Message fromthe President & CEO

Sustainability Management

Environment

SocialGovernance

Disclosure Based on
the TCFD Recommendations

ComplianceTargetl 8.7

Basic Approach and Policies
Corporate activities are closely interlinked with various laws and public systems such as those related tothe environment, labor, and consumer protection.
Corporate activities must be carried out in compliance with these laws and systems. MITSUBISHI
MOTORS recognizes that the failure to appropriately
comply with these laws, regulations, and systems
would not only impede its business continuity, butwould also place significant burdens on society andthe environment.
In order to fulfill its social responsibilities as acompany by not only complying with laws, international rules, and internal regulations but also by
respecting changing social norms to the greatest
degree possible, we have issued a “Global Code of
Conduct” to serve as a standard of conduct for all
executives and employees. We are also redoubling
our efforts to enhance our compliance frameworkand employee training, including those at our majoraffiliates in Japan and overseas. We review the “Global
Code of Conduct” as necessary. In 2019, we made revisions to clarify our policy on respect for human rights
and anti-corruption initiatives.

Targetl 16.5

MITSUBISHI MOTORS Global Code of Conduct[Principle]
MITSUBISHI MOTORS Group Companies (collectively herein referred to as “MITSUBISHI MOTORS Group” or “Company”) have
set this Global Code of Conduct that all MITSUBISHI MOTORS Group executives and employees must follow in order tofulfill our social responsibilities as a company.
This Global Code of Conduct applies to all MITSUBISHI MOTORS Group executives and employees. Each member of theCompany is charged with responsibility to comply this Global Code of Conduct.
1. Comply with all Laws and Rules

We shall comply with all applicable laws and regulations of
the country where the Company conducts business as well
as all Company policies and rules.

2. Promote Safety

We shall maintain and promote a healthy work environment, and engage in safe work practices. We are also committed to ensuring the safety of our customers and passengers, and continually promoting the safety of products.

3. Avoid Conflict of Interest

We shall act in the best interests of the Company, and shallnot behave, act, or use any information contrary to theCompany's interests. Furthermore, we shall strive to avoid
any conduct that may be considered a conflict of interest.

4. Prohibit Association with Anti-Social Forces

We shall never have any association with anti-social forces
whatsoever. We shall not participate in acts of terrorism,
drug dealings, money laundering, and other individual ororganized criminal activities.

5. Preserve Company Assets

We shall safeguard the Company's assets, and shall never
use the said assets, including funds, confidential businessinformation, physical properties and intellectual properties
without permission.

6. Be Impartial and Fair

We shall maintain impartial and fair relationship with public
servants as well as business partners, including dealers,

MITSUBISHI MOTORS CORPORATION Sustainability Report 2024

ESG Data

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106▶ Nextsuppliers, and other third parties. We shall not participate
in or endorse any corrupt practices including bribery, directly or indirectly such as through a third party.

7. Be Transparent and Accountable

We shall maintain accounts and records relating to corporate management with integrity, and disclose Company's
business activities fairly and transparently to our stakeholders, including shareholders, customers, employees,
and local communities with timely and properly manner.

8.	Respect Human Rights and Diversity, Provide Equal
Opportunity

We shall respect the human rights and diversity of suppliers, customers, other executives, colleagues, and local
communities. We shall never tolerate discrimination, retaliation or harassment in any form or degree.

9. Be Environmentally Responsible

We shall strive to take into consideration environmental
conservation when developing products and providing
services, and promote recycling, as well as resource andenergy savings.

10. Be Active and Report Violations

We shall carry out our work in accordance with this Global
Code of Conduct. When we have come to know any violation of this Global Code of Conduct, we shall immediately
report it to the Company, and the executives and employees who have come forward with such information basedon their own beliefs shall be infallibly protected from any
form of retaliation.

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Message fromthe President & CEO

Sustainability Management

Environment

SocialGovernance

Disclosure Based on
the TCFD Recommendations

ESG Data

Targetl 8.7

Major subsidiaries and associates in Japan andoverseas also appoint compliance officers. To help
prevent compliance infractions, we have establishedand operated MITSUBISHI MOTORS Global Hotline
since FY2018.
The Board of Directors is provided with regular
reports on these compliance structures, efforts related to education and the formulation or revision of the
Global Code of Conduct, as well as the status of any
compliance infractions and their countermeasures.
In the event of a major incident, an emergency response organization is set up in accordance with the
emergency response manual, and a system is in place
to ensure that an appropriate response is taken.
As for internal controls related to financial reporting, we verify compliance structures and proce-

Management Structure
At MITSUBISHI MOTORS, to prevent compliance infractions and information security incidents, under
the direction of the Executive Officer for Internal
Control Promotion/General Administration/Corporate Affairs each division appoints a compliance officer, and department heads serve as code leaders.
Compliance officers work closely with the codeleaders to prevent compliance violations within theirdepartments. When a compliance violation occurs,
compliance officers take corrective actions, measures
to prevent recurrence and confirm its effectiveness,and implement horizontal dissemination, then reportto the Executive Officer for Internal Control.
Organizational Framework for Promoting Compliance

Board of Directors
Executive Officer, President & CEO
Executive Officer for Internal Control Promotion/General Administration/Corporate Affairs
General Manager of Internal Control Promotion Office
RequestChief Officers, Division General Managers approval
ReportConsult/
Thoroughly implement focus
reporton compliance prioritization

DirectReportSupervise
Coordination

Compliance Officers
Consult/
reportThoroughly implement focus on complianceprioritization

General Managers = Code Leaders(including General Managers of the department incharge of the primary management of the affiliates)

Complianceproblem
consultation

Thoroughly
implement
focus oncomplianceprioritization

MITSUBISHI MOTORS
employees

ComplianceDepartment
ReportConsult/
ReportInformation
Security
Management
OfficeEmployee
Consultation
OfficeReportAffiliates
Compliance Officers

Coordination

Reporting,Consultation

Coordination

Outsideattorney
consultation

Reporting,Consultation

MITSUBISHI MOTORS CORPORATION Sustainability Report 2024

MITSUBISHI MOTORS and Affiliates
employees (in Japan)
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Business
Partner
Helpline

Reporting,
Reporting Consultation

Thoroughly implement
focus on complianceprioritization

Affiliates employees

MITSUBISHI
MOTORS
GlobalHotline

MITSUBISHI
MOTORS and
Affiliates
employees(in Japan
and overseas)107▶ NextBusiness
partners(in Japan)

Targetl 16.5dures for financial summaries. If inadequate controls are found at us being evaluated, we request
reporting on the nature of the problem and improvements being made. In FY2023, we checked thestatus of 19 Group companies (MITSUBISHI MOTORS,
6 domestic subsidiaries, and 12 overseas affiliates).
In FY2023, we experienced no serious compliance infractions that might damage our credibility
with customers, investors, or other parties.

Establishment of Internal andExternal Consultation Offices
To prevent and promptly detect improper conduct,
MITSUBISHI MOTORS has established an internal
consultation office (Employee Consultation Office)allowing employees of us or its subsidiaries andassociates in Japan to report or consult about suchconduct. We have set up an external consultation
office, the “MMC Hotline,” staffed by outside
attorneys, as well as the MITSUBISHI MOTORS Global
Hotline, accessible to employees both in Japan andoverseas. We have also established a Business Partner
Helpline designated to be used by our business
partners in Japan.
In a survey we conducted in February 2023 topromote the early detection and prevention ofcompliance violations, 93.7% of the approximately
5,000 employees who participated in the survey
indicated that they were “aware of the hotlines.”
In FY2023, these offices fielded 104 reports or
consultations. Offices endeavor to swiftly resolve
issues raised in reports and consultations after firstseeking to confirm the facts through an investigationby the Employee Consultation Office or by enlisting
the assistance of relevant compliance officers. Any
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Message fromthe President & CEO

Sustainability Management

Environment

SocialGovernance

Disclosure Based on
the TCFD Recommendations

ESG Data

Targetl 8.7

reports or consultations that raise concerns aboutcompliance issues or corporate risks are immediately
reported to the Executive Officer for Internal Control
and Audit Committee Members. After receiving
instructions on how to respond, offices endeavor
to resolve the issues. When we receive a report orconsultation via a hotline, we promptly conduct aninterview or other investigation. If a violation is found,
an incident report is filed, and corrective measuresand measures to prevent recurrence are implemented.
Receive report or consultation

Person in charge of hotline conducts
interview and investigation
Problematic or
fraudulent

Not problematic or
fraudulent

Corrective measures
Formulation of measures
to prevent recurrence
Notify the person reporting orrequesting consultation

Follow up

In handling such information and in investigating
the relevant facts, we established our “ComplianceOriented Whistleblowing Operation Procedure” andmade company personnel aware of the provision inorder to ensure that persons who seek consultation
are not treated unfairly.
“The MITSUBISHI MOTORS Global Hotline”
established in FY2018 was set up within an outside
MITSUBISHI MOTORS CORPORATION Sustainability Report 2024

firm providing such services. This makes it possible tofile anonymous reports. Systems for identifying andmanaging risks of the entire group have been put inplace, too, with MITSUBISHI MOTORS headquarters
even able to check details of reports from subsidiaries
and associates.
Number of Reports/Consultations Fielded by Consultation Offices by Category (FY2023, 104 reports)
Item
Corporate/business proposals
Workplace environment
Labor relations
Human relations/harassment
Compliance, violations of operational rules,
fraud
OthersNumber
3
19
3
40
32
7

Out of total 104 reports and consultations received
in FY2023, the results of the investigation revealed 6
cases of compliance problems, including violations oflaws and regulations and harassment. We instructed
the relevant departments to promptly take corrective
actions and confirmed that they were implemented
without fail.

Education and Training
Every fiscal year we formulate compliance-related
education and training programs, and offer them to
employees stratified by each job rank. Each divisionalso draws up and conducts its own measures under
the direction of the compliance officer.
Specifically, in order to improve the complianceawareness of all employees, when new graduates or
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108▶ NextTargetl 16.5

mid-career recruits join us, they receive training regarding our history of compliance problems and thelessons to be learned from it. This training is repeated
when employees are given promotions, helping reinforce employees’ sense of compliance. Furthermore,similar training is also offered in some Japanese subsidiaries, fostering such sense for the group as a whole.
We also provide all our employees with e-learning
opportunities, including courses on the basics of compliance, as well as education on information security,
the so-called “36 Agreement” and other aspects of
employment management.
On and around Safety Pledge Days,* each individual division voluntarily holds events to reaffirm the
day’s significance. Workplace discussions are also heldat the same time to talk about business ethics issues
faced in the workplace and workplace culture.
In addition, we provide easy-to-understand compliance-related information by posting a Compliance
Newsletter on our intranet every month.
In addition to the above, as a measure to raiseawareness further, in FY2023 we hosted a lecture
on business and human rights, given by an outside
expert. Assertive communication training by outside
instructors was provided to managers at the department manager level and above to help improve workplace management. Outside instructors also provided
communication training to newly appointed managers to enhance workplace communication and support remote work.
* To prevent past incidents, such as the regrettable recall coverup,from being forgotten over time, in October 2004 we designatedJanuary 10 and October 19 as “Safety Pledge Days.” These days
were chosen because two fatal accidents involving large trucks
manufactured by Mitsubishi Fuso, a former MITSUBISHI MOTORS
division, occurred on these days.
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Message fromthe President & CEO

Sustainability Management

Environment

SocialGovernance

Disclosure Based on
the TCFD Recommendations

ESG Data

Targetl 8.7

Anti-Corruption
Policies and Approach
The “Global Code of Conduct” clearly stipulates that
MITSUBISHI MOTORS executives and employees shallcomply with laws and regulations and shall maintain
fair and equitable relationships with public servants andbusiness partners. Moreover, we have built and operatea system that is designed to prevent corruption.

Management Structure
We implement e-learning programs for all employees
to familiarize them with the Global Code of Conduct
and allows them to review the code at any time by
distributing pamphlets containing this code and posting it to a smartphone app (for managers and above).
We also communicate the code across the group,
distributing the pamphlets to subsidiaries and associates in Japan, and in electronic form to subsidiaries
and associates overseas.
We have formulated the “MITSUBISHI MOTORSGLOBAL ANTI-BRIBERY POLICY” as a global guideline
for the prevention of bribery and corrupt practices.
This policy states clearly that we tolerate absolutely
no bribery or corrupt practices. In our efforts to reinforce measures for preventing bribery and corrupt
practices throughout the Group, we require subsidiaries and associates in Japan and overseas to comply
with the same policies. We also ask our suppliers,
contractors, procurement partners, dealers and outside agents to comply with applicable laws and regulations related to bribery and with individual companies’ anti-bribery policies.
MITSUBISHI MOTORS CORPORATION Sustainability Report 2024

In particular, we have formulated control regulations and operational standards on the provision andreceipt of gifts or business entertainment for public
servants, prohibiting the improper provision of suchgifts or business entertainment to public servants ortheir receipt from public servants. When providing
gifts or business entertainment to public servants,
a preemptive application must be made to the general manager of the Legal Department, and must be
provided only if approval is received. We have put
in place management and operational standards inaddition to those for public servants. These standards
expressly prohibit the provision of gifts or businessentertainment that is illegal or goes beyond generally
accepted bounds and the receipt of illicit payoffs. In
addition to this, we provide guidelines for the scopeof exceptions to the above and make filing of an application compulsory to ensure transparency. In casethese standards are violated, a system is in place forinternal reporting and the formulation and implementation of measures to prevent recurrence.
Since many employees in sales sites directly handle
money with customers, there is a heightened risk of improper conduct such as embezzlement. At our domestic
sales subsidiaries we conduct regular education andtraining to instill thorough awareness of our compliancepolicies and prevent improper activity. Each sales subsidiary implements site audits regularly. As part of ourinternal auditing of affiliated companies in Japan, ourInternal Audit Division also conducts operational auditsof domestic sales subsidiaries. Audit results are reported to our President & CEO, and the results are also
shared with our Domestic Sales Division. We follow up
the progress of action plans for improvement.
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109▶ NextTargetl 16.5

We work to thoroughly prevent corruption atoverseas subsidiaries and associates by assigningoversight to their executives and employees. Prior totheir appointment, we provide training on legal risks,
including the prohibition and prevention of corruption.
When conducting audits of overseas subsidiaries,
our Internal Audit Division also verifies the progress ofefforts to prevent bribery and other corrupt practices.
In FY2023, no fine or any other punishment was
imposed on us by regulatory authorities for corrupt
practices. No executives and employees have been
disciplined for corrupt practices.

Political Involvement(Political Contributions)
We respect the requirements set forth in the Global
Code of Conduct to “comply with all laws and rules,”“be impartial and fair” and “be transparent and accountable,” and maintain appropriate relationshipwith politics.
Recognizing that reasonable expenditures are
required to appropriately maintain a democratic government, we consider making political contributions
to be one aspect of its social responsibility. Whenmaking such contributions, we do so in accordancewith the Public Offices Election Act, the Political Funds
Control Act, and other laws and regulations related
to politics. We also ensure to follow our own internal
rules for approval.
In FY2023, we donated ¥13.9 million to the People’s
Political Association.
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Message fromthe President & CEO

Sustainability Management

Environment

SocialGovernance

Disclosure Based on
the TCFD Recommendations

ESG Data

Targetl 8.7

Information Security
MITSUBISHI MOTORS recognizes its social responsibility to adequately protect its important information
assets (information and the IT systems, equipment,
media, facilities, and products that handle this information) in the course of its business activities in ordertion protection are tend to be strengthened aroundand strive to maintain proper tax payments in compli-

the world. We coordinate with our bases in individual

ance with international rules and national regulations.

countries, putting in place systems to respond appropriately with their laws and regulations on the protection of personal information.
We did not receive any appeals related to breachesof customer privacy or loss of customer data in FY2023.

to gain the trust of all its stakeholders. We are promoting the following information security measures.
• Putting in place and reviewing internal regulations
related to information security• Strengthening management of information assets
and measures to counter ransomware due to malware infections and cyber attacks• Regularly conducting drills based on the assumptionof an incident at CSIRT*, the organization that prevents security incidents and responds promptly toincidents when they do occur• Providing employees with e-learning about information security, e-mail-based training, and alerts via
our intranet• Monitoring information security activities by the
Information Security Committee

Security Export Control
We sincerely believe in the importance of strict security export controls to prevent the proliferationof weapons of mass destruction and the excessive
accumulation of conventional weapons in order tomaintain international peace and security.
To conduct strict export controls, we have established “Security Export Control Regulations.” We
ensure the legality of our export transactions throughour management system, with its the Security Export Control Committee, led by the Executive Officer,
President & CEO, who serves as chief security export
control officer.

*CSIRT: Computer Security Incident Response Team

Approach to Taxation
Protection of Personal Information
Based on our Privacy Policy, we have built a management framework by establishing internal rules
and taking other measures. We also conduct ongoingeducation, such as through the use of e-learning for
employees. In addition, rules on personal informaMITSUBISHI MOTORS CORPORATION Sustainability Report 2024

Targetl 16.5

We recognize that proper tax payment in all operating
countries is one of key elements of corporate social
responsibility for multinational companies.
We have established the following Global Tax Policy
to promote tax compliance in business activities. In linewith this policy, we have created a governance system
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110▶ NextGlobal Tax Policy for MITSUBISHI MOTORS Group
1.	 Tax compliance
The MITSUBISHI MOTORS Group (hereinafter simply
referred to as “MITSUBISHI MOTORS”) pledges topursue proper tax payments all over the world basedon the “MITSUBISHI MOTORS Global Code of Conduct.”This means MITSUBISHI MOTORS maintains appropriate and timely tax payments by understanding theintent and purpose of the Base Erosion and Profit
Shifting (BEPS) Action Plan, which was developed andpublicized by the OECD and G20 countries, as well as
by complying with tax regulations in all countries andregions in which it conducts businesses, tax treaties,
and other international tax regulations related toits business. In addition, MITSUBISHI MOTORS pledges not to use any tax havens or loopholes that areagainst the intentions and purposes of laws.
2.	Corporate governance on tax matters(1) M ITSUBISHI MOTORS recognizes corporate governance on tax matters as an infrastructure topromote tax compliance and tax planning and,
under the initiative of top management, pursues
the optimization of governance systems to secure
the accuracy and transparency of accounting andtax-related information.
(2) The MITSUBISHI MOTORS Group makes disclosures to all relevant taxation authorities and discloses appropriately and in a timely manner the
BEPS transfer pricing documentation and otherinformation required for submission by multinational enterprises.
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