MITSUISOKO_HOLDINGS

Governance

Compliance

Basic Approach & Policy

The MITSUI-SOKO Group has established a corporate governance system that allows for separation of business execution and supervision, strengthening of mutual checks and balances, and verifications by outside experts including outside directors and auditors to promote highly transparent and compliance-oriented management, to pursue economy and efficiency, and to fulfill our corporate social responsibility through fair and lawful business operations.

Corporate Ethics Framework

Not only does the Mitsui-Soko Group strictly comply with all laws, corporate codes of conduct, and social norms, but each personnel member takes responsibility and pride in their work to operate our business in a highly ethical manner. To that end, we have established a corporate ethics framework and continue enhancing it and training our personnel in its understanding and application.
Corporate Ethics Framework
  • 1. The upper echelons of management recognize that ensuring corporate ethics is their ultimate mission and duty, and they take the initiative to set an example to promote ethics throughout the organization and group of companies, as well as assess company-internal and -external feedback at all times and establish an effective company infrastructure.
  • 2. In the event that an adverse event should occur, the upper management personally endeavor to resolve the issue and make public, both internally and externally, issues being taken, identifying the cause of the problem and preventing its recurrence. We also fulfill our duties to explain the business we engage in and provide information to the public in an accurate and timely manner. We establish specific roles and responsibilities and personally take the initiative to handle the problem accordingly.
  • 3. All personnel of the Mitsui-Soko Group strictly comply with applicable laws and refrain from illegal or excess entertainment of, gift-giving, or donations to customers, clients, and public institutions.
  • 4. All personnel of Mitsui-Soko Group strictly oppose anti-social forces or groups that would threaten or disturb the safety and order of society, and refuse to engage or interact with such entities.
  • 5. All personnel of the Mitsui-Soko Group do not engage in any form of discrimination, and we conduct our business activities with respect for the local culture of the region.
  • 6. All personnel of Mitsui-Soko Group recognize that the leak of confidential information, including that pertaining to customers, represents a major act of malfeasance that could breach the trust of our company in society at large. Therefore, we exercise the utmost care when handling information, including that on social networking services.
  • 7. Seeking to foster ongoing understanding of ethics among its personnel, the Mitsui-Soko Group actively implements training programs on corporate ethics and, given the increasingly complexity of work, acts to prevent potential malfeasance or incidents before they occur.
  • 8. All personnel of the Mitsui-Soko Group remain keenly aware that environmental initiatives are a goal shared by all of humanity, and essential to the longevity and activity of a company. To that end, we actively pursue a range of programs for the environment.

Compliance Promotion Framework

We have established the Compliance Committee for the purpose of strengthening each compliance system, including legal compliance to practice highly transparent management, and hold its meeting quarterly. The Compliance Committee discusses how to respond to compliance violations and other problems that affect management, has established the Corporate Code of Ethics, and builds the compliance system to promote compliance and prevent violations. In addition, the Compliance and Risk Management Liaison Meeting, attended by the compliance and risk management officers of operating companies, is held monthly to maintain and improve the Group's compliance system through thorough implementation of Group policies and management of issues.

Compliance Promotion Framework Chart

※Agenda: Compliance with laws and regulations, anti-corruption (anti-bribery), harassment, insider trading, etc.

Internal reporting system (Group Compliance Hotline)

The MITSUI-SOKO Group has established the Rules for the Handling of Internal Reporting and set up the Group Compliance Hotline for Group employees and other relevant people to prevent or quickly detect major violations, such as legal noncompliance, malpractice, or harassment. The domestic contact point is outsourced to a third-party organization to further strengthen the anonymity of whistleblowers, and is also available in English and Chinese to prevent potential risks such as misconduct by improving and expanding the reporting system.
Internal Reporting (Group Compliance Hotline) Framework Chart

Awareness Survey and Training on Compliance

The MITSUI-SOKO Group conducts compliance awareness surveys for the entire Group and training programs for Group employees to raise awareness and promote compliance. We strive to improve our legal compliance system by continuously and multilaterally surveying the actual status of compliance, verifying the results of our activities, and establishing a system to prevent compliance violation risks for the following year, as well as to raise compliance awareness of the entire Group.
Compliance Awareness Survey
Each year, we conduct a compliance awareness survey of all companies in the Group and share the survey results with Group employees. Based on the results of the analysis, the Compliance Committee reviews the response policy and training programs for the following year.
Compliance Training
We conduct compliance training annually for all domestic Group companies, providing opportunities to deepen learning about compliance regularly. In addition to case studies with various examples on each topic, interactive training is conducted, with participants answering compliance questions in real time, and the results shared and explained on the spot to promote understanding.
Other Initiatives
Specific activities to promote compliance include posting posters to inform employees of the compliance hotline and distributing compliance cards. We also regularly publish compliance-related articles in our Group communication magazine and issue an email newsletter to raise compliance awareness.

Response to Antisocial Forces

In order to prevent any relationship with antisocial forces, the Group has established the Antisocial Forces Response Guidelines and Antisocial Forces Response Manual and has also set up the Q&A section on our intranet site to deal with antisocial forces. We make efforts not to have any relationship, direct or indirect, with any forces that threaten the order and safety of civil activities or are suspected of involvement in criminal activities, such as fraud, extortion, money laundering, bribery, narcotics, and terrorism, and take resolute action, including legal measures, against any unjustified demands.
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