Mitsubishi Electric first clarified and formulated its code of corporate ethics in April 1990. The code has since undergone a series of revisions to reflect amendments to legislation and changes in the social environment. In 2001, we released the Corporate Ethics and Compliance Statement, which identifies six basic policies: compliance with the law, respect for human rights, contributing to society, collaboration and harmonization with the community, consideration of environmental issues and recognition of personal integrity.

To raise awareness of this statement throughout the Mitsubishi Electric Group, we display posters and have each employee in Japan carry a card with the statement written on it. In addition, every employee is issued a Corporate Ethics and Compliance Code of Conduct booklet, which contains the Corporate Ethics and Compliance Statement and specific action policies. The booklet has been revised four times to reflect revisions to laws and changes in society, most recently in March 2007.

Corporate Ethics and Compliance Statement Poster

Portable Card

Corporate Ethics and Compliance Code of Conduct Booklet

Compliance with the Law

We will conduct ourselves always in compliance with applicable laws and with a high degree of sensitivity to changes in social ethics or local practices. We will never establish a target, nor make a commitment, that could be achieved with conduct that would violate applicable laws or generally accepted community standards.

Respect for Human Rights

We will conduct ourselves always with a respect for human rights. We will not tolerate discrimination based on nationality, race, religion, gender, disability or any other reason prohibited by applicable laws nor will we tolerate other conduct that violates international laws, covenants or principles regarding respect for individual and human rights.

Contributing to Society

Concurrently with the pursuit of a reasonable profit, we will conduct ourselves always with an awareness of our corporate social responsibility in order to further the progress of the entire society.

Collaboration and Harmonization with the Community

As a good corporate citizen and neighbor, we will support worthwhile civic and charitable organizations and activities in the communities where we reside or work that contribute to community development.

Consideration of Environmental Issues

As part of our goal to achieve a recycling-oriented society, we will do our best to pay attention to and respect the global environment in every aspect of our business.

Awareness of Personal Integrity

We will conduct ourselves with the highest integrity, making a proper distinction between public and private matters and, will use company resources, including monetary resources, time and information for legitimate business purposes. We will use company computers and various networks and on-line services, including e-mail and Internet access, primarily for company business.

The formulation of the Group's policies and action codes with regard to corporate ethics and compliance is the responsibility of the Corporate Compliance Committee, which was established in 1991, the year in which the Nippon Keidanren created its Corporate Conduct Charter. The committee is chaired by an executive officer responsible for legal affairs and holds regular meetings twice annually and extraordinary meetings as required. Compliance is an essential element of conducting business. Recognizing this, in April 2007, we reinforced our primary compliance promotion systems in each division and the organizations that support them.

At each of the Company's divisions and operational sites, a compliance promotion committee determines the specific compliance measures that should be taken in its operations. To support compliance promotion, group compliance managers, compliance managers and compliance leaders are assigned at all organization levels. Also, in each business division and at each operational site, compliance managers and compliance leaders form a compliance information communication committee and hold regular meetings.

In April 2008, we reorganized the compliance system for Mitsubishi Electric Group companies to more closely reflect the parent Company's compliance policies and promotion systems.

For affiliates in Japan, we appoint chief compliance managers to support executive functions related to compliance promotion, and compliance managers to assist general managers in each business unit. In addition, chief compliance managers from each affiliate are required to attend chief compliance manager committee meetings.

Overseas, regional chief compliance managers have been appointed in every region in which we operate, extending our support of compliance at affiliates. Chief compliance managers are assigned to affiliates in the United States and Europe to support executive functions related to compliance promotion, while regional chief compliance managers form a regional compliance committee and work to improve the level of compliance. Depending on the region and local circumstances, we are gradually redeveloping relevant systems.

Mitsubishi Electric has set up an ethics and legal compliance hotline to prevent improper conduct before it occurs. The information communicated through the hotline is investigated by the Legal Division's Legal Compliance Office, and if improper conduct is discovered, the investigated division is requested to punish the perpetrator, or institute corrective measures. Anonymity and other protections for the whistleblower are prescribed in internal rules along with a prohibition against unfair treatment of whistleblowers.

In April 2006, an external communication channel was set up at the offices of legal counsel in conjunction with enforcement of the Whistleblower Protection Act. These communication channels are open to affiliate companies in Japan as well.

The ethics and legal compliance hotline is explained in the Code of Conduct for Corporate Ethics and Compliance, which is distributed to each employee. As well as posters displayed in each department, the employees are acquainted with the communication channels through the Legal Division's intranet site and other information outlets.

The Auditing Division assumes a central role in auditing compliance as part of the internal audits of corporate ethics and legal compliance at the business divisions of Mitsubishi Electric and affiliated companies in Japan and overseas. Divisions are requested to make improvements if found in need of corrective actions by the Auditing Division.

Mitsubishi Electric conducts seminars on compliance with various laws that must be abided by in conducting business, to each division as necessary. Additionally, from fiscal 2006, all employees receive compliance training either through e-learning programs, group classes, or correspondence courses.

Mitsubishi Electric's Legal Division and Associated Companies Division provide support for training at affiliated companies in Japan to hold compliance seminars as necessary. Overseas, our affiliated companies run compliance training while taking into account local laws, regulations, culture and customs.

Additionally, to prevent the occurrence of misconduct, we distribute educational materials on preventing misconduct, to all managers in Mitsubishi Electric and affiliated companies in Japan, via our compliance managers.