For Mitsubishi Chemical Holdings Corporation (MCHC) Group, the word “compliance” is a broad term covering corporate ethics and general social norms, not only basic adherence to laws.
We regard compliance as one of the most important management issues for ensuring that we continue to exist as a company and be trusted by the public. Accordingly, we take various measures to instill a culture of compliance throughout the entire Group.
Compliance promotion structure
The Chief Group Compliance Officer (CCO) is appointed by the Board of Directors, and the Internal Control Office supports the Group CCO, acting as a secretariat for compliance matters.
The secretariat prepares standard training tools, organizes training courses, and has established hotlines and educational system for overseas Group companies to support the Group’s activities. It seeks to ensure compliance in accordance with local conditions through Regional Headquarters (RHQ) established in the U.S., Europe, and China. Each operating company has its own Compliance Promotion Committee as well as an Internal Control Department that serves as secretariat. They operate hotline systems and implement training courses and seminars, business audits and compliance awareness surveys based on the MCHC Group Compliance Promotion Rules.
If an actual or potential compliance violation is found, the department with issues will report and consult with the CCO of each company and the Group CCO, receive guidance and directions, and take appropriate 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.
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 Holdings Corporation’s website or the operating companies’ websites.
The MCHC Group operates hotline systems, with either the internal control promotion departments of MCHC and main operating companies or external lawyers acting as contact points. As the internal and external contact points were effectively used, 142 pieces of information were provided in fiscal 2019. Their breakdowns and the content over the three-year period are shown in the chart below. The internal control promotion departments responded to the reported cases and, when problems were confirmed, we took corrective measures promptly in line with the MCHC Compliance Hotline Operation Rules under the CCO’s direction. As a result, disciplinary action was taken against 11 cases in fiscal 2019. At the same time, we are making efforts to prevent recurrence through the compliance training and other measures.