Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

GovernanceManagement System | Governance Structure | Number of Major Meetings and Attendances |Officer Remuneration | Legal/Regulatory Violations | Compliance Violations | Internal Audits
Compliance Consultation Desk | Approach to Prevention of Corruption | Prevention of corruption training
Approach to Tax Governance | Political Contributions | Categories of Shares Issued

Management System
Corporate governance and risk management organization chart

Compliance Consultation Structure1Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

Risk Management Promotion System2Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

Governance Structure
Indicator

Scope
Insidedirectors

Directors

Outsidedirectors(independent)

Unit

FY2019FY2020

FY2021

FY2022

FY2023Male

People98888Female

People00000Total

People98888Male

People23332Female

People01112Total

People24444People
Year115y11m

123y7m123y7mAltogether
Average term

124y9m12-

Ratio of independent outside directors(actual)%183333

Ratio of female directors%

088816

Executive directors-People98888Male

People22222Female

People00000Total

People22222Male

People22222Female

People00000Total

People22222People
Year

44y9m

45y9m

45y0m

44y0m-

Ratio of independent outside Audit &Supervisory Board members (actual)%

50505050-

Ratio of female Audit & Supervisory
Board members%000

Audit &Supervisory
BoardMembers

Inside Audit &Supervisory
Boardmembers
Outside Audit& Supervisory
Boardmembers
Altogether

Average term

400

*Data as of the conclusion of the General Meeting of Shareholders held each fiscal year

Number of Major Meetings and Attendances
Indicator

Unit

FY2019Board meetings
Average attendance of directors atboard meetings
Average attendance of Audit &Supervisory Board members at boardmeetingsTimes12121212%

99100

100100%98100100100

Audit & Supervisory Board meetings
Average attendance at Audit &Supervisory Board meetingsTimes14141414%

9898100100*Data from April to March of each fiscal year

3

FY2020

FY2021

FY2022

Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

Officer Remuneration
Indicator

ScopeUnit

FY2019FY2020

FY2021

FY2022

Directors (excluding outsidedirectors)

Total remuneration
Number of officers*Million yen

489

444464482

People131199Audit & Supervisory Board
Members (excluding outside
Audit & Supervisory Boardmembers)

Total remuneration

Million yen

52

53

52

52

Number of officers*

People2332

Outside officers

Total remuneration

Million yen

55

7075

75

Number of officers*
TotalPeople

4677

Million yen

596

567593611*Above number of Directors and Audit & Supervisory Board members, remuneration, etc. include remuneration for officers who
resigned at the close of the General Meeting of Shareholders.
There is no Officer Remuneration, etc. received by outside officers from our subsidiaries.

Legal/Regulatory Violations
Indicator

Unit

FY2019FY2020

FY2021

FY2022

Cease and desist orders from JFTCCases

0000

Suspension of operations due to, e.g., scandal

Cases

0000

Compliance-related criminal indictments

Cases

0000

Price-fixing

Cases

0000

Bribery

Cases

0000

Other violations

Cases

0000Compliance Violations
Unit

FY2019FY2020

FY2021

FY2022

Number of reports to the Compliance
Consultation DeskIndicator

Cases

17272520

Legal actions received for anti-monopoly/anticompetitive practices(cases under investigation)

Cases

0000Fines charged and settlement fees for antimonopoly/anticompetitive practicesThousand
yen

0000

Cases

0000

Fines charged and settlement fees forcorruption

Thousandyen

0000

Other incidents related to compliance(excluding environmental)

Cases

0011

Thousandyen

001,188

11,182

Reported cases of discrimination

Cases

0000

Reported human rights violations

Cases

―000

Reported cases of child labor

Cases

0000

Reported cases of forced labor

Cases

0000

Reported cases of infringement of rights ofindigenous peoples

Cases

0000

Confirmed corruption incidents(cases under investigation)

Fines charged and settlement fees for othercompliance-related incidents(excluding environmental)*For the reporting boundaries of the data in the table below, see page 45.

4Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

Internal Audits
MGC has established an Internal Audit Division, an internal organization that is dedicated exclusively tointernal auditing and reports directly to MGC’s president. As one activity to monitor internal controls, theInternal Audit Division conducts audits separate from the Audit & Supervisory Board and independent
auditor’s respective audits. It audits every facet of MGC and Group companies’ business execution.
Internal audits verify whether internal controls are implemented and functioning properly from multiple
standpoints, including maintaining operational effectiveness and efficiency, ensuring the reliability offinancial reporting, abiding by laws and regulations applicable to business activities and deterring
compliance violations such as bribery, embezzlement and other forms of corruption, and keeping assets,
all to enable MGC to achieve its management objectives. The Internal Audit Division audits all businessunits (MGC’s divisions, other organizational units equivalent thereto and consolidated subsidiaries) atroughly three-year intervals. Internal audit findings are periodically reported to the Board of Directors
and Audit & Supervisory Board by the director in charge of the Internal Audit Division.

Compliance Consultation Desk
The MGC Group has established a Compliance Consultation Desk accessible both internally andexternally (via a law office) to enable prompt detection of and responses to actual or potential situations
that cannot be dealt with through normal organizational channels, including legal/regulatory violations(e.g., bribery, other acts of corruption, harassment), misconduct and human rights infringements.
All parties connected with the MGC Group can consult with or report information to the Compliance
Consultation Desk, including not only Group personnel inclusive of temp and contract workers but also
their family members and the Group’s suppliers, customers and collaborators.
As a general rule, the Compliance Consultation Desk allows individuals to consult with or report to it bytelephone or in-person conversation in addition to by self-documenting means such as email, fax orletter. It allows individuals to also consult/report anonymously if they so wish and protects the privacy of
those who reveal their identity. The Compliance Consultation Desk never divulges names or reported
facts to anyone beyond a bare minimum of concerned parties who need to be informed to investigate orotherwise appropriately respond to reports.
The privacy of individuals who cooperate with investigations is also protected, with even the fact thatthey cooperated kept confidential.
Investigative findings pertaining to consultations/reports are reported to the Compliance Committee, an
independent body that reports directly to MGC’s president. When the Compliance Committee
determines that a compliance violation has occurred, appropriate corrective and recurrence-prevention
measures are taken and the whistleblower is notified of the outcome. All Compliance Committee
activities’ outcomes are reported to the president, Board of Directors and Audit & Supervisory Boardmembers.

Approach to Prevention of Corruption
Under published "MGC Corporate Behavior Guidelines" and "MGC Group Code of Conduct" that are
well known MGC Group, MGC Group employees, officers, directors and Audit & Supervisory Board
members are obligated to comply with Japan’s Unfair Competition Prevention Act, the U.S.’s Foreign
Corrupt Practices Act, the U.K.’s Bribery Act and other anti-corruption laws and regulations, including
those pertaining to bribery.
In addition, MGC prohibit transactions involving conflicts of interest, such as competitive transactions
and self-dealing, without the company's permission. MGC also prohibit insider trading and acts ofrequesting personal gains or favors from business partners by using one's professional position.
MGC promotes strict, Group-wide compliance and a comprehensive ban on "bribery" with "MGC
Corporate Behavior Guidelines" and "MGC Group Code of Conduct”, both of which have been translated
into English, Chinese and Thai.
Specific anti-corruption initiatives include compliance training programs for management personnel andoverseas subsidiaries’ Japanese expat executives. The programs cover prevention of bribery. Using
anti-corruption training materials, MGC strives to thoroughly and uniformly impart a correct mindset to
newly appointed executive officers with respect to bribery and other acts of corruption.
Additionally, every organizational unit keeps records of entertainment provided and received, thecontent of which is checked during internal audits.

5Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

Prevention of Corruption training
The compliance handbook distributed to all domestic Group companies’ personnel contains the MGC
Corporate Behavior Guidelines, MGC Group Code of Conduct, names of major domestic and foreignlaws relevant to anti-corruption compliance, including Japan’s Public Offices Election Act, Political Funds
Control Act and National Public Service Ethics Act, and internal regulations related thereto. The
handbook aims to promote understanding of, and cooperation toward compliance with, applicable laws
and regulations/ethical standards vis-à-vis public officials.
MGC promotes strict, Group-wide compliance with "MGC Corporate Behavior Guidelines" and "MGCGroup Code of Conduct", both of which have been translated into English, Chinese and Thai.
MGC posts compliance training materials, including content on preventing corruption, on its intranet site
to ensure employees are able to learn about the compliance risks most pertinent to their own jobs.
MGC conducts compliance training programs for management personnel and overseas subsidiaries’
Japanese expat executives. The programs cover prevention of bribery. Using anti-corruption training
materials, MGC strives to thoroughly and uniformly impart a correct mindset to newly appointed
executive officers with respect to bribery and other acts of corruption.

Approach to Tax Governance
The MGC Group recognizes that tax management and appropriate fulfillment of tax obligations incompliance with each country’s relevant laws and regulations plays an important role in the country’s
economic and societal development and helps to earn the support and trust of all stakeholders.
The Group properly pays taxes in accord with each country’s laws and regulations, including thosepertaining to transfer pricing taxation and anti-tax-haven taxation. It is endeavoring to strengthen its
tax governance by building closer ties with affiliates.

Political Contributions (Non-consolidated)
Indicator
Political contributions

Unit

FY2019Thousand yen

496

FY2020

FY2021524

FY2022

197

216

Categories of Shares Issued (As of March 31, 2023)
Number of shares

Number ofvoting rights

Notes

Non-voting shares

―

―

―

Shares with restricted voting rights(treasury shares, etc.)

―

―

―

Shares with restricted voting rights(others)

―

―

―

―

Number of shares
per unit: 100 shares

Category

Voting shares(treasury shares, etc.)

Ordinaryshares17,734,200

Voting shares (other)

Ordinaryshares204,254,800

Shares less than one unit

Ordinaryshares250,199

Total issued shares
Total number of voting rights

222,239,199―

2,042,548

Same as above―

Shares that are lessthan one unit (100shares)――

2,042,548―(Notes) 1. Shares less than one unit includes the following treasury shares and cross-held shares:
Treasury shares: 40 shares, Yamada Kasei Co., Ltd. 5 shares
2. Voting shares (others) includes 500 shares (five voting rights) held in the name of the Japan Securities Depository
Center, Inc.

6

Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

Reporting Scope
Compliance Violations
Japan

Overseas

Company
JSP CORPORATIONJAPAN FINECHEM COMPANY,Company●SAMYOUNG PURE
CHEMICALS CO., LTD.

●INC.

Korea Polyacetal Co., LtdTOHO EARTHTECH, INC●

MGC PURE CHEMICALSJapan U-PiCA Company, Ltd.

●TAIWAN, INC.

FUDOW COMPANY LTD.

●TAIXING MGC LINGSU CO.,MGC Terminal Company, Inc.

●LTD.

MGC Advance Co., Ltd.

●MITSUBISHI GAS CHEMICAL

MGC Woodchem Corporation●ENGINEERING-PLASTICS

Polyols Asia Company, Inc.

(SHANGHAI) CO., LTD.

MGC ENERGY Company

MGC PURE CHEMICALSLimited

SINGAPORE PTE. LTD.

KYOUDOU KASANKASUISOMITSUBISHI GAS CHEMICALCORP.

SINGAPORE PTE. LTD.

MGC Filsheet Co., Ltd.

●PT PEROKSIDA INDONESIAMGC Electrotechno Co., Ltd.

●PRATAMAYonezawa Dia Electronics Co.,Inc.

THAI POLYACETAL CO., LTD●AGELESS (THAILAND) CO.,MGC AGELESS Co., Ltd.

●LTD.

Global Polyacetal Co., Ltd.

●MGC ELECTROTECHNO

EIWA CHEMICAL IND. CO.,

(THAILAND) CO., LTD

Mitsubishi Gas Chemical
Trading, Inc.
Ryowa Enterprise Co., Ltd.

●
●

●

●

●

●

●
●
●

●

●MGC ADVANCED POLYMERS,LTD.
Toyo Kagaku Co., Ltd.

●

●

●INC.
MGC PURE CHEMICALS●AMERICA, INC●MITSUBISHI GAS CHEMICALAMERICA, INC
MGC Specialty Chemicals
Netherlands B.V.

7●

●

●

Mitsubishi Gas Chemical
Sustainability Data Book 2023

Published on October 1, 2023
Mitsubishi Gas Chemical Company, Inc.

Coverage Ratio
Indicator
Ratio of non-consolidated sales ofMitsubishi Gas Chemical Company
against consolidated sales

Unit

FY2019%57.3

8FY202057.9

FY2021
60.6

FY202256.3