Creating a Safe and Healthy Workplace Environment

Purpose of activities	Activities during fiscal 2022	Self- assessment	Targets/plans for activities from fiscal 2023 onwards
Promoting safety and health activities	Promote the Zero Occupational Accident Project	C	Not causing any occupational accident resulting in four or more lost days for 365 days
	Thorough equipment safety through risk assessment (to be implemented in 3 years)	B	Make efforts to ensure equipment safety based on risk assessments (to be implemented over a three-year period)
	Promote safety and health education through effective utilization of the Occupational Safety & Health Education Center and promote Virtual Reality accident simulation training	A	Continue to promote safety and health education through effective utilization of the Occupational Safety & Health Education Center and continue to promote Virtual Reality accident simulation training
	Promoting health and productivity management	A	Continue to promote health and productivity management
	Enhancing mental healthcare initiatives	A	Enhancing mental healthcare initiatives

Self-assessment grades A: Target achieved B: Target mostly achieved C: Target not achieved

Basic Approach

In the MMC Group Code of Conduct, we vow to “We are committed to providing a safe and healthy environment for all our stakeholders.” This is based on the notion that, if we can’t keep our employees safe and healthy, they won’t be able to provide secure and happy lives for their families, we won’t be able to operate effectively, and we will never be able to keep on expanding as a company.

MMC Group Basic Policy on Safety and Health Management

1. We will carry out safety and health activities based on full participation from all employees, underpinned by leadership and initiative from the President and other managing personnel.
2. We will ensure that all employees comply with the Industrial Safety and Health Act and other applicable legislation, manuals and operating procedures, and establish a workplace culture whereby everyone follows the rules and ensures that others do too.
3. We will make every effort to create pleasant workplaces that are healthy for both body and mind, for all employees, through activities aimed at creating open workplaces and promoting health.
4. We will take preventive measures in accordance with Ministry of Health, Labour and Welfare guidelines on the prevention of work-related traffic accidents and improve road etiquette amongst all employees, in order to eliminate traffic accidents based on our commitment to promoting road safety activities as an example to society as a whole.

And since 2018, we have declared that among the goals represented by SCQDE enacted as the guideline to decision-making concerning conduct of our work (priority order), “S” which represents “Safety and Health” is the first priority.

Guideline to decisionmaking concerning conduct of our work (priority order)

Let's act while recognizing the order of priority, "SCQDE"

1	ＳSafety & Health	Safety & Health come first
2	CCompliance & Environment	Compliance & Environment to ensure fair activities
3	QQuality	Quality of products and services provided to our "customers"
4	DDelivery	Delivery dates to be met
5	EEarnings	Reasonable profit (Obtained based on “customer” trust after satisfying SCQD)

“SCQDE” shows the order of priority of our business decisions. In providing customers with our products & services, we should thoroughly fulfill SCQ at first and satisfy D. We believe that we will be able to obtain trust from customers and society by continuously executing SCQD in good faith, and this will produce a reasonable profit.

Framework

In the wake of the fire and explosion at our Yokkaichi Plant in January 2014, we launched a new Zero Occupational Accident Project in April that same year, and set about strengthening the foundations of safety and health on a groupwide scale, with the aim of eliminating serious occupational accidents resulting in four or more lost days (not causing any occupational accident resulting in four or more lost days for one year).
The Zero Occupational Accident Project is led by the Zero Occupational Accident Subcommittee, which serves as a special subcommittee under the Sustainable Management Office headed by the Chief Executive Officer.
Based on factors including occupational accidents that have occurred, the Zero Occupational Accident Subcommittee, which consists of Safety Coordinators from the departments, identifies priority issues that our Group should tackle, sets priority tasks for safety and health management through exchanges of opinions with the Zero Accident Labor-Management Meeting, which consists of management and labor union members, and strives to make improvements through the PDCA cycle in accordance with the situations of each facility.
Specific measures for the Zero Occupational Accident Project are implemented after deliberations and approval at the Strategic Management Committee and their progress is regularly reported to the Sustainable Management Office.
Implementation of each measure revolves around the Mitsubishi Materials Safety, Environment & Quality Department. With Safety Coordinators appointed at each in-house company, we share information regarding progress and issues with safety and health measures at business sites under their management, including Group companies, and discuss solutions to the issues at monthly meetings with the Safety, Environment & Quality Department.
We have an integrated groupwide promotion framework in place whereby matters that extend beyond the confines of individual companies are reported and discussed at the above-mentioned Zero Occupational Accident Subcommittee.
At the same time, the occupational safety and health management systems are operated at individual business sites. In addition, Safety Managers, Safety Coordinators and Safety Instructors are assigned to individual business sites, where their role is to promote safety activities. We hold regular Groupwide Safety Manager meetings and meetings for Safety Coordinators and Safety Instructors, where we exchange openings on a wide range of occupational accident information and health and safety activities across the Group and the various business sectors in which it is involved, and endeavor to raise the level of health and safety.

Management Priorities

To expand the joint labor-management initiative to achieve zero occupational accidents, we have identified issues at the MMC Group in light of occupational accidents, etc. that occurred last year, engaged in joint labor-management discussions on the particular items to be addressed to achieve solutions, and designated management priorities on that basis. In 2021, we set out the following management priorities, and rolled out occupational safety and health management systems at each of our plants/factories accordingly.

Group-wide Priorities for Safety and Health Management (2021)

Thorough Efforts to Make Equipment Safe (engineering measures) through Risk Assessments (RA)

While the number of serious occupational accidents related to machines and electricity and those related to handled materials caused by equipment has been decreasing in the long term, there remains residual risk that we have yet to reduce, and not a few accidents have occurred due to unrecognized hazard sources. In response, we decided to examine the appropriateness of risk assessments that we have conducted to date, over a period of three years from FY2021, in our attempt to review requirements. We take the following actions.

• To identify new risks and lower the risk level
• Checking for hazard sources and dangerous tasks that had yet to be identified
• Reassessments of risks which have been identified and corrective actions against insufficient measures
• Promotion of inherent safety of existing equipment
• To improve risk assessment ability, etc.

An analysis of the types of occupational accidents occurring at the MMC Group has revealed that many occupational accidents occur due to two factors: “flawed protective and safety measures” such as incomplete safety measures for machinery and equipment, and “proximity to dangerous areas,” such as touching machinery or equipment while it is operating. To strengthen the physical measures in place by reviewing structures and mechanisms from the perspectives of the foolproof*¹ and failsafe*², we are employing thorough engineering-based action through risk assessments.
Further, with respect to occupational accidents caused by “flawed operating methods” such as the use of inappropriate tools and jigs or incorrect operating procedures, we will strive to make risk assessment-based improvements including the verification of operating methods, and revised operating procedures that reflect hazard prediction. Risk assessment is an effective means of discovering, eliminating or mitigating potential danger or harm attributable to operating practices and other work performed at a manufacturing site. At the MMC Group, we implement risk assessment activities from the perspective of workers on the production floor at each business sites. We have trained risk assessment instructors at each business site to improve their ability to identify unsafe equipment states and began offering training classes in October 2015. As of March 2020, more than 520 people have taken the course (although classes could not be held from April 2020 onward due to the impact of COVID-19). Centering on these instructors, the course is contributing to enhancing and stimulating on-site activities. In addition, since August 2020, we have been conducting risk assessment classes by remote learning, led primarily by front line supervisors with the aim of raising the ability level of personnel who conduct risk assessments. As of March 2022, 419 people have received training in those classes.

• *1 Foolproof: A function that prevents human error from resulting in an occupational incident or disaster
• *2 Failsafe: A function ensuring that equipment will operate on the safe side in the event of mechanical malfunction, power outage or otherwise

Safety Record

State of Occurrence of Occupational Accidents

The number of employees involved in occupational accidents (injuries without lost time) in the Company and at 20 major Group companies stood at 164 in 2021. Sadly, 40 of these were accidents requiring employees to take leave. The number of accidents at the Company, on a non-consolidated basis, has been showing a downward trend for the past ten years, but it has leveled off in recent years. (The number of business sites increased by two as a result of the merger of the former Mitsubishi Shindoh Co., Ltd. in April 2020.) The accident frequency rate which evaluates the state of occurrence of occupational accidents taking place at the Company (LTIFR (Lost-Time Injury Frequency Rate): casualties per million actual hours worked (employees taking time off work)) was 0.21; a lower figure than the 2021 manufacturing business average of 1.31 (Ministry of Health, Labour and Welfare (MHLW) statistical data). The accident frequency rate including accidents not requiring employees to take leave (TRIFR (Total Recordable Injury Frequency Rate): casualties per million actual hours worked including accidents not requiring employees to take leave) was 1.68.
In 2022, too, we worked thoroughly to further increase the safety of facilities through risk assessments, added further measures to prevent accidents, and made other efforts toward achieving our zero accident target.

Safety Record Trend (Mitsubishi Materials)

Breakdown of Safety Performance

		2018	2019	2020	2021
MMC (non-consolidated)	Fatal	0	0	0	0
	Lost-time (or more serious)	4	2	7	3
	No lost-time	20	18	21	21
MMC (subcontractors)	Fatal	0	0	0	0
	Lost-time (or more serious)	10	2	4	10
	No lost-time	13	18	19	17
Group companies (Incl. subcontractors)	Fatal	0	0	1	0
	Lost-time (or more serious)	31	30	13	27
	No lost-time	95	120	83	86
Total	Fatal	0	0	1	0
	Lost-time (or more serious)	45	34	24	40
	No lost-time	128	156	123	124

Injury Frequency Rate Trend

		2018	2019	2020	2021
MMC (non-consolidated)	LTIFR	0.34	0.17	0.51	0.21
	TRIFR	2.05	1.68	2.03	1.68
MMC (subcontractors)	LTIFR	2.09	0.45	0.85	2.27
	TRIFR	4.82	4.49	4.92	6.12

• * LTIFR (Lost-Time Injury Frequency Rate): casualties per million actual hours worked (number of victims of accidents requiring employees to take leave including deaths) = accident frequency rate
  TRIFR (Total Recordable Injury Frequency Rate): casualties per million actual hours worked (number of victims of accidents requiring employees to take leave including deaths + number of victims of accidents not requiring employees to take leave)

State of Occurrence of Fires and Explosions.

In 2021, there were 16 accidents (fires and explosions, etc.) at the Company. They include two cases of fire, where it took a certain amount of time before the accident ended. However, all of the other 14 accidents were minor ones scoring 3 points or less (with 13 of them scoring 1 point or less) under our internal accident evaluation standards, which are a measure of the magnitude of damage and impact. There was no explosion in 2021. There were zero (0) Tier 1 process safety events (PSEs) per million hours. The Company bases its definition of PSEs on the CCPS definition. ^※
However, partly because the total number of accidents was much higher than in the previous year (seven), we will continue to pursue initiatives that focus on fire prevention through the internal proliferation of accident data, among other measures.

• * Tabulated values are for the company (non-consolidated) for the calendar year. Tier 1 PSE (Process Safety Events) are identified based on the "Process Safety Metrics: Guide for Selecting Leading and Lagging Metrics" Version 3.2 issued by CCSP.

Occurrence of Fires and Explosions, etc.

	2018		2019		2020		2021
	Number of accidents	Score	Number of accidents	Score	Number of accidents	Score	Number of accidents	Score
Fire	4	3.8	5	2.2	6	5.1	10	18.3
Explosion	1	0.6	1	0.3	0	0.0	0	0.0
Leakage, etc.	1	0.6	4	1.9	1	0.3	6	1.8
Total	6	5.0	10	4.4	7	5.4	16	20.1

MMC-method Accident Assessment Criteria

Severity level (points)	Assessment items
	Human injury	Property damage	Impact of leakage/spill  (Leakage of high-pressure gas, spill of hazardous material)	Time it takes before a fire is extinguished (Duration of time between occurrence and extinguishment of a fire)
Ⅴ（27）	Multiple deaths	Property damage outside the premises	Impact on a wide area outside the premises, such as a river	4 hours or longer
Ⅳ（ 9）	One death or multiple lost days	Property damage to adjacent facilities on the premises	Impact on the area around the premises	2 - 4 hours
Ⅲ（ 3）	Lost time injury	Burnout or damage to the building with equipment as the fire source	Impact on adjacent facilities on the premises	1 - 2 hours
Ⅱ（ 1）	Injury without lost time	Burnout or damage of the equipment as the fire source, or minor damage to a part of the building with such equipment	Leakage/spill only inside the building with equipment as the fire source or inside protective facilities such as dikes	30 minutes - 1 hour
Ⅰ（0.3）	Below Level II (Minor incidents)	Below Level II (Minor damage to a part of the equipment as the fire source)	Below Level II (Minor leakage/spill)	Shorter than 30 minutes

• * Set by referring to accident assessment criteria of the Japan Petroleum Industry Association and the severity indicators for fire and spill accidents at dangerous facilities, which were notified by the Fire and Disaster Management Agency
• * To be evaluated based on the total number of points, or sum of the points for the intensity level of each evaluation item that applies
• * The number of points shall be zero (0) if none of the intensity levels applies.