As stated in the Mission Statement of our Sustainability Policy, MITSUBA Group is working together as a group to promote compliance initiatives in order to meet the expectations of the society and be a company that is trustworthy.
MITSUBA Group believes that it is essential to gain the trust of stakeholders through the actions of its executives and employees in conducting its business activities. Based on this idea, we established the code of conduct called “How We Should Act,” in 2015, which specifies the sustainability actions that the MITSUBA Group executives and employees should practice on a daily basis. In 2019, we established the Group Compliance and Risk Management Regulations and clearly defined “How We Should Act” as the MITSUBA Group's common code of conduct.
Moreover, the President / Representative Director issued a request to the Group executives and employees to practice “How We Should Act,” and expects each and every one of them to be aware of sustainability actions, including compliance, and to act with high level of ethics.
To strengthen its compliance system, MITSUBA has established the so-called “three defense lines” (raising awareness on-site, management by the Legal Department, and implementation of internal audits by the Audit Office), to build a system that ensures thorough compliance with laws and regulations. Moreover, decisions on important matters concerning compliance and risk management initiatives in MITSUBA Group are made in the ESG committee. Details of discussions, resolutions, and progress made in the ESG committee are reported to the MITSUBA Board of Directors through the MITSUBA management meeting.
MITSUBA Group has set up the “MITSUBA Comprehensive Consultation Desk,” both internally and externally (at law firms), where employees can report and consult about “corporate ethics” and “compliance.” All reported or consulted cases are investigated and appropriate measures are taken to resolve them. When operating the consultation desk, we ensure that it is managed in a way that protects the privacy of whistleblowers or individuals seeking advice and prevents any disadvantage to them, allowing them to use the service with peace of mind. Moreover, our internal rules clearly state the penalties that will be imposed for any unfavorable treatment of whistleblowers and individuals seeking advice.
The MITSUBA Group is working to foster compliance awareness throughout the Group by distributing portable cards with the Group Code of Conduct, "How We Should Act.“ In addition, we conduct compliance education by theme, such as the Antitrust Law, as part of our stratified education. Moreover, once a year, at the “Personnel Labor Management Meeting” for MITSUBA managers, we provide various education according to roles and duties, such as education on the Labor Standards Act, daily labor management, and harassment.
Regarding the Antitrust Law and the Subcontract Law, MITSUBA Group has established an "Antitrust Law Compliance Manual" and provides regular education to prevent anti-competitive behavior. When MITSUBA Group employees come into contact with competitors, prior application and post-event reporting are carried out, and thorough measures are taken to prevent acts that could be suspected of violating the Antitrust Law, as well as offer global e-learning courses. Moreover, the internal rules clearly state the penalties for violations of the law.
In the FY 2024, there were no cases of fines, terminations or other incidents related to anti-competitive behavior.
The MITSUBA Group has issued and is implementing the "Anti-Bribery and Anti-Corruption Guidelines". These guidelines clarify the behavior required of MITSUBA Group employees, mainly by indicating prohibited acts when interacting with public officials. Moreover, aside from preventing bribery of public officials, the law also calls for thorough implementation of fair transactions with private suppliers. The internal rules clearly state the penalties for violations of the law.
In FY 2024, there were no cases of fines, terminations or other incidents related to corruption. Moreover, since FY 2024, we have been holding confirmation meetings with overseas group companies. Through discussions with the relevant personnel, we grasp the local situation regarding anti-corruption and provide education, thereby raising understanding of the importance of bribery risks and awareness of how to prevent them from occurring.
MITSUBA undergoes regular (once a year) sustainability performance evaluations by a third-party organization and strives to maintain and improve the system by incorporating any compliance-related issues that emerge into the next fiscal year's plan. Furthermore, based on Group standards related to sustainability, each Group company conducts a self-evaluation periodically (once a year) using a check sheet. The compliance-related questions in the check sheet are based on compliance items that should be considered in the MITSUBA Group's corporate activities, such as export transactions and intellectual property, in addition to Competition Law and Anti-corruption. Based on the results of self-evaluation by each group company, the MITSUBA Group analyzes compliance issues and develops specific measures for correction and improvement. Through these efforts, MITSUBA aims to reduce compliance risks across the entire group.
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