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[Build an organization with integrity]

Sharing Values by Promoting the Concept of Integrity

Mitsui & Co. believes that, in business, trust is most important. In order to maintain and enhance trust, besides compliance with laws, regulations and rules, it is also vital for employees to be aware of the need for integrity, in terms of one’s own conscience and dignity.

To ensure that values relating to integrity and compliance are shared throughout the Mitsui & Co. group, we put together the Mitsui & Co. Group Conduct Guidelines “With Integrity” in November 2018.

In order for the Mitsui & Co. group to continue to be a corporate group that is genuinely trusted by society, we are taking steps on a global group basis to build an organization with integrity, in which individual employees will act with integrity.

Encouraging employees to think about what integrity is

Encouraging employees to think about what integrity is

The Compliance Department of Mitsui’s Legal Division is responsible for liaising with the managers overseeing compliance in each unit, for putting in place the overall compliance framework and compliance programs, and for responding to compliance issues when they occur. One of our most important missions is to promote the concept of integrity throughout the Mitsui & Co. group.

Mitsui has been actively using the term “integrity” in its efforts to enhance employees’ compliance awareness since April 2017. However, some employees were unsure as to what “integrity” (a word which has come into Japanese from English) actually meant. Integrity is inherently difficult to define, and difficult to find an exact Japanese equivalent for; we realized that there was a need to explain in an easy-to-understand way, Mitsui’s intention in adopting the concept of integrity, and how it differs from compliance. With this in mind, we have put together “With Integrity,” working in collaboration with many others in the company.

“With Integrity” defines integrity, in the sense in which it is used by the Mitsui & Co. group, as thinking for oneself about what is right, in light of one’s own conscience and dignity, and then acting accordingly. Actual examples of integrity would include, besides the obvious example of compliance with laws and regulations, respect for human rights and diversity, the elimination of discrimination, the cultivation of an open-minded corporate culture, and above all, acting honestly in accordance with the highest ethical standards.

Whereas compliance, which involves complying with laws, regulations and rules, has a heteronomous (i.e. imposed from outside) aspect to it, integrity could be considered as constituting a more autonomous approach. When viewing things only from the compliance perspective, there can be a rather “passive” stance of focusing only on complying with relevant laws, regulations and rules; this tends to lead to uncertainty when faced with situations that are not clearly addressed by the rules, and there is a risk that people may think that, because something is not explicitly prohibited by rules, it is acceptable to do it. At Mitsui, our recommendation is that, when dealing with this kind of situation, employees should think for themselves about what they should do in light of the principle of integrity, and then take appropriate action. “With Integrity” specifies three questions that can be useful when thinking about this type of issue: “Is it right?”, “Is it honest?” and “Is it ethical?” The important thing is to verify the appropriateness of our words and actions in light of our sense of integrity, and to consider what the right thing to do is.

In the past, compliance-related awarenessraising activities have tended to focus on asking employees to comply with laws, regulations and rules. By contrast, integrity has a more autonomous aspect to it; it is not something that the company forces employees to implement. For this reason, when promoting the concept of integrity, we have been rolling out programs that are deliberately designed to create opportunities for getting employees to think by themselves, and to discuss issues together with their colleagues. One example of this approach is sending out messages from senior management. On the blog of the Chief Compliance Officer (CCO) on Mitsui’s intranet, besides blog posts that are directly related to compliance operations, the CCO also posts about aspects of daily life that have a bearing on integrity. Sent out to all employees twice a month or so, these blog posts act as a catalyst for getting employees to think about integrity. We have often seen employees discussing the content of these blog posts among themselves, and employees who have read the blog sometimes contact the CCO directly with messages outlining what they think integrity means. In the future, we would like to continue to roll out initiatives that, rather than positioning integrity as something that is forced on employees by the company, instead help employees to think more deeply about integrity by getting them to think about the concept themselves and discuss it with others. Also, if while reading “With Integrity” an employee thinks “I don’t agree with this part,” then we hope that they will share their views with other employees. It is only through this kind of process that the concept of integrity as used at Mitsui can take on content that strikes a chord with everyone working for the company.

Speaking up is also an aspect of integrity

Speaking up is also an aspect of integrity

“Speak Up” is another concept that we are working to promote in parallel with integrity. The “Speak Up” initiative aims to foster the development of a corporate culture in which employees who feel that something is wrong will speak up about it, and make effective use of the company’s internal whistleblowing system. There is a tendency for people to have reservations about internal whistleblowing systems, and to be embarrassed about using them. However, at Mitsui we see the internal whistleblowing system as constituting a very effective means for identifying problems at an early stage so that we can nip them in the bud; we actively encourage employees to report problems, rather than pretending that they haven’t noticed them. Possibly as a result of the “Speak Up” initiative, there has been an increase in the number of reports submitted via the company’s internal whistleblowing system, and we are in the process of developing a more open internal environment in which employees feel comfortable about using the system. When employees speak up about problems that in the past they would have tended to ignore or adopt a laissez-faire attitude towards, this can be a first step towards solving those problems.

Employees’ integrity can enhance the level of trust that people have in the company

If a company is not trusted by society, then that company will not be able to achieve sustainable growth. Building this trust depends on the trustworthiness of individual employees, in terms of compliance and integrity. We believe that, if every one of us always acts with integrity, and speaks up without hesitation when we feel that something is wrong, then we can build an even better company.