Compliance & Risk Management
Our sound reputation is the foundation of our business. As such, we recognize that it is only through compliance that we can maintain that reputation and gain even more trust from our customers.
To that end, we are working to heighten awareness among all management and staff of the importance of upholding high ethical standards and are accordingly striving to build a global compliance framework that advances best business practices.
Building a Better Compliance Framework
Business Conduct Guidelines for Employees and Officers
The "Business Conduct Guidelines for Employees and Officers of Mitsui & Co., Ltd." specify how every Mitsui employee should act in his or her daily activities, from the perspective of compliance with laws, internal regulations, and corporate ethics. The Business Conduct Guidelines help us fulfill our corporate social responsibility (CSR) and win the trust of our stakeholders. They have been revised from time to time since their enactment in February 2001, to reflect changes in the law and best practices.
Our aim is to ensure that all Mitsui employees develop a broad awareness of the Business Conduct Guidelines through training and e-learning opportunities, and to see that all employees have pledged to comply with them. We have also introduced bespoke business conduct guidelines for each of Mitsui & Co. Group companies, which are based on the Business Conduct Guidelines but tailored to the specific business structures of those companies. In addition, we have put in place the Business Conduct Guidelines in each of our overseas offices, reflecting the local laws, regulations, and customs of the countries in each region.
Business Conduct Guidelines for Employees and Officers
- 1.Compliance with the Law and Respect for Human Rights
- 2.Office Environment and Harassment
- 3.Compliance with Antitrust Law
- 4.Conflicts of Interest between Employees and the Company
- 5.Gifts and Favors
- 6.Treatment of Company Information
- 7.Compliance with Procedures for Export and Import and Other Applicable Laws
- 8.Company Fund and Financial Reporting
- 9.Political Donations and Other Contributions
- 10.Social Contributions
- 11.Protection of the Environment
- 12.Action against Corporate Racketeering and Industrial Espionage
- 13.Reporting and Sanctions
Business Conduct Guidelines for Employees and Officers
The Compliance Program
The Compliance Department of the Mitsui Legal Division leads compliance efforts on a global and Group-wide basis under the direction and supervision of the Chief Compliance Officer (CCO) and with the support of the Compliance Supervising Officers appointed in each of Mitsui's domestic and overseas business units, in Mitsui branches and offices, and in other such entities. The objectives of these efforts are to: (i) heighten awareness of compliance issues, (ii) strengthen and improve compliance programs and systems within Mitsui, and (iii) respond to specific compliance issues that arise. In addition, a Compliance Committee has been established as a forum for discussions relating to the promotion of compliance with laws and ethical standards across the Group as a whole. With the participation of external attorneys, the Compliance Committee discusses various issues that have arisen in the wider Group, and discussion outcomes are made available on the company intranet.
Specific measures carried out with compliance in mind include conducting thoroughgoing supervision at the working level, preventing corruption through management of business entertainment for public officials and appointment of agents, strengthening systems to comply with applicable competition laws, strengthening business process controls, and promoting the rotation and movement of personnel. Such initiatives are implemented on an ongoing basis, and with the aim of preventing misconduct. With respect to anti-corruption, we have published MITSUI & CO., LTD. Anti-Corruption Policy.
Facilitating Communication and Improving the Internal Whistleblowing System
We believe that the compliance function essentially calls for us to prevent compliance-related incidents from arising by maintaining an open working environment that is facilitated by transparent and open communication within the Mitsui community, and which reflects our management philosophy and values. Accordingly, we require that employees who have concerns about possible misconduct promptly raise those concerns with their supervisors or other managers, and duly seek their guidance, in an appropriate and timely manner.
Mitsui offers eight channels for raising compliance concerns, including internal reporting lines and reporting routes involving external attorneys or third-party hotline service providers that promise anonymity. Mitsui has published Whistleblowing System Regulations clearly stipulating that no employee will suffer any form of retaliation or prejudice for raising any compliance concern. Furthermore, we have made it possible for Group companies in Japan to refer compliance reporting to Mitsui's designated external attorneys and third-party hotline service providers as their own external reporting channels, and we are enhancing our system to allow employees of Group companies to raise concerns without fear of retaliation through providing guidance to Group companies on how to set up and manage internal whistleblowing channels.
Overseas, our regional Compliance Supervising Officers are chiefly responsible for overseeing the implementation of reporting channels that make it possible for employees in overseas offices and affiliated Group companies in each region to report and seek guidance on compliance concerns in line with local laws and customs.
Effective Education and Training
Mitsui & Co. provides employees with a wide range of compliance training programs to promote a high degree of awareness of business ethics throughout Mitsui and to ensure that all employees have the necessary skills and information available to them to ensure that work practices remain in compliance.
In the fiscal year ended March, 2017, we provided such training for employees at all levels, including new employees and line managers, as well as for Mitsui employees moving overseas or being seconded to Group companies. Mitsui also provides an extensive program of compliance training for executives and employees of Group companies. In November 2016, we conducted the “Compliance Review Week”, in which we held a seminar about compliance issues that everyone may come across, in addition to sharing information and exchanging opinions.
In addition, during the fiscal year ended March, 2017, we provided lessons involving the Compliance Handbook for Mitsui employees which explains the contents of the "Business Conduct Guidelines for Employees and Officers of Mitsui & Co., Ltd.", and also conducted online testing to ensure that employees in Japan who had not taken the testing last year understood the Handbook content. Through such activities, we are working to ensure that all management and employees have adequate knowledge related to compliance that they need to conduct of day-to-day business activities. Moreover, we newly prepared “Compliance Handbook for Mitsui Group companies” and distributed it to domestic Group companies upon request.
We also provide overseas operations and Group companies specifically-tailored compliance training that takes into account particularities of the regions in which they are located.
Compliance Awareness Survey
In order to understand and monitor the level of compliance awareness among executives and employees, we have conducted Compliance Awareness Surveys as appropriate not only in Mitsui & Co., Ltd., but also in our oversea offices and major subsidiaries. We use the survey results to address issues and implement a variety of measures to promote further compliance awareness and to reduce compliance problems.
In addition to the previously mentioned initiatives, we also visit individual key subsidiaries and associated companies to ensure adherence to best compliance practices at the Group level. In so doing, we gain a better understanding of compliance issues facing each company, thereby enabling us to offer advice geared toward helping those companies design and implement compliance programs that can be run autonomously and independently.
Throughout the fiscal year ending March, 2018, we will continue initiatives that call for even better communication needed to support more effective and more fully-instilled compliance program design and implementation in order to further make compliance an integral part of daily Group-wide operations.
Global Tax Management Policy
We are committed to meeting our tax compliance and simultaneously managing our global tax expenses. Our Global Tax Management Policy is available below.
Protecting Personal Information
We appointed a Chief Privacy Officer (CPO) and established a CPO office to work for heightening awareness among all management and staff of the importance of personal information protection in accordance with our Personal Information Protection Guideline and Regulations on the Protection of Personal Information.
As we have a broad spectrum of involvement in diverse commodities and services, we handle a large amount of personal information, particularly in B-to-C (business to consumer) business fields. Accordingly, we take extreme care to ensure that all data is protected. From the perspective of accident prevention, in addition to our education and training system, we appoint Personal Information Management Officers in each division. The Officers regularly review the status of personal information management in the daily course of business and enhance it as needed.
Ensuring Safety and Consumer Confidence
The Consumer Affairs Agency was established in September 2009 in order to proceed with the measures to protect and enhance consumer benefits and deliver a society where every consumer can enjoy a safe, secure and prosperous life. Likewise, Mitsui & Co. is also well aware of that consumer safety, confidence and security are of major importance in conducting its business.
With such concerns in mind, Mitsui has established its Consumer Product Handling Policy and Consumer Product Handling Regulations, and has also prepared detailed regulations for each business unit to ensure the appropriate handling of consumer products.
Moreover, in the foods area, Mitsui works to secure food products to supply Japan, which has the lowest rate of food self-sufficiency among the industrialized countries. Food Business Unit, Food & Retail Management Business Unit place maximum priority on food safety and security and accordingly has established internal rules and committee for food sanitation, maintains a food-safety database, and monitors related activities overseas down to the food production stages.
To manage the risk against food safety and security, we have been holding ongoing food safety seminars for our employees and those of Mitsui subsidiaries and associated companies, and have been redoubling efforts to ensure that details on labels such as country of origin, product quality, and product grade are accurate, and to facilitate product traceability.
When it comes to product safety and peace of mind, consumers can rest assured that the overriding priority that Mitsui places on ensuring the safety and security of consumer products and food extends to all of the items that we handle.
The Consumer Product Handling Policy
- Placing More Emphasis on the Consumer and Ensuring Product Safety
- Whether engaging in manufacturing, importing, or domestic marketing of consumer products, Mitsui reaches beyond its goal of providing products that offer cost savings or superior performance, and thereby additionally emphasizes a consumer-oriented approach by which the utmost priority is placed on handling safe products that consumers can use with total confidence. This policy is aligned with our management philosophy comprising our Mission, Vision and Values (MVV).
- Developing and Operating a Risk Management System
- To ensure that the Consumer Product Handling Policy functions in practice, we have developed a sound risk management system and are working to maintain and improve systems used in collecting, disseminating, and disclosing information on accidents involving products, and arranging for product recalls in the event of product-related accidents.
Information Risk Management
Based on the understanding that the proper management of information, which is an important business resource, is indispensable to us, we established the Information Risk Management Subcommittee under the Information Strategy Committee, which the Chief Information Officer (CIO) chairs. In accordance with our Information Security Policy, we have streamlined our Rules on Information System Management and the same on IT Security, so that we could maintain and keep enhancing Information Risk Management Systems.
With the advancement of ICT in business, both of our own and our affiliates, we established a dedicated department for cyber security dealing with cyber risks. It implements countermeasures and reviews consolidation of emergency systems.
Information Security Policy