Compliance & Risk Management
Mitsui & Co. considers a sound reputation to be the foundation of business, and recognizes that compliance is the prerequisite for maintaining our reputation and trust from society.
In order for the Mitsui & Co. global group to become a truly trustworthy corporate group for society, we make serious efforts to heighten awareness among all officers and employees of the importance of upholding "Integrity" and to build a global-group compliance framework. "Integrity" here means more than compliance with laws, regulations and rules, and it refers to an employee's ability to act honestly and ethically with a high degree of dignity and respectability, to use good judgment in connection with his/her business activities, and to behave with common courtesy and in accordance with business ethics and social norms.
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 and officer should act in his or her daily activities, from the perspective of compliance with laws and regulations, internal rules, and corporate ethics. The Business Conduct Guidelines help us fulfill our corporate social responsibility (CSR) and gain the trust of our stakeholders. They have been revised from time to time since their establishment in February 2001, to reflect the changes of the times.
To ensure that all our employees develop a proper understanding of the Business Conduct Guidelines, we implement training and e-learning courses, and at the same time, we require all employees to pledge to comply with the Business Conduct Guidelines. Likewise, each our global group company has formulated and implemented its own individual business conduct guidelines, based on the "Business Conduct Guidelines for Employees and Officers of Mitsui & Co., Ltd.", that suits its specific business activities. In addition, we have put in place business conduct guidelines in our overseas business locations, reflecting the local laws and regulations, and customary practices 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 Department of the Legal Division leads compliance-related initiatives on a global group basis under the direction and supervision of the Chief Compliance Officer (CCO) and in collaboration with the Compliance Supervising Officers appointed in each of Mitsui.'s domestic and overseas business units, and branches and offices. The objectives of these efforts implemented on the Mitsui & Co. global group basis are to: (i) heighten compliance awareness, (ii) improve and strengthen compliance programs, and (iii) respond to specific compliance issues as they arise.
In addition, the Compliance Committee has been established as a forum for discussions relating to the promotion of compliance with laws and regulations, and ethical standards across our global group as a whole. With the participation of external attorneys, the Compliance Committee discusses various issues that have arisen in the group, and discussion outcomes are made available on the company intranet.
Specific measures carried out include conducting thoroughgoing supervision at workplaces, implementing preventive anticorruption measures through the management of business entertainment for public officials and appointment of sales 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 in order to prevent misconduct. With respect to anti-corruption, we have published.
Facilitating Communication and Improving the Internal Whistleblowing System
We believe that the essence of compliance lies in the continual efforts to develop an open working environment which embodies our management philosophy and values and facilitates transparent and smooth communication within the Mitsui & Co. global group.
In case some problem arises, a report must be immediately made to one's superior or relevant persons, so that the problem can be properly addressed in a timely manner.
Mitsui has established eight channels for raising compliance concerns, including internal reporting lines to external attorneys or third parties that promise anonymity.
We have established the rules on a whistleblowing system which clearly stipulate that no employee will suffer any form of disadvantage for raising any compliance concern. Furthermore, we have made available to our group companies in Japan the use of Mitsui's designated external attorneys and third parties as their external reporting channels to ensure a system in which issues emerged in our group companies can be reported with a sense of security, through the appropriate establishment and operations of the whistleblowing system.
Furthermore, at our overseas offices and affiliated companies, our regional Compliance Supervising Officers are taking the lead in developing reporting and consultation channels, also taking into consideration local laws and regulations, as well as specific local customary practices at each country.
Effective Education and Training
Mitsui provides employees with a wide range of compliance training programs to promote a high degree of awareness of business ethics throughout the company 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 2018, we provided such training for employees at all levels, including new employees and line managers, as well as for our employees being transferred overseas or being seconded to group companies. We also provides an extensive program of compliance training for officers and employees of group companies. In November 2017, we conducted "Compliance Review Week", in which we held a seminar about compliance issues that everyone might encounter, in addition to sharing information and exchanging opinions.
In addition, during the fiscal year ended March 2018, we provided lessons involving the Compliance Handbook for our 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 test last year understand the Handbook's content. Through such activities, we are working to ensure that all management and employees have the compliance-related knowledge they need to conduct day-to-day business activities. Moreover, we distributed "Compliance Handbook for Mitsui & Co. Group Companies", which was newly prepared last year to domestic group companies upon request.
We also provide overseas offices 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 the level of compliance awareness among officers and employees, we have conducted Compliance Awareness Surveys not only at Mitsui (non-consolidated), but on a global group basis, as needed. We utilize the survey results to address issues and implement a variety of measures to further promote compliance awareness.
In addition to the previously mentioned initiatives, we also visit individual key affiliated companies in order to ensure adherence to compliance at the global group level. By gaining a better understanding of compliance issues facing each company, we provide advice geared toward helping those companies autonomously design and implement compliance programs.
Throughout the fiscal year ending March 2019, we will strive to make compliance an integral part of daily work in our global group operations, by continuing to support group companies to help them develop and implement compliance programs more effectively, in order to instill the importance of compliance among their employees. For this, we will further deepen communication and information exchanges.
Global Tax Management Policy
We are committed to complying with our tax obligations and simultaneously managing our global tax costs. Our Global Tax Management Policy is available below.
Protecting Personal Information and Information Risk Management
Protecting Personal Information
We have 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 the Personal Information Protection Guidelines and Rules 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 pay particular care to ensure that all data is protected. From the perspective of accident prevention, in addition to our education and training systems, we appoint a Personal Information Management Officer 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 promote measures to protect and enhance consumer benefits and deliver a society where every consumer can enjoy a safe, secure and high-quality 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, we have established the Consumer Product Handling Policy and Consumer Product Handling Regulations, and each individual business unit has also established detailed rules to ensure the appropriate handling of consumer products.
Moreover, in the foods area, Mitsui works to secure food products for supply to Japan, which has the lowest rate of food self-sufficiency rate among the industrialized countries. The Food Business Unit and the Food & Retail Management Business Unit place maximum priority on food safety and security and, accordingly, have established internal rules and internal committees for food sanitation and developed a food-safety database, which includes overseas production processes.
To manage risks associated with food safety and security, we have been implementing food safety seminars for our employees, as well as our affiliated companies, in order to reinforce traceability through appropriate labeling for the indication of country of origin, product quality, and product grade, and other key information.
Mitsui places consumer safety and security first for all items it handles, not just consumer products and food.
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 is chaired by the Chief Information Officer (CIO). In accordance with our Information Security Policy, we have developed the Rules on Information System Management and the Rules on IT Security, in order to maintain and keep enhancing our information risk management systems.
Information Security Policy
In line with the advancement of information and communications technology (ICT) in business at Mitsui & Co., as well as at our affiliated companies, Mitsui & Co. group companies continue enhancing the cyber security framework, including the establishment of a dedicated unit to tackle cyber security, which examines and implements cyberattack countermeasures.