1.Efforts to maintain Corporate Compliance of Mitsui-Soko Group


Basic Idea of Corporate Governance

At Mitsui-Soko Group, we promote transparency and regulatory compliance while pursuing economic efficiency. As part of our social responsibilities, we operate under a fair and legal manner. To do this, we have established a corporate governance structure which separates executive and supervisor positions, and reinforced checks and balances by incorporating external experts, such as non-executive directors and statutory auditors.

Situation of Development of Internal Control System

We have developed an internal control system to ensure that the duties of the executive position comply with the laws and regulations of the articles of association, and to ensure proper execution of business activities. In order for the executive position as well as employees to comply with the laws,regulations of the articles of association and social norms as a standard of conduct, we disseminate Basic Policy for Internal Control System that stipulates an framework of Compliance includingour model of corporate ethics, to all the corporate employees.

Situation of the Development of Risk Management System and Internal Audit

Under the supervision of the risk management officer, the risk management department prevents corporate risks, and has set up a compliance hotline in case a risk does occur. Mitsui-Soko Holdings strives to minimize corporate risks by having all employees be mindful of risks, maintains and updates a response manual, and through internal auditing.

2.Established a “Corporate Code of Conduct” for Maintaining Corporate Compliance

The Mitsui-Soko Group will comply with laws, internal rules and social norms, and believe that it is important for all executive and employees to operate with a sense of responsibility, pride, and have high ethical standards. For this, we have established and strengthened our corporate code of conduct, and continue to further educate our staff.


Corporate Code of Conduct

  • 1. The chief executive officer will recognize that the establishment of the corporate ethics is one his most important duties, and leading by example, he will ensure compliance to the code of conduct internally and throughout the group, as well as constantly follow the voices of those internal and external to maintain an effective internal system.
  • 2. In the event that a situation that contradicts the aforementioned statement occurs, the chief executive officer must show effort internally and externally to solve the issue, as well as investigate the cause, and must prevent such an incident from reoccurring. Also, he must quickly and explicitly publicize information and be accountable for his actions, clarify his authority and responsibilities, and including himself, take responsibility for said situation.
  • 3. All Mitsui-Soko Group executives and employees must comply to laws and regulations, and will refrain from providing excessive or illegal entertainment, gift-giving, and donations to clients, partners, and public organizations.
  • 4. All Mitsui-Soko Group executives and employees must absolutely refrain and confront any connections to anti-social organizations who pose a threat to the order and safety of civil society.
  • 5. All Mitsui-Soko Group executives and employees must not discriminate or hold any prejudice against others based on race or sexuality, and when overseas will operate with consideration to the local culture and customs.
  • 6. All Mitsui-Soko Group executives and employees will handle information appropriately, such as on social networking services, and must acknowledge that disclosing corporate confidential information such as client information is a serious act of misconduct, and will result in the loss of trust in the company.
  • 7. All companies in the Mitsui-Soko Group will prevent fraud and misconduct that may be accompanied with the specialization and advancement of business operations by conducting the staff training withthe morals and corporate code of ethics.
  • 8. All companies in the Mitsui-Soko Group will proactively make an effort to the environmental cause as it is a universal theme as well as a crucial component for the survival of the corporation and its operations.

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