Our broad view of compliance encompasses such elements as corporate ethics and social norms in addition to legal compliance, reflecting our sincere determination to live up to our stakeholders’ expectations.
We are continually implementing new measures to enhance our Group-wide compliance framework, including domestic and overseas training, aimed at realizing improved compliance awareness among individual Group employees. We will continue these initiatives with the aim of further spreading and establishing compliance awareness.
In addition, quickly and accurately consolidating and sharing information on compliance violations that have happened within the Group (not only legal and regulatory violations but violations of corporate ethics, codes of conduct and internal regulations, including the possibility of such violations) leads to an appropriate response to violations and helps prevent recurrences by having the information reflected in risk management activities, education, training and other action.
Under the supervision of Executive Managing Director Nogawa, who oversees compliance, we strive to ensure adherence to the Code of Conduct and other relevant policies. Additionally, the status of compliance including adherence to the Code of Conduct and other matters, is regularly reported to the Board of Directors.

Since 2006, the Mitsubishi Materials Group has designated October as Corporate Ethics Month. Each October, the CEO posts a message on the Company intranet, and business sites and Group companies plan and conduct unique activities.
Recognizing the importance of establishing our Corporate Philosophy, Vision, Mission, Values, Code of Conduct and Our Commitment among all our employees, we have produced cards and handbooks (Basic Edition) for our Group employees in 19 languages. The cards are distributed to sites around the world, posted to the Company intranet. And the handbooks (Basic Edition) are posted to the Company intranet and used in education and training activities. Furthermore, for domestic use we have produced an employee handbook (Case Study Edition). This edition is posted to the Company intranet in Japan and used by domestic Group companies for educational activities. It is designed to deepen understanding of the Code of Conduct by explaining familiar cases that could possibly occur, and covers examples such as the prohibition of forced labor, prevention of power harassment, sexual harassment, occupational health and safety, health management, quality control, anti-corruption and legal compliance issues such as the Antimonopoly Act, Subcontract Act and Foreign Exchange and Foreign Trade Act. Particularly with regard to harassment, “Prohibition of Harassment” is included in “8. Commitment to Human Rights Issues” of the Human Rights Policy which applies to the entire Group, and the Company has formulated Harassment Prevention Guidelines. In addition, we have taken up harassment prevention as one of the themes of awareness-raising efforts through training videos targeting all employees and online training for the managers’ responsibility for promoting compliance activities at their respective workplaces. Regarding customer harassment, we established the Basic Customer Harassment Policy in June 2025 to prevent customer harassment of Group employees and to prevent Group employees from engaging in customer harassment themselves, and we internally published a manual on the handling of customer harassment issues. We also provide training for the staff tasked with work related to in-house reporting, including cases of harassment. 
We are working to spread awareness of the SCQDE through training, education, posters and cards, etc.
Across the Group we are striving to build an organization and corporate culture with good and healthy communication where employees have unrestricted communication, and we see these efforts as further enhancing Group governance and preventing compliance violations. To this end, we are working to strengthen communication through dialogue-focused town hall meetings, training and other measures.
Additionally, through small group compliance activities, we are working to foster compliance awareness and improve workplace communication by having each employee share a healthy sense of urgency, view issues as those that affect them, and exchange opinions.

We provide compliance education and training for Mitsubishi Materials Group employees in Japan and overseas by utilizing external instructors, e-learning, etc.
We have constructed a framework that enables every employee in every domestic Group company to participate in compliance training once a year. From the fiscal year ended March 2021, we have been promoting online participation in this training. In addition to general compliance themes, the curriculum includes topics on the Antimonopoly Act, harassment, and the prevention of bribery and other forms of corruption. In the fiscal year ended March 2025, sessions were conducted on the themes of “Thinking about the Significance of Compliance-related Initiatives by Exercising Your Imagination” and “Group Discussion for Open Communication,” with other sessions touching on the topics of examples of non-compliance, harassment and the Antimonopoly Act. We also regularly conduct training by job grade, etc.
For overseas education and training on compliance, we consider training content while taking into account the circumstances in each region of the world. In addition to the distribution of training videos in multiple languages (seven languages), we efficiently conduct training in a wide range of regions through interactive training that places an emphasis on communication.
Since the fiscal year ended March 2019, our senior management and external lawyers have been providing governance training for directors of the Group companies in Japan. The training is aimed at helping them to understand the duties and roles that managers must fulfill with respect to governance and compliance, and to foster an awareness and acquire the means to fulfill them. In the fiscal year ended March 2022 we also began offering this training overseas. In addition to senior management, the training is provided by outside experts who are familiar with circumstances overseas.
Furthermore, since the fiscal year ended March 2019, we have conducted annual surveys on the compliance awareness of all employees. We analyze the results of these surveys to help measure the effectiveness of various initiatives and promote them.

The Group’s Code of Conduct does not tolerate corrupt behavior in any form. It prohibits all forms of corruption including giving and receiving gifts and entertainment, stipulates that the content, frequency and monetary amounts involved with any such activities be consistent with social norms, requires that political activities and political contributions always be carried out through fair and honest means, and stipulates that we must endeavor to maintain healthy and normal relationships with politics and government.
In April 2022, the Mitsubishi Materials Group Entertainment Expense Management Regulations were established for the Company and domestic Group companies. The regulations require that business entertainment, gifts and the like always be limited in their nature, frequency and monetary value in light of social norms.
In addition, given the importance of preventing corruption, a global sustainable development challenge, in April 2018 we formulated our “Regulations for Combating Bribery of Public Officials, etc.” in order to help prevent bribery in our global business activities. The regulations prohibit the bribery of foreign public officials and others directly or through agents (third parties brokering transactions). In accordance with internal guidelines, when engaging the services of agents and similar parties, it is necessary to explain our anticorruption system and conduct appropriate screening, including advance checks regarding an agent’s reputation, the reasonableness of their compensation, their relationship with government entities, and so on. Under the guidelines we are also required to comply with relevant anticorruption laws and regulations in related countries and regions when engaging the services of agents, and must also enter into contracts stipulating immediate contractual termination in the event of a breach (or possible breach) of anticorruption-related laws or regulations. We also provide necessary support and undertake internal training and other activities to facilitate the creation and operation of bribery prevention systems in Mitsubishi Materials Group companies.
In addition, the CEO periodically releases messages to employees about the importance of adhering to compliance requirements, and we also provide Group companies the support and internal training, etc. needed for operation of anti-corruption systems.
The SCQ Promotion Office headed by the CEO, actively pursues initiatives related to compliance, including bribery and other corrupt behavior. Subcommittees for specific areas have been set up under the SCQ Promotion Office, which reviews annual policies and action plans, follows up on specific measures, etc. related to each field, and reports on the status of those activities to the Strategic Management Committee and Board of Directors monthly. Additionally risk management activities are conducted on a Company-wide basis to not only deal with bribery but to manage all manner of assumed risks. However, through regular monitoring we have determined that risks related to bribery are low. 

We established an Internal Contact Office in December 2002 in Japan as a consultation service to handle reports and inquiries from employees of Mitsubishi Materials Corporation and its Group companies (including temporary, contract, part-time, casual and dispatched employees, and those who resigned within the last year), mainly those in Japan. The cases in question involve ethical issues within the corporate framework, encompassing concerns related to human rights, including harassment, violations of laws and regulations, breaches of internal policies, and corrupt practices such as embezzlement, conflicts of interest, and bribery. Since January 2020, we have contracted an external vendor to run the “Mitsubishi Materials Group Employee Hotline” for reports and inquiries, as well as improving the response systems of Group companies. This reflects efforts to ensure that we can appropriately respond to reports and inquiries and better respond to issues, while also strengthening the reliability of report and inquiry systems. We also established a contact office for consultation with Members of the Audit Committee in June 2018 to contribute to the work performed by members of the Audit Committee in promptly detecting incidents and initiating corrective measures.
Contact information for these reporting systems is printed on cards for employees of the Mitsubishi Materials Group to keep on their person and is made available on our Group intranet and through each training activity.
On April 1, 2021, we established and began operation of the “MMC Group Global Hotline,” a global in-house reporting system for the Mitsubishi Materials Group. This in-house reporting system can be used by personnel in overseas Group companies and overseas sites (with some exceptions), and receives anonymous reports regarding conduct related to antitrust violations, bribery, accounting fraud, improper trade practices and other fraudulent conduct. The availability of the global in-house reporting system is made known to target overseas companies and sites and also explained at overseas training. In the fiscal year ended March 2024, there were six reports/inquiries received through the global in-house reporting system.
The “Mitsubishi Materials Group Employee Hotline” ensures that reports can be submitted either anonymously or with identifying information. The content of the reports is processed in accordance with the "Mitsubishi Materials Group Whistleblowing Regulations" based on the Whistleblower Protection Act and the "Whistleblowing Regulations" of various Group companies. This framework guarantees the protection of whistleblowers, maintains their privacy, and ensures that no disadvantages arise in terms of personnel matters.
In addition, in the fiscal year ended March 2025, information about the hotline was disseminated via the intranet and training-based awareness-raising activities were also conducted as part of measures to improve the reliability of the domestic in-house reporting system. In addition, in response to Japan’s Freelance Act which came into effect in November 2024, we added freelancers to the scope of the people who are able to use the Mitsubishi Materials Group Employee Hotline. We will continue our efforts to improve the reliability of the in-house reporting system.
We have also set up an inquiry form regarding compliance, human rights and other issues on the company website. This mechanism enables outside stakeholders to contact the Company and also ensures the anonymity of the communications.

In September 2019, the Japan Fair Trade Commission (JFTC) issued a cease and desist order and a surcharge payment order to Universal Can Corporation, a Group company of that time, for violations of the Antimonopoly Act in the form of cartel activity. In response to this, from November 2019 onwards, the Group has engaged in various measures to rebuild its Antimonopoly Act compliance system.

• Formulation of Antimonopoly Act compliance regulations for MMC and Japanese subsidiaries
• Ongoing communiqués from top management regarding compliance with the Antimonopoly Act
• Clarification of Antimonopoly Act compliance as part of the Group’s Code of Conduct
• Review and revision of regulations regarding disciplinary actions for MMC and Japanese subsidiaries
• Implementation of self-audits by MMC and Japanese subsidiaries, assessment of potential for Antimonopoly Act violations within each business segment
• Design and implementation of measures at individual business sites in the form of risk management activities
• Ongoing implementation and expansion of Antimonopoly Act compliance training
• Review and revision of internal audits related to the Antimonopoly Act
• Strengthening of measures against bid-rigging and transactions with competitors