Compliance

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.

Compliance system diagram: “Mitsubishi Chemical Holding Corporation Board of Directors” gives instructions and makes requests to CCOs with respect to operating companies and receives reports from CCOs.
                        Each operating company has a “Board of Directors,” “Chief Compliance Officer (CCO),” “Compliance Promotion Committee (Chairperson: CCO),” and “Compliance promotion structure.”
                        “Board of Directors” appoints and receives reports from “Chief Compliance Officer (CCO),” and controls/supervises and receives reports from “Compliance promotion structure.”
                        “Chief Compliance Officer (CCO)” organizes and receives recommendations/advice from “Compliance Promotion Committee (Chairperson: CCO).”
                        “Mitsubishi Chemical Holding Corporation Board of Directors” appoints and receives reports from “MCHC Group Chief Compliance Officer (Group CCO).” 
                        “MCHC Group Chief Compliance Officer (Group CCO)” makes reports to and receives recommendations/advice from “Management Committee” and controls/supervises and receives reports from “MCHC Chemical Holdings Group Corporation compliance promotion structure.”

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.

Hotline Systems

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, 116 pieces of information were provided in fiscal 2020. 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 7 cases (Harassment) in fiscal 2020. At the same time, we are making efforts to prevent recurrence through the compliance training and other measures.

”Contact Points” pie chart: “External lawyers” account for just under 1/4 of total, and “Internal control promotion departments” account for just over 3/4 of total. “Areas of concern” pie chart:  “Working environment” account for at least half,  “Treatment/personnel affairs” account for around 10%,  “Laws/regulations/rules” account for just under 20%, and “Others” account for just under 20%