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Gate 4 Management Foundation

An Organization with Integrity

Takashi Masuda, the first president of the former Mitsui,* once said, “Let not short-term gains tempt your mind, seek only enduring prosperity by embracing grand aspirations.” Since then, the Mitsui Group has inherited the spirit of working with high aspirations to realize valuable business that is truly required by society.

We believe that business is built on a foundation of trust, and compliance is necessary to maintain and foster such trust. In our pursuit of compliance, it is not enough simply to follow laws, regulations, and norms. It is also extremely important that we continually verify the appropriateness of our words and actions against our sense of integrity. With these ideas forming the foundation of our business, Mitsui’s Corporate Management Philosophy (Mission, Vision, Values) also embodies these concepts of integrity that each and every employee on a Global Group basis cherishes while acting with an awareness of compliance.

From a legal perspective, there is no continuity between the former Mitsui & Co. and the present Mitsui & Co., and they are totally separate corporate entities.

Mitsui & Co. Group Conduct Guidelines—“With Integrity”

It is essential that Mitsui & Co. and each of the Mitsui Group’s companies act with the highest levels of integrity and compliance, sharing our approach toward integrity and compliance on a Group basis to continue achieving sustainable growth as a Group and earning the trust of society. With this in mind, in November 2018 we put together the Mitsui & Co. Group Conduct Guidelines—“With Integrity.” These guidelines are reflected in each company’s corporate philosophy (MVV) and business conduct guidelines. As every officer and employee across the entire Group puts these conduct guidelines into practice in their daily work activities, the Mitsui Group faithfully and sincerely respects the trust placed in us by society.

Mitsui & Co. Group Conduct Guidelines—“With Integrity” Mitsui & Co. Group Conduct Guidelines—“With Integrity”

Initiatives to Build an Organization with Integrity

To continue to be a corporate group that is truly trusted by society, we are working to rigorously reinforce compliance awareness with each employee. We are also asking employees to maintain a proper awareness and level of dignity as a member of a corporation, or in other words, to act with integrity. In these ways, we are working to build an organization with integrity on a Global Group level.

Compliance Framework

Mitsui promotes 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 business units, and branches and offices in Japan and overseas. Initiatives of these Groupwide efforts include heightening awareness of integrity and compliance, improving and strengthening compliance programs, and responding to specific compliance issues as they arise. Furthermore, Compliance Administrators have been established in each business unit to provide assistance to the Compliance Supervising Officers. Based on the frontline conditions in each business, the Compliance Supervising Officers and Compliance Administrators promote a thorough response to compliance, including the implementation of initiatives to prevent the occurrence or recurrence of compliance-related issues as well as the promotion of integrity.

Also, to serve as an organization that operates under the Corporate Management Committee, Mitsui established the Compliance Committee, which works to develop our compliance framework and maintain and improve its effectiveness. With the participation of external attorneys, the Compliance Committee meets twice a year to discuss the state of the action plans based on trends in compliance-related matters, arising issues, and the overall compliance framework. The minutes of the committee meetings are shared among all of our officers and employees.

Across the entire Group, we aim to bolster the management capabilities, including enhancing integrity, and strengthen compliance at affiliated companies through their own efforts by having each company thoroughly discuss and put into practice our “Guidelines on the Establishment of Compliance Systems at Affiliated Companies,” a set of key rules and principles that are the bare essentials for operating compliance systems at affiliated companies. Furthermore, we periodically hold the Mitsui & Co. Group CCO Meeting, attended by CCOs from domestic affiliated companies, and regional CCO meetings at overseas bases to share knowledge and exchange information and opinions on a Global Group basis, in addition to implementing compliance measures at overseas bases that are designed for each region.

Compliance Programs

We believe that even if detailed, fine-tuned integrity and compliance programs are formulated, their effectiveness cannot be reinforced without senior executives taking the lead in related initiatives. By leveraging the Mitsui & Co. Group Conduct Guidelines—“With Integrity,” the CCO blog, and other efforts, we are continuously striving to instill an awareness of compliance while providing as many opportunities as possible to learn about compliance, including training programs. In these ways, we share lessons and important points of concern on compliance. We have designated November of each year as “With Integrity Month,” and have provided opportunities for every officer and employee to think more deeply about integrity by having the president give talks about integrity and having senior executives take the lead on reminding everyone that compliance and integrity are the foundation of our businesses. Any cases of compliance violations are handled strictly, including disciplinary actions, and measures to prevent a recurrence are formulated and implemented in accordance with our Working Regulations.

Compliance Programs

Compliance Programs

Meeting in November 2019

Fostering a “Speak Up” Culture

Fostering a “Speak Up” Culture

We believe that the essence of compliance lies in the development of an open working environment that reflects our management philosophy and values, so that problems can be prevented through smooth communication. At the same time, we strive to form open and innovative workplaces, and make concerted efforts to improve productivity and management capabilities while making workplaces better and encouraging employees to grow. Should problems occur, a report must be immediately made to superiors or to those in charge, so that appropriate action can be taken in a timely manner. We recognize the importance of discovering problems at an early stage, and we are actively fostering a culture in which people speak up when they become aware of issues. Senior executives continually disseminate the message that we can improve the Company by speaking up about issues.

The Company has established eight channels for reporting compliance-related matters within or outside of the administrative chain of command, including anonymous access to attorneys and independent organizations outside of Mitsui. The rules for the whistleblowing system prohibit any form of retaliation against or disadvantageous treatment of whistleblowers. We also clearly state that any infractions of this prohibition or any form of retaliation against or disadvantageous treatment of whistleblowers or investigators will be dealt with severely, thereby encouraging employees to speak up. Furthermore, Mitsui has introduced the Global Group Hotline, a special whistleblowing hotline for reporting and seeking advice regarding cases that breach the laws of Japan or another country in relation to anti-trust (monopoly) laws or anti-corruption laws, or cases that give rise to suspicion of such breaches. Under the system, the Compliance Department of the Legal Division of Head Office becomes a unified channel by which to receive whistleblowing reports from overseas trading affiliates, and other subsidiaries in Japan and overseas. Also, officers and employees of Group companies are able to seek advice directly through Mitsui’s whistleblowing system when the issues are related to officers and employees of Mitsui or when the issues could have a serious impact on the Mitsui Group.