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, contribution to society, collaboration and harmonization with the community, consideration of environmental issues and awareness of personal integrity.

To raise awareness of this statement throughout Mitsubishi Electric, we not only display posters but also hand out cards for each employee in Japan to carry. We have also distributed to every Mitsubishi Electric Group employee a booklet titled "Corporate Ethics and Compliance Code of Conduct", which contains the Corporate Ethics and Compliance Statement and specific action policies. The booklet has been revised four times to reflect revisions of laws and changes in society. The most recent version was issued in March 2007.

Corporate Ethics and Legal Compliance Statement Poster

Portable Card

Ethics and Compliance
Activities 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.

Chaired by an executive officer responsible for legal affairs, the Corporate Compliance Committee formulates across-the-board policies and action codes for the employees regarding corporate ethics and compliance activities in the Mitsubishi Electric Group worldwide. Established in 1991, the same year in which Nippon Keidanren created its Corporate Conduct Charter, the Corporate Compliance Committee holds regular meetings two times per year and extraordinary meetings as needed.

In April 2007, Mitsubishi Electric has further clarified the inextricable link between compliance and business promotion, reinforcing its primary compliance promotion systems in each division and the organizations that support them.

In each division and at each operational site, we have established a compliance promotion committee that determines specific measures regarding compliance in its own department. At the same time, at all organization levels in each business division and at each operational site, we have appointed group compliance managers, compliance managers, and compliance leaders. In divisions and at operational sites, compliance managers and compliance leaders regularly hold compliance coordinating meetings.

In April 2007, the title of "legal manager" was changed to "compliance manager" in order to promote compliance in a broader sense that includes corporate ethics as well as legal compliance.

In international operations, Mitsubishi Electric Group companies formulate their own corporate ethics codes based upon the Corporate Ethics and Compliance Code of Conduct, taking into account local laws, culture and customs. In addition, compliance meetings are held in an effort to thoroughly entrench compliance concepts.

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 leads audits of corporate ethics and legal compliance at the business divisions of Mitsubishi Electric and affiliated companies in Japan and overseas. Following the auditing of Mitsubishi Electric and its affiliated companies in Japan and overseas, divisions are requested to make improvements if found in need of corrective actions.

Mitsubishi Electric conducts on-demand education regarding compliance through e-learning methods, group classes, and correspondence classes. We also hold compliance seminars accordingly. Managers in each division also distribute materials containing commonplace examples, practice lessons, and other information in an effort to prevent the occurrence of improper conduct.

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

Mitsubishi Electric will re-educate our salespeople on antimonopoly law through e-learning methods as well as further educate compliance leaders.