Mitsubishi Chemical HoldingsTHE KAITEKI COMPANY

Legal Compliance and Fairness, Equitability, and Integrity

Charter of Corporate Behavior

We shall comply with laws and international standards and shall hold ourselves to the highest ethical conduct at all times. In addition, we shall always adopt an attitude of fairness, equitability, and integrity towards customers, suppliers, shareholders, business partners, government agencies, local communities, and other stakeholders. This attitude shall also apply to our dealings with each other.

Recognition of Issues and Basic Approach

The Mitsubishi Chemical Holdings Group recognizes the word "Compliance" as a broader definition covering corporate ethics and general social norms, not staying at basic legal adherence. The Group regards compliance as one of its top management priorities in order to continue to be a company that stakeholders and society as a whole can trust. At overseas Group companies, as well as domestic Group companies, we have formulated codes of conduct and regulations in line with each country's laws and rules and social standards, based on a common basic rule.

Structure

To steadily incorporate compliance into the Mitsubishi Chemical Holdings Group, Mitsubishi Chemical Holdings Corporation has established the Internal Control Office to manage compliance, as well as either a Compliance Promotion Committee or a Corporate Ethics Committee at operating companies, under the supervision of the Group Chief Compliance Officer (Group CCO) appointed by the Board of Directors of Mitsubishi Chemical Holdings Corporation.
Overseas, the Group has appointed in-house lawyers at the regional management companies of Mitsubishi Chemical Holdings Corporation in the U.S., Germany and China, along with appointing Compliance promotion leaders in various countries and regions, such as Indonesia, Singapore, Thailand, India and Taiwan.

Compliance Promotion Structure

Compliance Promotion Structure

Main Activities

Mitsubishi Chemical Holdings Group operating companies are pushing ahead with activities to strengthen compliance, such as formulating rules of conduct based on standards established by Mitsubishi Chemical Holdings Corporation.

Implementing Training Courses

Every year, operating companies conduct compliance-related training courses and seminars for the group companies they manage. Mitsubishi Chemical Holdings Corporation dispatches instructors to lead seminars, along with producing training tools and other materials, to support the training activities of the operating companies.

Preparing Compliance Guidebooks

Operating companies prepare compliance guidebooks for practicing compliance according to the characteristics of the businesses of each company.

Implementing Operational Auditing and Monitoring

The Internal Audit Office of Mitsubishi Chemical Holdings Corporation conducts annual Control Self Assessments (CSA) at Group companies. As part of these efforts, the Company ascertains the extent of compliance promotion at each Group company based on a series of compliance-related questions.

Establishing and Managing Compliance Hotline Systems

Operating companies establish and operate their own compliance hotline systems, through which employees can talk with either the internal control promotion department manager of each company or an outside attorney. The operating companies regularly report to Mitsubishi Chemical Holdings Corporation on the implementation status of the compliance hotline systems. Mitsubishi Chemical Holdings Corporation also provides a compliance hotline system for employees at Group companies and is working to promote the system and ensure that it continues to be operated appropriately.
An investigative team led by the internal control promotion department manager of each company processes all information that is provided. If it is deemed that there is a problem, the team will take swift action to remedy the situation, under the supervision of the CCO of each company.
In addition, to those employees seeking advice or filing reports, each company vows to keep the facts and contents of their consultation and reports confidential, and guarantees that they will not suffer any discriminatory or unjust treatment, including dismissal, on account of these facts. If anyone should act unjustly toward such an employee, that person will be disciplined in accordance with internal rules.

Disclosure of Compliance Violations and Unfair Practices

Necessary disclosure of compliance violations and unfair practices in the Mitsubishi Chemical Holdings Group will be completed appropriately via news releases on Mitsubishi Chemical Holding Corporation's website or the operating companies' websites.

Targets and Results

Target Achieve zero occurrences of serious compliance violations
Result Fiscal 2013 Zero serious violations

Number of compliance violation occurrence

Fiscal 2013 Zero serious violations
Fiscal 2012 Zero serious violations