Compliance / Risk management
Compliance
As described in the Mitsubishi Steel Group Code of Conduct, the Group carries out business activities in compliance with laws, regulations, and societal norms.
Enhancement of the compliance structure
Based on the Basic Regulations on Compliance, which applies to all Group companies, the Group strives to enhance its compliance structure by appointing individuals responsible for compliance at individual facilities and subsidiaries and cooperating with a Chief Compliance Officer (director in charge of Risk Management Office). As the section in charge of overseeing compliance, the Risk Management Office exchanges information regularly with the individuals responsible for compliance and also drafts and implements compliance measures.
Compliance initiatives
Response to serious compliance risks
We are currently studying and implementing the following measures to address serious compliance risks, including risks posed by corruption, cartels, and quality misrepresentation. These measures are intended to prevent compliance violations in Japan and overseas.
- Establishing and implementing regulations on compliance with the Antimonopoly Act
- Establishing and implementing guidelines and response flowcharts to prevent corruption
- Establishing and implementing quality audit regulations and quality audit manuals (internal audits by quality sections)
- Strengthening and enhancing operations by revising rules and regulations, including rules for establishing leak response flows in response to the amendment of the Act on Protection of Personal Information
Compliance training
The Group is currently enhancing its compliance training programs. Training efforts include reviews of practical case studies, preparation of content and teaching materials tailored to specific employee levels from executives to ordinary employees, discussions, and other activities. Examples of training programs implemented to date are given below.
- Executive compliance training (led by an outside instructor)
- Training on harassment
- Training for individuals responsible for compliance and for Sales Division general managers on prevention of cartels
- Level-specific training on the Detailed Rules for Mitsubishi Steel Manufacturing Group Corporate Code of Conduct (for facilities in Japan, including subsidiaries)
- Training on prevention of quality misrepresentation (for quality control sections at manufacturing facilities in Japan)
Since September 2023 the Risk Management Office has undertaken individual compliance interviews with all employees of all facilities in Japan. These are intended to strengthen compliance by deepening employee understanding of compliance through individual communication and striving swiftly to identify any issues that could lead to compliance violations.
We plan to sustain efforts to raise awareness of compliance issues and to ensure thorough understanding of compliance issues among all Group employees.
Review of the state of operation of the compliance Structure
To enhance oversight of the compliance structure, matters related to the state of its operation are reviewed and submitted annually to the Board of Directors.
Results of the review conducted in FY2021 verified that the Company's compliance structure is operated appropriately.
Internal whistleblowing system
Internal whistleblowing systems are in operation not just at all Group companies in Japan but at subsidiaries in Thailand, China, the Philippines, and India. Since We’ve collected employee opinions to help permeate the system throughout the organization and have implemented the following since June 2024 to make the system easier to use:
● Renamed Hottoline
● Email address is newly added to the hotline’s telephone and fax numbers as an external contact point
We have also incorporated in compliance training explanations of topics such as this system’s response structure and the whistleblower protection system, to encourage use of the system.
| FY2019 | FY2020 | FY2021 | FY2022 | FY2023 |
|---|---|---|---|---|
| 4 | 4 | 3 | 5 | 13 |
- ※Incudes domestic and overseas subsidiaries
Cutting off relations with antisocial forces
As stated in the "Mitsubishi Steel Group's Business Conduct Guidelines," our Group is firmly opposed to antisocial forces and has established that we will have no relations with them. Based on this, we have concluded a memorandum with our business partners regarding the exclusion of antisocial forces. In addition, as part of our employee education, we strive to comply with the "Mitsubishi Steel Group's Business Conduct Guidelines," including instructing employees to cut off relations with antisocial forces and to deal firmly with threats and unreasonable demands without yielding.
Risk management
The Group carries out appropriate ascertaining and management of risks to minimize losses and maximize gains as we fulfill our social responsibilities through sustained growth.
Development of the risk management structure
The Group established the Investment and Credit Committee, led by the Corporate Planning Division, to contribute to management decisions through close examination of business plans and risks from a neutral perspective on issues potentially entailing risks of business losses.
We have also established a Risk Management Committee, led by the Chief Risk Officer (CRO), whose members consist of individuals responsible from the Control & Administration Unit. The purpose of the committee is to manage risks effectively in governance, compliance, and other aspects at domestic and overseas facilities. The committee seeks to identify major risks and draft countermeasures to address these risks.
Information security measures
Information security risks continue to proliferate around the world. To ensure preparedness for such risks, based on the our Corporate Philosophy and the Mitsubishi Steel Group Code of Conduct, the Group has established a Basic Policy for Information Security, as well as associated regulations and associated information security management structures.
These measures focus on establishing an Information Security Committee whose members consist of the individuals responsible from the Company’s sections and the Group companies. The committee is charged with promoting measures to prevent information leaks and unauthorized alterations or destruction of data and with overseeing information security across the entire Group to enable prompt response to major incidents.
We also provide continual training and education on information security for Group employees and perform internal audits to evaluate related aspects such as the state of retention and control of confidential or sensitive information, thereby raising awareness of the significance of information security throughout the organization. Recognizing that high awareness of information security and aggressive security actions by individual employees are key to enhancing the defensive capabilities of the entire organization, officers take the lead in maintaining a high level of awareness of security in everyday business activities by all employees.
In particular, given expanding cyber-attacks in recent years, we’ve enhanced training and education for all employees on targeted email attacks, organizing periodic Computer Security Incident Response Team (CSIRT) drills for potential incidents, and have also taken out cyber risk insurance to ensure preparedness for any eventuality. These are part of efforts to strengthen and enhance information security.
Countermeasures against quality misrepresentation
The Group has established quality assurance structures at each production facility and strives to enhance these structures to deliver quality that keeps customers satisfied. As part of these efforts, since FY2020 quality control sections have continued to perform internal audits that aim to prevent unauthorized alteration of quality data and quality misrepresentations under the leadership of the Risk Management Office.
These internal audits check for the three main contributing factors to improprieties: motive, opportunity, and justification. The audits strive to prevent unauthorized alteration of quality data and quality misrepresentations before they occur.
With the goal of heightening awareness of the importance of quality controls, we provide periodic compliance training for our employees in quality control sections. In addition, we are currently making progress on automating inspection systems and developing related automation technologies.
Business continuity planning measures
To enable the rapid collection of information and coordinated guidance in response to severe threats to business operations such as disasters, accidents, and infectious diseases, the Group has established guidelines for establishing emergency task forces and maintains a business continuity plan (BCP) to enable each section, business site, and subsidiary to respond and achieve recovery without delay
We prepared BCPs on responding to major earthquakes in FY2020 and on responding to infectious diseases and storms and flooding at business sites expected to be at risk of typhoons in FY2021. Since last year, we’ve shifted our focus to BCP verification and revision in various ways, including periodic education to promote awareness of the BCP and desktop drills based on the BCPs formulated.
We plan to continue carrying out drills to strengthen our capacity to respond to risks and improve the BCP, thereby enhancing business continuity capabilities.
Overseas crisis management measures
We have taken measures to ensure that expatriate staff, accompanying families, and business travelers living in environments completely different from the safe and sanitary conditions in Japan can live overseas with peace of mind in case of emergencies.
In collaboration with a specialist company for overseas crisis management, we have a system in place to provide advice and assistance in Japanese 24/7, 365 days a year, in terms of medical care and security (crime, disasters, etc.), no matter where in the world they are.
In addition, whenever there is cautionary information due to climate or protest activities, we share information between the headquarters and overseas bases, and value international communication on a daily basis.
Fire prevention measures
As part of its safety measures, each manufacturing facility in the Group strives to enhance fire prevention measures. Together with regular follow-up on the Groupwide fire risk checks launched two years ago, we are taking action to prevent fires by deploying Groupwide measures based on the lessons of past fires.
We are also promoting fire prevention awareness through continual monitoring, improvements, and periodic patrols to highlight fire risks.
Lifesaving initiatives
Among its disaster prevention measures, the Company provides regular lifesaving courses for employees at the Head Office. Lifesaving has been a particular focus especially in the past few years, for example by adopting a basic goal of having all employees at the Head Office earn lifesaving qualifications and encouraging those already qualified to participate in repeat training once every three years to keep their qualifications valid. These courses continued even during the COVID-19 pandemic, with appropriate safety measures. As a result, a total of more than 180 persons (including those taking repeat training) completed the course during the six years since 2017, and the Tokyo Fire Department presented us with a letter of thanks reflecting its high regard for our contributions to lifesaving activities in the community.
We will continue these regular courses to improve employees' knowledge and skills regarding lifesaving.
Privacy Policy
The Mitsubishi Steel Personal Information Protection Policy is available on our website.
https://www.mitsubishisteel.co.jp/english/privacy/index.html