Mitsubishi Electric Corporation

Based on public information, there is evidence that the company has published a statement from the Chief Executive Officer referencing the ethics and anti-corruption agenda of the company. However, this is assessed to be insufficiently strong, preventing the company from scoring on this question.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company, for example through public speeches or involvement in industry anti-corruption initiatives.

Based on public information, there is insufficient evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. TI notes that one statement on the company website refers to internal-facing commitment in regard to compliance generally, rather than ethics or anti-corruption in particular.

Based on public information, there is evidence that the company publishes a statement of principles representing high standards of business conduct. However, only trust is referenced within the statement, as well as a reference to personal integrity in in the Compliance Statement. To score on this question the company would need to provide evidence that other values sought by this question are listed and clearly explained in detail.

Based on public information, there is no readily available evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is evidence that the company has appointed the Corporate Compliance Committee with overall corporate responsibility for its ethics and anti-corruption agenda. However, it is unclear what this responsibility specifically involves, with no formal Terms of Reference for the Committee having been found. The company therefore scores 1.

Based on public information, there is evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. This individual is the head of the Legal Affairs and Compliance, Export Control and Intellectual Property Committee, Nobushi Morooka.

Based on public information, there is no readily available evidence that there is regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda.

Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is evidence that the company has a process to review and update policies in response to violations. However, no details of this review process are provided. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal risk assessment procedure that covers ethics and compliance. However, there is insufficient detail provided about this procedure or any associated mitigation plans. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents.

Based on public information, there is insufficient evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption in its various forms, including giving and receiving improper payments.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is evidence that the company’s Conduct Guidelines are easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company. The Conduct Guidelines are available on the website, in English, Japanese, Chinese and Thai.

Based on public information, there is evidence that the company’s Conduct Guidelines are easily understandable and clear to Board members, employees and third parties.

Based on public information, there is evidence that the company's Conduct Guidelines explicitly apply to all employees. However, there is no evidence that the Conduct Guidelines also apply to members of the Board. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy on potential conflicts of interest, which includes a definition and several examples. The company therefore scores 2.

Based on public information, there is evidence that the company has a policy for the receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy on giving gifts is made implicitly through the prohibition of making improper payments. There is no evidence that the company sets upper limits for gift exchange or value thresholds for senior management authorisation. The company therefore scores 1.

Based on public information, there is evidence that the company has a policy for the receipt of hospitality, to ensure that such transactions are bona fide and not a subterfuge for bribery. The policy on giving hospitality is made implicitly through the prohibition of making improper payments. There is no evidence that the company sets upper limits for hospitality exchange, or value thresholds for senior management authorisation. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is some evidence that the company regulates political contributions. However, there is no evidence that the company provides additional guidelines to regulate political contributions or publicly discloses all such contributions. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which it lobbies.

Based on public information, there is some evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. However, there is no evidence that the company provides additional guidelines to regulate charitable contributions or publicly discloses all such contributions. The company therefore scores 1.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s compliance policy. However, as this guidance is not publicly available it is not possible to assess whether it ensures unambiguous understanding of the policies in place, such as through illustrations or scenarios. The company therefore scores 1.

Based on public information, there is evidence that the company has a compliance training programme. However, there is no evidence of an explicit anti-corruption training module. The company therefore scores 1.

Based on public information, there is evidence that compliance training is provided in all countries where the company operates.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is some evidence that the company provides compliance training for employees in sensitive positions. However, the company does not specify which high risk positions are targeted. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is evidence that the company considers applying disciplinary procedures to individuals found to have violated the Conduct Guidelines. However, there is no evidence of an explicit commitment to apply disciplinary procedures, or that they will be applied to Board members. The company therefore scores 1.

Based on public information, there is evidence that the company has well-publicised channels for employees to report concerns or instances of suspected corrupt activity. This includes both internal and external hotlines that allow for anonymous reporting.

Based on public information, there is evidence that across geographies, all employees have access to at least one whistleblowing channel. However, the company’s external hotlines are only available to company affiliates in Japan. The company therefore scores 1. To score higher the company would need to provide evidence that across geographies, all employees have access to more than one whistleblowing channel.

Based on public information, there is no readily available evidence that the company has mechanisms to assure itself that whistleblowing by employees is not deterred, or that whistleblowers are treated supportively. TI notes the company states that internal rules set protections for whistleblowers, but evidence does not suggest that this includes mechanisms such as employee surveys or monitoring of whistleblower channel usage statistics.

Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought. The website provides a statement, where it is clear that Compliance Departments have been set up in every business division with management "guiding and supervising" staff members. However, the emphasis seems to be on ensuring compliance, rather than providing advice and guidance. The company therefore scores 1.

Based on public information, there is limited evidence that the company has a commitment to non-retaliation for bona fide reporting of corruption. However, there is no evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.