 |
|
|
|
 |
|
|
|
|
Mitsubishi Chemical Corporation (MCC) has long positioned 'Compliance' (compliance with laws and corporate ethics) as a top management priority and has endeavored to ensure and promote adherence to our compliance program.
In the wake of the public's ever-increasing exhortation for corporate social responsibility (CSR), as well as our managerial environment requiring a broader group management style, MCC started a new Compliance Program to make all the employees in the MCC Group observe 'Compliance' thoroughly on October 1, 2004.
Each of us in the MCC Group will fully recognize corporate social responsibility and comply with social rules so that we can collectively respond to society's expectations for us. |
|
 |
|
 |
| Mitsubishi Chemical Holdings Group Corporate Ethics |
|
 |
|
|
We, constituent members of the Mitsubishi Chemical Holdings (MCHC) Group, shall share the following ethical standards and act with sound ethics and good common sense, and exert our utmost to ensure sustained development as a corporate group that engenders society's trust, in every aspect of our corporate activities.
1. Awareness and Responsibility
Based on the basic understanding that the foundation of our corporate activities is society's trust and confidence in us, we shall endeavor to contribute to the realization of an affluent and enriching society through respective business activities with a keen sense of corporate social responsibility.
2. Fairness, Equitability and Integrity
We shall respect the dignity and rights of all people and shall not engage in invidious discrimination for any reason whatsoever, be it racial, gender or religious. Furthermore, we shall deal with third parties including customers, suppliers, vendors, shareholders, business partners, administrative organs and local communities who associate with the MCHC Group, in a fair, equitable and sincere manner. The same holds true for relations among inter-MCHC Group constituent members.
3. Strict Compliance
Strict compliance constitutes the foundation as a member of society. "Never engage in unlawful activities," is a natural social norm (legal and ethical standards), which must be observed at all times.
At the MCHC Group, we shall act in accordance with the following standards in order to avert possible risks that may lead to illegality:
| |
(1) |
Continue to sharpen sensitivity toward illegal conduct. |
| |
(2) |
Never engage in suspected illegal activity. |
| |
(3) |
Do not be optimistic in evaluating risk of illegality. |
| |
(4) |
In the event that an illegal act is committed, do not conceal or justify it. |
| |
(5) |
Avoiding risk of illegality takes precedence over corporate interest at all times. |
4. Prudence
With respect to inter-company or inter-group relationships, as well as relationships with our customers, vendors and business partners, we shall avoid improper associations and maintain proper relationships that conform to prevailing social standards, to prevent misunderstanding.
In particular, we shall make a clear distinction between official and private matters and shall not exploit one's position or status as a member of the MCHC Group to pursue one's own personal interests in any business activity.
5. Transparency and Openness
Recognizing the importance of accountability in corporate activities, we shall maintain transparency in our corporate activities and proactively disclose appropriate information to uphold "openness" within and without the Company. |
|
|
|
|
| Mitsubishi Chemical Holdings Group Compliance Code of Conduct |
|
|
|
|
At the MCHC Group, the meaning of the word "Compliance" goes much further than simply complying with laws and regulations. It means compliance with social rules and norms in a broad sense, including corporate ethics. We must develop a strong sense of corporate social responsibility, comply rigorously with social rules and regulations and live up to the expectations of our stakeholders, including customers, suppliers, vendors, consumers, investors such as shareholders, business partners, employees and local communities.
[Chapter 1: Awareness and Responsibility]
[Chapter 2: Fairness, Equitability and Integrity]
[Chapter 3: Strict Compliance]
[Chapter 4: Prudence]
[Chapter 5: Transparency and Openness]
[Chapter 1: Awareness and Responsibility]
1-1: Awareness of Social Responsibility
Recognizing corporate social responsibility, we will strive to win public trust by contributing to the affluence and comfort of society by offering socially beneficial goods and services based upon the expertise and technologies we have developed in various fields of endeavors, including chemistry.
1-2: Responsible Care for the Environment
We will commit ourselves to the protection of the environment and endeavor to reduce environmental burden in the course of all our business activities, including promotion of resource and energy conservation, waste reduction, reuse and recycling, as well as environmental conservation and development of its technologies.
1-3: Responsible Care for Safety
Recognizing safety assurance as a corporate social responsibility, we will place top priority on safety in the course of all our business activities, which include ensuring the safety of all our products and services, including adequate handling of chemical substances, as well as operational safety. |
|
|
|
[Chapter 2: Fairness, Equitability and Integrity]
2-1: Respect for the Dignity and Rights of Individuals
We will respect individual human rights and character. We will abstain from any conduct that undermines individual dignity, such as discrimination against others on the basis of race, ethnicity, national origin, religion, gender, disability, disease and social status; we will also avoid language and behavior that offends others, such as sexual harassment. We will also adhere to internationally recognized norms, eschew forced labor in all of its forms, and support the effective abolition of child labor.
2-2: Creating a Motivational Workplace
We will strive to create a motivational workplace that provides job satisfaction to Group members through the nurturing of respect for diverse personalities and values, the creation of a free and open-minded working environment in which individual employees can manifest their best qualities, and the fostering of mutual trust through fair and equitable personnel treatment.
2-3: Customer Relations
We will listen to the voices of our customers and take a pro-customer approach so that we will be able to respond with utmost sincerity and offer safe and high-quality products and services.
2-4: Partnership/Vendor Relations
Based on the basic understanding that all business partners and vendors are our partners in conducting business, we will endeavor to foster mutual trust through fair and equitable transactions.
2-5: Ethical Business and Government Relations
We will abstain from illicit political donations, illegal incentives and bribe-giving to politicians and public servants, and strive to maintain healthy and transparent relations with political and governmental organizations at all times.
2-6: Severing Ties with Anti-Social Influences
We will take a firm stand against anti-social influences that disrupt social order and threaten sound activities, and never involve ourselves in malfeasance or anti-social conduct. We will not provide any favors, including financial, to anti-social influences, under any circumstances whatsoever. |
|
|
|
[Chapter 3: Strict Compliance]
3-1: Compliance with Laws and Regulations
We will conduct business by adhering to high ethical standards and sound common sense, and comply with all relevant laws and regulations in and outside of Japan, socially-recognized rules and standards, agreements and promises we have entered into with our customers, vendors, business partners and local communities, as well as our corporate rules and manuals.
In particular:
| ⅰ |
We will comply with relevant administrative laws and regulations applicable to our businesses and perform procedures required by such, including obtaining official approval and licenses and notification; and reporting properly and in complete detail. |
| |
|
| ⅱ |
We will comply with the Antimonopoly Act*and other relevant laws and regulations, abstain from illegal conduct such as forming cartels, engaging in bid-rigging and abusing one's dominant bargaining position, and participate in fair and free competition in the marketplace. |
| |
|
| ⅲ |
We will comply with the Unfair Competition Prevention Law* and other relevant laws and regulations, and shall not pursue our commercial interest by improper means such as illicit acquisition of others' trade secrets, or acts that may be detrimental to others' commercial interests. |
| |
|
| ⅳ |
We will comply with the Subcontract Act* and other relevant laws and regulations and abstain from engaging in conduct that may be detrimental to subcontractors' interests, such as delays in payment. |
| |
|
| ⅴ |
We will comply with the Foreign Exchange and Foreign Trade Law* and other relevant laws and regulations, and properly handle the import/export of raw materials, products, and other items. We will also abstain from exporting products and technologies that may destabilize international peace and security. |
| |
|
| ⅵ |
In addition to laws and regulations pertaining to accounting procedures and taxes, we will abide by generally accepted accounting standards as we implement proper accounting procedures, ensure the reliability of our financial reports, and make appropriate tax payments. |
| |
|
| ⅶ |
We will comply with the Labour Standard Law* and other relevant laws and regulations, and strive to maintain pleasant working conditions including occupational safety and health. |
| |
|
| ⅷ |
We will not engage in fraudulent transactions prohibited under the Financial Instruments and Exchange Act* and other relevant laws and regulations, including the trading of stocks and corporate bonds by taking advantage of undisclosed information one has come to know in the course of one's work. |
| |
|
| ⅸ |
We will correctly record business transactions and activities, including the signing of contracts, and properly manage and maintain the records in accordance with relevant laws and regulations as well as relevant internal rules. |
| Note: |
The names of individual laws referred to in this Chapter are those then effective in Japan and, therefore, please replace them with corresponding laws and regulations of your country. |
3-2: Protection of Intellectual Property
We will endeavor to develop innovative technologies, products and services, and obtain intellectual property rights and commercialize them. In this process, we shall not infringe upon the intellectual property owned by other parties, including patents, utility models, designs, trademarks and copyrights.
3-3: Protection of Personal Data
We will strictly control personal data pertaining to employees, customers and other stakeholders that we may have access to in the performance of our duties. Unless personal consent is secured, we will not disclose or leak any personal data to third parties or other employees who have no need to acquire the information in terms of business, and, at the same time, will not use it for purposes other than the original intent.
3-4: Confidentiality
Strict control must be maintained over trade secrets and other confidential information belonging to the company or to third parties (including customer information and technical know-how) that one might obtain in the performance of one's business duties. Without the express permission of the proper authorities, such confidential information must never be disclosed or leaked to third parties or to internal staff who have no legitimate need for it, and must never be used for purposes other than the original intent. |
|
|
|
[Chapter 4: Prudence]
4-1: Prudent Conduct
In our relationships with customers, vendors and other business partners, we will not engage in misleading acts such as offering or receiving business entertainment and gifts that go beyond business norms or exceed the bounds of limits acceptable to the industry.
4-2: Appropriate Use of Corporate Assets
Corporate assets and expenses, both tangible and intangible, must be used properly to achieve corporate business objectives and must not be used for personal purposes.
4-3: Appropriate Use of Information Systems
Pursuant to relevant internal rules, corporate networks and operation software will be used only for business operations authorized by the company. Wrongful acts such as hacking into the information system, damaging, falsifying or altering data, or making unauthorized use of computer software, are not permitted.
4-4: Preventing Conflict of Interest
We shall not exploit our official positions and authority or information we may have access to in the performance of our duties to engage in acts that benefit ourselves or third parties, nor shall we involve ourselves in activities that may compete against our corporate businesses, without corporate permission.
4-5: Prohibition of Political/Religious Activities at the Workplace
We will not engage in political or religious activities at the workplace, including solicitation on behalf of political or religious groups or requests for votes, without corporate authorization.
4-6: Discontinuance of Empty Formalities
Except for those within the acceptable business norms, in-house and inter-Group gift-giving and exchange of gifts and items should be shunned in view of abolishing empty formalities. |
|
|
|
[Chapter 5: Transparency and Openness]
5-1: Co-existence with Local Communities
We will strive to deepen our understanding of the cultures and customs of the countries and communities in which we operate our businesses, respect their social norms, and harmoniously co-exist with local communities as good corporate citizens through participating in activities that contribute to society.
5-2: Appropriate Disclosure of Information
As a corporate group open to society, we will maintain the transparency of our activities and appropriately disclose relevant information to promote public understanding of our activities. Pursuant to relevant laws and regulations, we will also accurately and adequately disclose financial data and information pertaining to the state of our business activities to shareholders and investors.
5-3: Open Workplace
We will maintain an open environment at the workplace where members feel comfortable about discussing anything. If, at the workplace, one learns of acts committed that violate laws and regulations or transgress this Code of Conduct, or the possibility of such acts, one must not conceal or neglect it but report it to the Company for a solution through the management or other systems, such as the Compliance Hot Line. |
|
|
|
|
|
|
|
