internal Control Office supports the CCO, acting as a secretariat dealing with compliance matters on a Group-wide basis. To support Group activities, the secretariat compiles standard education tools, arranges training courses, and has established hotline systems for overseas Group companies. Furthermore, it aims to ensure compliance in accordance with regional conditions through the regional control companies established in the Americas, Europe and China.
Each operating company has its own Compliance Promotion Committee and internal control promotion department to serve as the secretariat. They operate hotline systems and implement training courses and seminars, business audits and compliance perception surveys based on the MCHC Group Compliance Promotion Rules. In the event that any company within the Group has caused compliance violations, it is required to report to and consult with its internal control promotion department and Internal Control Office of MCHC, and take corrective actions and measures to prevent recurrence.

Initiatives for Fair Business Practices

We established the MCHC Group Global Anti-Bribery Policy and the MCHC Group Global Antitrust Policy in 2014, and drew up the guidelines to supplement the Global Anti-Bribery Policy for China in 2015 and for Asia in fiscal 2016. As a result of these initiatives, there were no major violations of relevant laws and regulations during fiscal 2016.
Going forward, we will continue to take measures to ensure not only to prevent bribery and violations of antimonopoly law from a global perspective and to also ensure legal adherence in each country.

Hotline Systems

The Group operates hotline systems with the internal control promotion departments of MCHC and main operating companies, and with external lawyers as contact points. We respond to the reported issues through our investigation teams headed by the internal control promotion department managers. In case of any issue, we take corrective measures promptly in line with the MCHC Compliance Hotline Operation Rules under CCO’s direction.