Maintenance and Improvement of Governance

Reinforcing Compliance

Ensuring compliance

Toward the Ensuring Compliance

“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.

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 improved compliance awareness among individual Group employees. We will continue these initiatives with the aim of further spreading and establishing compliance awareness.
In addition, 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 and report to the Board of Directors.

Initiatives Conducted to Raise Compliance Awareness

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.
Recognizing the importance of establishing our Corporate Philosophy, Vision, Mission, Values, Code of Conduct and Our Commitment among all our employees, we have produced cards, posters and the handbooks for our Group employees (basic edition) in 20 languages. By distributing the cards and posters to sites around the world and making the handbooks for our Group employees (basic edition) available on the Company intranet, we ensure that these concepts are shared among Group employees around the world. Our Code of Conduct also clearly states the need to comply with antitrust laws. Furthermore, for domestic use, we distribute an employee handbook - Case Study Edition - (for domestic use) on the company's intranet, covering examples such as the prohibition of forced labor, prevention of power harassment, sexual harassment, labor safety and health management, quality control, corruption prevention including embezzlement and bribery, compliance with laws such as the Antimonopoly Act, Subcontract Act, Foreign Exchange and Foreign Trade Act, etc. This handbook is utilized for educational activities by various domestic Group companies.
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.

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. 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 in Education and Training Program During Fiscal 2023 (including MMC and its 38 Group companies)

  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
  • Subjects of the above data for education and training program hours include non-regular employees as well as regular employees.

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 Mitsubishi Materials 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, 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.

Response flow of the Mitsubishi Materials Group Employee Hotline

Response flow of the Mitsubishi Materials Group Employee Hotline

Numbers of Reports and Inquiries Received through the Mitsubishi Materials Group Employee Hotline (FY)

2016 2017 2018 2019 2020 2021 2022 2023
33 38 42 61 58 54 47 65

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. Furthermore, in fiscal 2023, we worked on establishing a compliance framework for overseas competition laws.

  • 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 risks related to intellectual property, 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 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.

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The Intellectual Property Policy of Mitsubishi Materials Group

Through our intellectual property activities, we contribute to "For people, society and the earth, circulating resources for a sustainable future."

  1. We implement strategic intellectual property right formation in line with business and development strategies, ensure appropriate protection both in Japan and overseas, and apply effective utilization for the purposes of our business activities.
  2. We respect the intellectual property rights of third parties and establish systems to prevent infringement.
  3. We encourage new inventions and innovations, and establish appropriate incentive systems for inventors.
  4. We work to earn the trust and confidence of stakeholders by fostering and protecting our brands.
  5. We strengthen controls on counterfeit products distributed globally and ensure the implementation of countermeasures.
  6. We cultivate human resources that make strategic use of intellectual property information, and provide appropriate education systems and environments to achieve this.

(Established on May 1, 2022)
(Partially revised on April 1, 2023)

Group Intellectual Property Regulations

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)

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 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.

IP as Intellectual Capital

IP Mix

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.

Patent Data (as of March 31, 2023)

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
  • The number of patent applications is the number filed from April 2022 to March 2023.
  • The number of patent applications overseas indicates the number of patent families (PCT is included).

Incentive System

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.

Handling of Technology Contract Risks

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.

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. 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.

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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 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.

Activities across the Mitsubishi Materials Group

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.

MMC