|Chief executive||Masahiko Mishima (Executive Vice President, GC)|
|Responsible institution or committee||Name||Compliance committee|
|Members||Chaired by the Executive Vice President, General Council, and composed of 24 members.|
|Number of meetings||2 (FY2017)|
|Whistle-blowing system||We have the MHI Group Whistleblowing Hotline, which is available to all employees, including those of Group companies, and the MHI Group External Whistleblowing Hotline, which is overseen by external lawyers. In addition to Group employees, any related external parties, including business partners, can utilize these hotlines to report concerns on corruption, including bribery, or other compliance-related issues. We also have systems which accept reports in the languages spoken at our major business locations, including English, Chinese, and Thai. The Compliance Committee
Secretariat promptly investigates and responds appropriately to all reports made to these hotlines. Information on
how to report is contained in the MHI Group Portal accessible by all employees and in bulletins published in-house. This
was followed by the establishment of the internal and external Harassment Contact Hotlines in January 2012 as a
measure to respond to harassment, which is becoming an increasingly serious social issue.
With the operation of the hotlines, protection of the rights afforded to informants, including confidentiality, were set out in the 2007 Company regulations entitled Compliance Promotion Regulations. These regulations state that the whistleblower's name will not be released without his/her consent, and that the whistleblower will not be placed at any disadvantage because of the information he/she has reported.
Employees have been advised of the protection of the rights given to whistleblowers with the existence of the hotline.
|Number of attendees||75,871||82,292||75,303||93,353||84,300||Group|
|Number of whistle-blowing reports||2013||2014||2015||2016||2017||coverage|
|Compliance awareness survey||Since fiscal 2004, MHI has been conducting a yearly compliance awareness survey. Since fiscal 2013, MHI had expanded this survey to all employees of the Group, in combination with its e-learning compliance training. In fiscal 2015, we checked the degree of recognition and awareness of the MHI Group Global Code of Conduct, formulated that year, which has led to greater awareness of compliance among employees and consideration of measures to ensure thorough compliance promotion. Through these surveys, we are able to check the effcacy of existing measures while keeping our compliance efforts consistent and thorough.|
|Reporting on breaches||In fiscal 2017, we received 113 reports through our whistleblowing system, including reports suggesting corruption, such as embezzlement or bribery. Among them we made corrective action on 59 cases. 26 cases out of them were identified as cases of compliance breaches, as shown in the table above (including breaches carried over from previous fiscal years).
There was no significant breach last year, with no related fines or penalties as a result.
|Anti-corruption Policy||MHI maintains a policy prohibiting conduct that leads to any form of corruption, and as a signatory company of the UN Global Compact since 2004, we have worked to disseminate and practice the ten principles contained within the four domains of the Compact, including anti-corruption. MHI strives for fairness in its global commercial transactions by strictly complying with the anti-bribery laws of all countries, including Japan's Unfair Competition Prevention Act which prohibits the giving of illicit benefits to foreign public offcials. In 2005, MHI established the Guidelines for the Prevention of Bribery Involving Foreign Civil Servants to define rules of conduct based on the Unfair Competition Prevention Act. In addition, we issued the Anti-Bribery Rules and Anti-Bribery Procedural Guidelines based on these guidelines in February 2012 in order to respond to the enactment of the British Bribery Act 2010 of July 2011 and strengthened regulations in various countries. MHI also set forth screening procedures for engaging with trading companies and distributors. Furthermore, through the MHI Group Global Code of Conduct, established in May 2015, we are thoroughly engaged in preventing bribery toward all Group directors and employees. In September 2016, we also issued the Guidance for the Prevention of Bribery of Foreign Public Offcials, an interpretation of related legislation and internal rules, and we strive to comply with the rules and the Global Code of Conduct. A global policy, formulated in September 2017, stipulates MHI Group companies to monitor whether measures to prevent bribery are being appropriately managed and deal with if needed. Moreover, to evaluate and improve the MHI Group's organization for preventing bribery, we appointed an expert and carried out a bribery risk assessment in 2017.|
|(Reference)||MHI Group Global Code of Conduct|
|Total Donations and Contributions (fiscal 2018)||Political contributions: ¥33 million (Donate to: The People's Political Association)|
|Employee training||Since fiscal 2014, we have promoted anti-bribery education across MHI and Group companies in Japan and overseas. Since fiscal 2015, we have conducted training to make every employee in MHI Group worldwide aware of the MHI Group Global Code of Conduct, which includes prohibition of bribery. Since fiscal 2014, MHI and its Group companies worldwide have steadily conducted e-learning education to prevent bribery, mainly for manager-level employees. Approximately 17,000 employees in total have taken these courses so far. In 2017, we conducted face-to-face training on bribery prevention in eight locations nationwide, and around 800 people have taken this training so far.|
|Anti-trust policy||MHI has worked to prevent the violation of anti-trust laws through messages from top management and through the use of rules and manuals such as the Code of Conduct Pertaining to Communication/Contact with Competitors. In May 2015, we published the MHI Group Global Code of Conduct and thoroughly ensured that all executive offcers and employees throughout MHI Group are aware that anti-competitive conduct is strictly forbidden.|
|(Reference)||MHI Group Global Code of Conduct|
|Employee training||MHI entered into a plea agreement with the U.S. Department of Justice concerning the U.S. anti-trust laws in 2013, in connection with the sales of compressors and condensers for automotive air-conditioning systems. In response to this, we have continued every effort to raise compliance awareness and to prevent its recurrence. Specifically, in order to ensure thorough compliance throughout the whole MHI Group, we have reinforced compliance training by various means including educational videos, lectures by lawyers, and e-learning programs.
In addition, since fiscal 2015 we have conducted training to make every employee in the MHI Group worldwide aware of the MHI Group Global Code of Conduct, which includes compliance with competition laws. Since fiscal 2014, MHI and its Group companies worldwide have steadily conducted e-learning education to comply with anti-trust laws, mainly for manager-level employees. Approximately 15,000 employees in total have taken these e-learning courses so far. In 2017, we conducted face-to-face training on compliance with anti-trust law in eight locations nationwide, and around 800 people have taken this training so far.
|Export Control Policy||From the perspective of maintaining international peace and safety, the export and transfer of products, services,
technologies or information that could be used in the development or manufacture of weapons of mass destruction
or conventional weapons are managed under an international security trade control framework.
MHI Group also strives to conduct thorough monitoring by performing assessments and transaction screenings, including confirmation of the country or region of destination, use, and customer when exporting commodities or providing technologies overseas and acquiring the necessary export licenses and permissions prior to export. Through the MHI Group Global Code of Conduct, established in May 2015, we have conducted awareness training of export control to all MHI Group executives and employees. Furthermore, through the Global Policy on Export-Related Laws and Regulations Compliance, released in October 2017, we have set fundamental standards and rules in connection with the proper implementation of Export Controls that each Group company is expected to follow.
|(Reference)||MHI Group Global Code of Conduct|
|Employee training||We are making steady progress in providing education, including face-to-face education and e-learning, focused on
export controls throughout the whole MHI Group. We have conducted e-learning on export control for MHI and Group
companies in Japan since fiscal 2007, and a total of 35,000 people have taken these courses to date. Since fiscal
2016, we have been conducting e-learning on export control for people at overseas Group companies at the
management level, and 4,300 people have completed these classes so far.
Furthermore, since fiscal 2015 we have made steady progress in providing education for all employees of MHI and its Group companies in Japan and overseas to further familiarize themselves with the MHI Group Global Code of Conduct, including export control.