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Ensuring compliance

Ensuring Compliance

“Compliance” serves as a vital component of a company as the foundation for achieving sustainable development.
The Group implements measures for spreading and establishing an awareness of “compliance” as a means to fostering an ethical corporate and organizational culture.

Spreading and Establishing an Awareness of Compliance

Our broad view of compliance encompasses such elements as corporate ethics and social norms in addition to legal compliance, reflecting our sincere determination to live up to our stakeholders’ expectations.
We are continually implementing new measures to enhance our Group-wide compliance framework, including domestic and overseas training aimed at realizing our steadfast commitment to improving compliance awareness among individual Group employees. We will strive to continue these initiatives in an aim to further spread and establish an awareness of compliance.

Activities Conducted to Raise Compliance Awareness

Since 2006, the Mitsubishi Materials Group has designated October as Corporate Ethics Month. Each October, the President posts a message on the Company intranet, and business sites and Group companies plan and conduct unique activities.
Recognizing the importance of establishing the Corporate Philosophy system among all our employees, we produce and distribute booklets, posters, cards, and a handbook for Group employees. The booklets, posters, cards, and handbooks for our group employees are created in 22 languages so that they can be used by employees worldwide. In fiscal 2021, the employee handbook case study collection was distributed via the intranet and used in training activities conducted by Group companies in Japan.
We are working to spread awareness of the SCQDE through training, education, posters and cards, etc.
We are striving to build an organization and corporate culture with good and healthy communication where employee has unrestricted communication, and we see these efforts as further enhancing Group governance and preventing compliance violations. To this end, we are working to strengthen communication through the dialog-based communication measures and training.
Additionally, through small group compliance activities, we are working to foster compliance awareness and improve workplace communication by having employees share a healthy sense of urgency, view issues as those that affect them, and exchange opinions.
Furthermore, we aim to strengthen initiatives throughout the group through initiatives such as establishing entertainment expense management rules and a global hotline.

Expanding and Reinforcing Compliance Education

We provide compliance education and training for Mitsubishi Materials Group employees in Japan and overseas by utilizing external instructors, e-learning, etc.
We have constructed a framework that enables every employee in every domestic Group company to participate in compliance and risk management training once a year. From fiscal 2021, we have been promoting online participation in this training. We also regularly conduct communication workshops and training by job grade, etc.
For overseas education and training on compliance and risk management, we consider training content while taking into account the circumstances in each region of the world, and in addition to group training at overseas regional headquarters, we have introduced online training since fiscal 2019 to efficiently conduct training in a wide range of regions.
Since 2018, our senior management and external lawyers have been providing governance training for directors of the Group companies in Japan. The training is designed to help them to understand the duties and roles that managers must fulfill with respect to governance and compliance, and to foster an awareness and acquire the means to fulfill them. Since fiscal 2022, the training has also been offered overseas.
Furthermore, since fiscal 2019, we have conducted annual surveys on the compliance awareness of all employees. We analyze the results of these surveys to help measure the effectiveness of various initiatives and promote them.

Number of Participants in Education and Training Program During Fiscal 2022 (including 53 Group companies)

  Number of Participants
CSR training at domestic facilities, branches and group companies 17,773
CSR education at overseas group companies 832
Position-specific training 795
Total 19,400
  • Subjects of the above data for education and training program hours include non-regular employees as well as regular employees.
  • The above disclosures include data for employees belonging to the Cement Business but do not include data for those belonging to the Aluminum Business.

Anticorruption Measures

Given the importance of preventing corruption, a global sustainable development challenge, in April 2018 we formulated our “Regulations for Combating Bribery of Public Officials, etc.” in order to help prevent bribery in our global business activities. We provide necessary support for the creation and operation of bribery prevention systems in Group companies.

In-house Reporting System

We established an Internal Contact Office in December 2002 in Japan as a consultation service to handle reports and inquiries from employees of Mitsubishi Materials Corporation and its Group companies. Since January 2020, we have contracted an external vendor to run the “Mitsubishi Materials Group Employee Hotline” for reports and inquiries, as well as improving the response systems of Group companies to ensure that we can appropriately respond to reports and inquiries and better respond to issues, while also strengthening the reliability of report and inquiry systems. We also established a contact office for Members of the Audit Committee in June 2018 to contribute to the work performed by members of the Audit Committee in promptly detecting incidents and initiating corrective measures.
Contact information for these reporting systems is printed on cards for employees of the Mitsubishi Materials Group to keep on their person and made available on our Group website and through each training activity.
On April 1, 2021, we established and began operation of the “MMC Group Global Hotline,” a global in-house reporting system for the Mitsubishi Materials Group. This in-house reporting system can be used by personnel in overseas Group companies and overseas sites (with some exceptions). The availability of the global in-house reporting system is made known to target overseas companies and sites. In Fiscal 2022, there was one report/inquiry received through the global in-house reporting system.

Numbers of Reports and Inquiries Received through the In-house Reporting System (FY)

2016 2017 2018 2019 2020 2021 2022
33 38 42 61 58 54 47

Measures for Rebuilding our Antimonopoly Act Compliance System

In September 2019, the Japan Fair Trade Commission (JFTC) issued a cease and desist order and a surcharge payment order to Universal Can Corporation, a Group company of that time, for violations of the Antimonopoly Act in the form of cartel activity. In response to this, from November 2019 onwards, the Group has engaged in various measures to rebuild its Antimonopoly Act compliance system.

  • Formulation of Antimonopoly Act compliance regulations for MMC and Japanese subsidiaries
  • Ongoing communiqués from top management regarding compliance with the Antimonopoly Act
  • Clarification of Antimonopoly Act compliance as part of the Group’s Code of Conduct
  • Review and revision of regulations regarding disciplinary actions for MMC and Japanese subsidiaries
  • Implementation of self-audits by MMC and Japanese subsidiaries, assessment of potential for Antimonopoly Act violations within each business segment
  • Design and implementation of measures at individual business sites in the form of risk management activities
  • Ongoing implementation and expansion of Antimonopoly Act compliance training
  • Review and revision of internal audits related to the Antimonopoly Act
  • Strengthening of measures against bid-rigging and transactions with competitors

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Intellectual Property Management

At the Mitsubishi Materials Group, we engage in activities to develop a portfolio of intellectual properties and intangible assets in line with our business and development strategies, manage intellectual property risks, respond to related disputes, and improve the level of the Group's intellectual property governance.

Governance

As the importance of intangible assets including intellectual property grows, we are reinforcing our governance systems related to intellectual property in compliance with the Corporate Governance Code and proactively disclose our initiatives related to intellectual property, such as our ‘Strategic Dialogue’, to external parties. Further, in May,2022, we have established the Intellectual Property Policy of Mitsubishi Materials Group, which indicates the direction of Group-wide intellectual property activities, based on the idea that we should maximize the value of intellectual property and intangible assets in a Group-wide manner.

Strategic Dialogue and Intellectual Property Creation

 We promote Strategic Dialogue between business divisions and intellectual property divisions aiming for strategic creation of intellectual property.
We will focus on the creation of intellectual property in line with our business strategies and the R&D strategies that support them, based on the analysis data using the IP Landscape. as we continue to build a powerful portfolio of intellectual property rights .

Data as of March 31, 2022

Number of patent applications Japan 318
Overseas 106
Number of registered patents Japan 3474
Overseas 3190
  • The number of patent applications is the number filed from April 2021 to March 2022.
  • The number of patent applications overseas indicates the number of patent families, as PCT is included.

Handling of Technology Contract Risks

By building and operating a database on technology contracts, such as non-disclosure agreements, we give advice on contracts related to our research, development and intellectual property matters, including advice about the prevention of the leakage of confidential information, the management of contract periods, and the consideration of wording in contracts.

Intellectual Property Education

 We organize a number of in-house educational programs on an ongoing basis, in an effort to improve understanding of how to establish and use intellectual property. The programs include position-specific training for employees from new recruits, young employees, and middle-level employees through to managerial-level employees, training geared towards obtaining intellectual property qualifications, and training given at business locations.

Enhancement of Countermeasures to Product Counterfeiting

As a countermeasure to address counterfeit cutting tools that are manufactured overseas, we have identified a large number of illegal operators who sell these products at local brick-and-mortar stores. Further, in fiscal 2021, we began to strengthen the monitoring and crackdowns of websites all over the world selling these products. We have deleted thousands of websites selling counterfeit products. We will continue to detect brick-and-mortar stores selling counterfeit goods and monitor websites selling these products, in our effort to eradicate counterfeit products.

Group-wide Expansion

We believe it is important to engage in initiatives related to governance, Strategic Dialogue and intellectual property creation, the handling of technology contract risks, intellectual property education, and the enhancement of countermeasures to product counterfeiting. We will expand these initiatives across the entire Group, instead of only engaging in them within Mitsubishi Materials Corporation, thus maintaining and improving the level of the Group's intellectual property governance, contributing to reducing intellectual property risks and maximizing the value of the Group's businesses.

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