“Compliance” is an important part of the foundation for the sustainable development of a company. The Group implements measures for spreading and establishing an awareness of “compliance” as a means to fostering an ethical corporate and organizational culture. The "Code of Conduct" is overseen by the Board of Directors, and the establishment and revision of it are also determined and decided by the Board of Directors.
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 improved compliance awareness among individual Group employees. We will continue these initiatives with the aim of further spreading and establishing compliance awareness.
In addition, quickly and accurately consolidating and sharing information on compliance violations that have happened within the Group (not only legal and regulatory violations but violations of corporate ethics, codes of conduct and internal regulations, including the possibility of such violations) leads to an appropriate response to violations and helps prevent recurrences by having the information reflected in risk management activities, education, training and other action.
Our Chief Governance Officer (CGO), who is one of our Executive Officers, oversees compliance, and under supervision of the CGO, efforts are made to comply with the Code of Conduct. Additionally, the status of compliance including adherence to the Code of Conduct and other matters, is regularly reported to the Board of Directors.
Since 2006, the Mitsubishi Materials Group has designated October as Corporate Ethics Month. Each October, the CEO posts a message on the Company intranet, and business sites and Group companies plan and conduct unique activities.
ReRecognizing the importance of establishing our Corporate Philosophy, Vision, Mission, Values, Code of Conduct and Our Commitment among all our employees, we have produced cards and handbooks (Basic Edition) for our Group employees in 19 languages. The cards are distributed to sites around the world, posted to the Company intranet, and used in education and training activities. Furthermore, for domestic use we have produced employee handbook (Case Study Edition). This edition is posted to the Company intranet in Japan and used by domestic Group companies for educational activities. It is designed to deepen understanding of the Code of Conduct by explaining familiar cases that could possibly occur, and covers examples such as the prohibition of forced labor, prevention of power harassment, sexual harassment, occupational health and safety, health management, quality control, anti-corruption and legal compliance issues such as the Antimonopoly Act, Subcontract Act and Foreign Exchange and Foreign Trade Act.
Particularly with regard to harassment, in addition to formulating Harassment Prevention Guidelines, we have taken up harassment prevention as one of the themes of awareness-raising efforts through training videos targeting all employees and online training for the managers responsibility for promoting compliance activities at their respective workplaces. We also provide training for the staff tasked with work related to in-house reporting, including cases of harassment.
We are working to spread awareness of the SCQDE through training, education, posters and cards, etc.
Across the Group 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 dialogue-focused town hall meetings, training and other measures.
Additionally, through small group compliance activities, we are working to foster compliance awareness and improve workplace communication by having each employee share a healthy sense of urgency, view issues as those that affect them, and exchange opinions.
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. In addition to general compliance themes, the curriculum includes topics on the Antimonopoly Act, harassment, and the prevention of bribery and other forms of corruption. In fiscal2023, sessions were conducted on the themes of "Explanation of the In-house Reporting System," "Prevention of Power Harassment," "Compliance with Antimonopoly Laws," and "Reaffirmation of Entertainment Expense Management Regulations." We also regularly conduct training by job grade, etc.
For overseas education and training on compliance, we consider training content while taking into account the circumstances in each region of the world. In addition to the distribution of training videos in multiple languages, we efficiently conduct training in a wide range of regions through interactive training that places an emphasis on communication.
Since fiscal 2019, our senior management and external lawyers have been providing governance training for directors of the Group companies in Japan. The training is aimed at helping 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. In fiscal 2022 we also began offering this training overseas. In addition to senior management, the training is provided by outside experts who are familiar with circumstances 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 (aggregated) |
|
|---|---|
| Compliance education at domestic facilities, branches and Group companies | 16,311 |
| Compliance education at overseas Group companies | 363 |
| Position-specific education | 4,500 |
| Total | ★21,214 |
The Group’s Code of Conduct does not tolerate corrupt behavior in any form. It prohibits all forms of corruption including giving and receiving gifts and entertainment, stipulates that the content, frequency and monetary amounts involved with any such activities be consistent with social norms, requires that political activities and political contributions always be carried out through fair and honest means, and stipulates that we must endeavor to maintain healthy and normal relationships with politics and government.
In April 2022, the Mitsubishi Materials Group Entertainment Expense Management Regulations were established for the Company and domestic Group companies. The regulations require that business entertainment, gifts and the like always be limited in their nature, frequency and monetary value in light of social norms.
In addition, 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. The regulations prohibit the bribery of foreign public officials and others directly or through agents (third parties brokering transactions), and require that engaging the services of agents and similar parties be subject to appropriate review in accordance with internal guidelines. We also provide necessary support and undertake internal training and other activities to facilitate the creation and operation of bribery prevention systems in Mitsubishi Materials Group companies.
In addition, the CEO and CGO periodically release messages to employees about the importance of adhering to compliance requirements, and we also provide Group companies the support and internal training, etc. needed for operation of anti-corruption systems.
The SCQ Promotion Office headed by the CEO, actively pursues initiatives related to compliance, including bribery and other corrupt behavior. Subcommittees for specific areas have been set up under the SCQ Promotion Office, which reviews annual policies and action plans, follows up on specific measures, etc. related to each field, and reports on the status of those activities to the Strategic Management Committee and Board of Directors monthly. Additionally risk management activities are conducted on a Company-wide basis to not only deal with bribery but to manage all manner of assumed risks. However, through regular monitoring we have determined that risks related to bribery are low.
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 (including temporary, contract, part-time, casual and dispatched employees, and those who resigned within the last year), mainly those in Japan. The cases in question involve ethical issues within the corporate framework, encompassing concerns related to human rights, including harassment, violations of laws and regulations, breaches of internal policies, and corrupt practices such as embezzlement, conflicts of interest, and bribery. 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. This reflects efforts 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 consultation with 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 intranet 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), and receives anonymous reports regarding conduct related to antitrust violations, bribery, accounting fraud, improper trade practices and other fraudulent conduct. The availability of the global in-house reporting system is made known to target overseas companies and sites and also explained at overseas training. In fiscal 2023, there were two reports/inquiries received through the global in-house reporting system.
The “Mitsubishi Materials Group Employee Hotline” ensures that reports can be submitted either anonymously or with identifying information. The content of the reports is processed in accordance with the "Mitsubishi Materials Group Whistleblowing Regulations" based on the Whistleblower Protection Act and the "Whistleblowing Regulations" of various Group companies. This framework guarantees the protection of reporters, maintains their privacy, and ensures that no disadvantages arise in terms of personnel matters. In addition, in fiscal 2023 a dedicated intranet site was established as a measure to improve the reliability of the domestic in-house reporting system, and awareness-raising activities were conducted to make employees aware of the site. These included displaying posters, publishing informational videos, and incorporating the information into training. We will continue our efforts to improve the reliability of the in-house reporting system.
We have also set up an inquiry form regarding compliance, human rights and other issues on the company website. This mechanism enables outside stakeholders to contact the Company and also ensures the anonymity of the communications.
| 2016 | 2017 | 2018 | 2019 | 2020 | 2021 | 2022 | 2023 |
|---|---|---|---|---|---|---|---|
| 33 | 38 | 42 | 61 | 58 | 54 | 47 | 65 |
When a compliance violation (including when guidance has been received from a supervisory authority regarding a violation, and cases where a compliance violation reported via the in-house reporting system has been determined to be factual, etc.) has occurred within the Group, the matter is reported to top management and related departments through the department responsible for compliance, in line with the Mitsubishi Materials Group Compliance Violation Reporting Guidelines . Information concerning compliance violations related to legal matters, health and safety, quality, information security, labor standards or environmental laws and regulations is quickly and accurately consolidated and shared, thereby encouraging appropriate responses from subordinate departments. This approach also helps to prevent recurrences by reflecting trends and issues related to misconduct in risk management activities, education and training.
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. Furthermore, in fiscal 2023, we worked on establishing a compliance framework for overseas competition laws.
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 risks related to intellectual property, respond to related disputes, and improve the level of the Group's intellectual property 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 established the Intellectual Property Policy of Mitsubishi Materials Group, which indicates the direction of our intellectual property activities as a Group, based on the idea that we should maximize the value of intellectual property and intangible assets in a Group-wide manner. Additionally in February 2023, in accordance with this Intellectual Property Policy, we formulated the Group Intellectual Property Regulations, which stipulate the intellectual property-related activities of Group companies in more concrete terms.
Through our intellectual property activities, we contribute to "For people, society and the earth, circulating resources for a sustainable future."
(Established on May 1, 2022)
(Partially revised on April 1, 2023)
These regulations stipulate the activities of Group companies in a detailed manner regarding reporting to the executives and board of directors of each company, their guidance and supervision, the formation, analysis and utilization of strategic intellectual property, licensing between Group companies, commissioned and joint research, brand development, Mitsubishi trademarks, measures to deal with counterfeits, infringement clearance measures, rewards for inventions, and human resource development.
(Established on February 1, 2023)
We promote Strategic Dialogue between business divisions and intellectual property divisions aiming for strategic creation of intellectual property.
We will analyze the market and customer trends surrounding the Company from the perspective of intellectual property using various tools such as the IP Landscape, and use those findings as the basis to shape an intellectual property portfolio that help build our business strategies and the R&D strategies that support them.
We will strategically develop an IP mix (patents, designs, trademarks and brands, trade secrets and agreements on data, etc.) in line with our business and development strategies.
Through such intellectual property activities, we're trying to maximize the value of our intangible properties.
| Number of patent applications | Japan | 193 |
|---|---|---|
| Overseas | 79 | |
| Number of registered patents | Japan | 2,858 |
| Overseas | 2,758 | |
| Number of registered designs | Japan | 102 |
| Overseas | 28 | |
| Number of registered trademarks | Japan | 339 |
| Overseas | 147 |
We have established Employee Invention Regulations and offer fixed monetary amounts as incentives for when patent, utility model and design applications are filed and registered. Additionally, when a degree of profits is earned as a result of those patent, utility model or design registrations, their inventors are also rewarded based on this performance.
In fiscal 2024, the Employee Invention Regulations will be revised in an effort to enhance rewards in a Group-wide manner, fair evaluation and incentives for the Mitsubishi Materials Group.
We have built and operate a database on technology contracts such as non-disclosure agreements, and 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.
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. And the programs include position-specific training for employees from new recruits, young employees, and middle-level employees through to managerial-level employees and senior management, training geared towards obtaining intellectual property qualifications, and training given at business locations.
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 over ten thousand 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.
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. While adhering to the Group Intellectual Property Regulations, we will strive to maintain and improve the level of intellectual property governance Group-wide, helping to mitigate intellectual property risks and maximize the value of the Group's businesses.