FY 2022 Modern Slavery Statement

Contents
1. Message from the Senior Vice President
2. About the Statement
3. About Mitsubishi Corporation
4. MC’s Philosophies and Principles
5. MC’s Commitments in Relation to Modern Slavery
6. MC’s Activities in Fiscal Year 2022
in Relation to the Prevention of Modern SlaveryA) Training and Awareness RaisingB) Investment ScreeningC) Supply Chain Managementa) Formulation of Guidelinesb) Review of our Purchasing Policyc) Supply Chain Surveysd) Communication with Supplierse) Grievance Mechanismf) Dialogue with Stakeholdersg) External collaboration with international organizations
7. Looking Ahead
8. Approval by MC’s Board of Directors

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1.

Message from Kenji Kobayashi, Senior Vice President
Mitsubishi Corporation (“MC”), since its establishment, has
held the Three Corporate Principles as its core philosophy,
and aims to contribute to the sustainable development ofsociety by conducting its global business activities withintegrity and fairness in line with these principles.
The need to find solutions to the challenges facing the
global environment and society is becoming more urgent,and expectations upon the private sector to be part of those solutions to societal issues such as climatechange, human rights, and biodiversity are increasing year by year.
In October 2021, we formulated our “Roadmap to a Carbon Neutral Society” in which we declared our goalof achieving a carbon neutral society, fulfilling our responsibility as an active player in industries including
resources and energy by maintaining stable energy supplies while providing decarbonization solutions.
In this Roadmap, in addition to committing to halve our GHG emissions by FY2030 (FY2020 baseline) and toachieve Net Zero by 2050, we have also established “Integrated EX (Energy Transformation) / DX (Digital
Transformation) initiatives to ’Create a New Future’” as a common theme for company-wide businesspromotion.
Furthermore, in Midterm Corporate Strategy 2024, we defined and announced our goal of creating"MC Shared Value (MCSV)" as the continuous creation of significant shared value by enhancing the MCGroup’s collective capabilities to address societal challenges.
In April 2023, MC established the position of Chief Stakeholder Engagement Officer (CSEO) and I have been
appointed to strengthen mutual engagement with a diverse range of stakeholders. The MC Group willcontinue to communicate with our stakeholders and to help provide solutions, including with respect to
global agenda items such as the protection of human rights through our business to continuously create
MCSV.

July 24, 2023_________________________________________
Kenji Kobayashi
CSEO, Senior Vice President

1Mitsubishi Corporation2.

About the Statement

As a company which carries out a portion of its business in the United Kingdom (“UK”), MC has
produced this Modern Slavery Statement (this “Statement”) for Fiscal Year 2022 (a period starting from
April 1, 2022 and ending on March 31, 2023, “FY2022”) in line with the requirements of Section 54 of
the UK Government’s Modern Slavery Act 2015 (the “Act”).
This Statement is intended to communicate the steps that MC has taken during FY2022 to prevent any
occurrence of modern slavery in any part of its business or supply chains.
In recognition that modern slavery can manifest in many ways depending on local circumstances, thisStatement covers MC’s efforts to prevent any form of modern slavery; ensuring that workers are safe
throughout its business operations and supply chains; and that all relevant laws and international
standards are being upheld.
This Statement has been approved by MC’s Board of Directors and has been signed by its
Representative Director.
This Statement is publicly available on MC’s website and the Modern Slavery Statement Registry of the
UK Home Office.

3.

About Mitsubishi Corporation

MC is a global integrated business enterprise that develops and operates businesses together with its
offices and subsidiaries worldwide, as well as a global network of around 1,700 group companies, andglobal workforce of approximately 80,000 professionals.
MC has 10 Business Groups that operate across virtually every industry: Natural Gas, Industrial
Materials, Chemicals Solution, Mineral Resources, Industrial Infrastructure, Automotive & Mobility,
Food Industry, Consumer Industry, Power Solution and Urban Development. Through these 10 BusinessGroups, plus the addition of its Industry Digital Transformation Group and Next-Generation Energy
Business Group, MC’s current activities have expanded far beyond its traditional trading operations toinclude project development, production and manufacturing operations, working in collaboration with
our trusted partners around the globe.
Further details are available via the following link: https://www.mitsubishicorp.com/jp/en/
4.

MC’s Philosophies and Principles

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The Three Corporate Principles – “Corporate Responsibility to Society”; “Integrity and Fairness”; and“Global Understanding through Business” – established early in MC’s history, serve as MC’s corephilosophy.
MC has constantly endeavored to enhance its compliance initiatives. Measures have included
establishing the Corporate Standards of Conduct to set forth expectations with regard to how businessshould be conducted, in conjunction with developing various compliance-related internal rules,
introducing a compliance officer system, and expanding and upgrading risk management frameworks.
MC requires employees to conduct business in compliance with local laws and regulations as well as
global standards such as the Universal Declaration of Human Rights established by the United Nations(“UN”), the Guiding Principles on Business and Human Rights, and the core labor standards of theInternational Labour Organization (“ILO”). Through the Code of Conduct, MC also requires employees
to act in a socially responsible manner by complying with the highest ethical standards in the conductof their business.
5.

MC’s Commitments in Relation to Modern Slavery

MC is committed to respecting human rights and strives to ensure that its business activities do notcause or contribute to adverse human rights impacts, including modern slavery. This commitment isexpressed through a variety of channels including the following:•

MC’s Social Charter states that MC “will fully respect human rights” and will also “fully respectfundamental labor rights and endeavor to ensure the provision of proper working
environments with consideration for safety, health and other aspects.”•

MC’s Basic Approach on Human Rights affirms MC’s commitment to various international
standards including the Universal Declaration of Human Rights, the ILO International Labour
Standards and the Voluntary Principles on Security and Human Rights.

•

MC is a signatory to the UN Global Compact, declaring support for the 10 universal principles
in the fields of human rights, labor, environment and anti-corruption. Principle 4 of theCompact states that signatories should strive for “the elimination of all forms of forced andcompulsory labor.”•

MC has announced its Materiality in Midterm Corporate Strategy 2024 as a set of crucial
societal issues that we will prioritize through our business activities. Through “Promoting
Stable, Sustainable Societies and Lifestyles” and “Respecting Human Rights in Our Business
Operations,” MC will continue to implement a sustainable approach to procurement and3

supply operations while taking into account environmental and social factors not only in MC’s
own business but also throughout the supply chain.

•

MC’s commitment to respect and uphold human rights also extends to its supply chains. In
order to convey this stance to suppliers, MC created the MC Policy for Sustainable Supply Chain
Management (the “MC SSCM Policy”), which all suppliers are expected to understand, embrace
and abide by. Article (1) of the MC SSCM Policy states that “suppliers shall employ all
employees of their own free will with no employee being subject to forced or bonded labor.”
The MC SSCM Policy also addresses issues such as child labor, freedom of association andsuitable remuneration.

•

MC has established the Palm Oil Procurement Guidelines, Timber and Paper Products
Procurement Guidelines, and Tuna Procurement Guidelines which set out MC’s stance onhuman rights in relation to the procurement of those products.

6.

MC’s Activities in FY2022 in Relation to the Prevention of Modern SlaveryA)

Training and Awareness Raising
MC provides training on its corporate philosophy, including respect for human rights andrelevant guidelines, on a consolidated basis.
•

Training for all officers and employees: MC’s policies and guidelines, including those related
to respecting human rights through its businesses and supply chains, are communicated to
all new recruits and reinforced at various internal training sessions on a regular basis. These4

policies and guidelines are also conveyed to employees of overseas businesses and affiliatedcompanies at various internal training seminars on a regular basis.
In addition, content related to human rights violations and the Act are incorporated into an
e-learning program which all executives and employees are required to take every year, inorder to cultivate a better understanding of modern slavery.
MC’s data related to training for FY2022 is as follows.
Scope

Total time spent

Officers and Employees

16 hours

Participation Rate*1
96.2%(Non-Consolidated Basis)*1: Average rate of participants for each training course.

•

In July 2022, we held a business and human rights seminar for MC Group companies andglobal suppliers who are subject to our supply chain survey. A total of approximately 200
people representing approximately 70 companies attended this event, where outside
lecturers provided an overview of the various international standards forming thefoundation of human rights due diligence, as well as specific processes in this field. We also
took this opportunity to reiterate our basic approach on human rights and various otherrelated initiatives.

•

Furthermore, from FY2022, in order to strengthen efforts to respect human rights
throughout the MC Group, MC has added human rights related questions to its annual
survey conducted to collect sustainability related information/data on a consolidated basis.
MC will utilize information collected through this survey to continue enhancing its humanrights due diligence activities on a consolidated basis.

B)

Investment Screening
In order to ensure that the direct business operations and relationships that MC enters into do notcause or contribute to adverse human rights impacts, when making decisions on investments, MCapplies a screening process that considers not only financial and legal risks but also environmental,social and governance (ESG) factors, including human rights. With regards to human rights
screening, we examine any potential negative impacts on stakeholders (size, scope and difficulty
to make improvements) and the likelihood that such negative impacts will materialize(procurement country status, industry and region). These factors are all carefully scrutinized fordeliberation and consideration. By having the General Manager of the Sustainability Department

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serve as a member of the Investment Committee, MC has put in place a screening system thatreflects potential environmental and social impacts in its decision-making process. MC’s ESG
screening takes into account various standards which emphasizes the importance of human rights.
These standards include the International Finance Corporation (IFC) guidelines and the Guidelines
for Confirmation of Environmental and Social Considerations published by the Japan Bank forInternational Cooperation (JBIC).

Further details are available via the following link:
https://mitsubishicorp.disclosure.site/en/themes/109/#1208
Furthermore, in FY2022 MC has set environmental and human rights due diligence guidelines andimplemented this program from FY2023. These guidelines state the kinds of due diligence that theBusiness Groups must conduct depending on the risk and types of investment, and also provides
a self-assessment questionnaire model. By setting this unified method across various businessfields, MC can proceed to ensure suitable due diligence and effectively identify, assess, preventand mitigate adverse environmental and human rights impacts.
C)

Supply Chain Managementa) Formulation of Guidelines
MC strives to ensure that it does not contribute to adverse human rights impacts throughout the
supply chain. As part of these efforts, MC has established the MC SSCM Policy, which is madeavailable to MC’s suppliers.
In addition, in the year ended March 2020 (“FY2019”) MC established the Timber and Paper
Products Procurement Guidelines (revised in FY2021) Palm Oil Procurement Guidelines (revised in
FY2020), and the Tuna Procurement Guidelines (revised FY2022) and started initiatives aiming toresolve specific issues related to those products.
b) Review of our Purchasing Policy6By referring to the MC SSCM Policy in its contracts with suppliers*2, MC ensures its suppliers abideby the MC SSCM Policy. MC may ask a supplier to correct their business behavior if there is aviolation of the MC SSCM Policy, and will re-evaluate its business relationship with the relevant
supplier if no correction has been made. MC will continue to work with its suppliers to ensure thatenvironmental and social considerations are taken into account.
*2: The terms and conditions of purchasing contracts, consignment sales agreements, long-term purchasing contracts,
etc.

c) Supply Chain Surveys
In order to confirm that its policies and guidelines are being upheld, MC conducts regular supplierassessments (the “Supply Chain Surveys”) for products that are considered to have high levels ofenvironmental and human rights risks, including modern slavery.
MC selects “products to be monitored” from among all of its business products based on various
international supply chain management declarations and international norms such as the UN
Guiding Principles on Business and Human Rights and prioritizes them in terms of the following
regarding potential impacts to stakeholders: (1) severity (scale, range, difficulty to make
improvements) and (2) probability (procurement country status, industry and region). In FY2022
the number of “products to be monitored” has increased to 18 from the 14 that were identified
in the previous year. In addition, in relation to tuna, palm oil and tea related products, the scopeof coverage has extended to include Tier 2 suppliers (suppliers that deliver to Tier 1 suppliers).
Therefore, the range of products to be surveyed by Tier 2 suppliers, together with apparel whichcame under the Tier 2 supplier survey scope in FY2021, totals 4 products. Current “products to bemonitored” are as follows;
LNG, Plastics (PP, PE etc.), Wood (biomass), Crude oil, Copper, Zinc, Coal, Iron ore, Chicken,
Sugar (cane/raw sugar), Shrimp, Tuna, Cacao, Coffee, Palm oil, Tea, Tires (natural rubber),
ApparelBoth the UN Guiding Principles on Business and Human Rights and the Guidelines on Respecting
Human Rights in Responsible Supply Chains that the Government of Japan released in FY2022
state that it is necessary for companies to include indirect business partners in their initiatives toprevent and mitigate adverse human rights impacts. According to those protocols MC is trying toextend our due diligence to Tier 2 suppliers.
MC asks suppliers questions that take into account the specific issues and risks of the products

7handled by each supplier, with a focus on aspects including “existence of policies, compliance withlaws and regulations”, “prevention of forced labor, child labor and discrimination towards workers”,“environmental protection” and “information disclosure”. We have also established our own web
system to improve convenience and accessibility for suppliers for our supply chain survey, and we
conduct the survey through this system.
Based on the results of the assessment, MC has incorporated a mechanism to monitor suppliersin terms of their governance and operations, identify high-risk suppliers, and determine whether
further surveys or site visits are required. In the event that potential or actual adverse impacts are
identified, or further improvement is deemed necessary, MC commits to engaging with suppliers
to ensure that corrective measures and improvement plans are implemented. Should a supplierfail to take the necessary steps to cease or prevent the adverse impacts identified, MC willreevaluate its business relationship with the supplier. The level of communication with suppliers
achieved through these surveys and site visits provides a valuable opportunity to deepen the
suppliers’ understanding of MC’s stance on sustainability. It also gives MC the opportunity to
deepen communication with its suppliers and provide them with training and assistance asnecessary.
For the survey conducted in FY2022, MC received replies from approximately 1000 companies in
50 countries including China and Thailand. As we have done previously, the results of thisassessment have been shared with stakeholders via MC’s website. MC also began disclosing thenumber and percentage of suppliers the company is working with to share concerns, solve issues,
etc., in order to increase transparency and share progress with all stakeholders.
Our results for FY2022 are as follows.
Area

Number of

The number (%) of suppliers MC is working

surveywith to share concerns, solve issues, etc.*3

responses
North/Central/South America53

1 (2%)

Europe, Middle East, Africa34

1 (3%)

East Asia320

14 (4%)

Asia/Oceania236

2 (1%)

Japan373

23 (6%)*3: As of January 2023 (figure excludes the number of suppliers with which MC has already worked to share concerns,
resolve issues, etc.)

Further details are available via the following link:8https://mitsubishicorp.disclosure.site/en/themes/126/#1039

d) Communication with Suppliers
In FY2022, MC visited a domestic meat processing company, which is a poultry supplier for
MC’s subsidiary Foodlink Corporation. This time, an inspector from DNV Business Assurance
Japan Co., Ltd., a third-party inspecting company, accompanied MC during the visit andevaluated the supplier’s sustainability management system through interviews with the
supplier’s management and employees.
The evaluation was conducted based on
MC’sSupplyconfirms

the

Chain

Checklist

supplier’s

validity

thatofsustainability management systems andits implementation in practice. The
checklist items related to personnel andlabor affairs were found to be generally
properly managed. However, since someof the items did not have policies orprocedures in place, MC requested thatthese policies and procedures be documented and improved. Regarding occupational healthand safety as well as environmental issues, only a small number of the checklist items were
documented and management seemed to be dependent on specific employees for knowledge
about these issues. Although a certain amount of education and training is provided to theemployees and no accidents have occurred as of yet, MC recommended that proper policies
and procedures be established and thoroughly communicated across the company in the
future.
Further details of the report are available via the following link:supplier_inspection_report_202304_en.pdf (disclosure.site)e) Grievance Mechanism
Both the UN Guiding Principles on Business and Human Rights and Japan’s Guidelines on
Respecting Human Rights in Responsible Supply Chains have stated that business enterprises
should enable a remedial system as an important element of the responsibility to respecthuman rights by establishing a grievance mechanism. Through this grievance mechanism,

9individuals and groups can raise concerns or bring complaints about adverse impacts causedby business enterprises, file a grievance, and seek remedy. This allows business enterprises to
use the information and suggestions obtained through the grievance mechanism to identify
and address adverse human rights impacts. In FY2022, MC established a grievance mechanism
through its website which serves as a point of contact for external stakeholders to consult on
their specific concerns.
f)Dialogue with Stakeholders
In order to respond to the ever-changing demands of society, MC believes it is important to
conduct dialogues with all its stakeholders, formulate policies, and follow up with
implementation plans. The main content of MC’s dialogues with its stakeholders is as follows.
•

In FY2022, MC held approximately 40 direct dialogues with shareholders on the topic ofsustainability. MC also conducted 85 direct dialogues with NGOs, including 9 in Japan, 32
in Europe and 44 in the Americas. These meetings provided valuable insights into
stakeholders’ perspectives, including expectations in relation to our strategies toward
the transition to a low-carbon/decarbonized society, as well as policies around individual
fossil fuel projects. MC will consider the suggestions received and will strive to provide
timely and appropriate disclosure of the response measures and policies it formulates.

•

Sustainability Advisory Committee: MC has established a Sustainability Advisory
Committee which consists of external experts representing the perspectives of MC’s
diverse stakeholders including NGOs, international agencies and the ESG investment
sector, as an advisory body to the Chief Stakeholder Engagement Officer (CSEO). MC
conveys its stance on sustainability policies to the Committee members and, with theaim of improving stakeholder engagement, receives advice and recommendations fromthem. With regards to supply chain management, MC has received feedback regarding
its survey methods and risk definitions when reporting on the current year’s activities.

g) External collaboration with international organizations
MC collaborates with external international organizations in order to enhance our knowledge
on human rights initiatives and to continuously conduct capacity building.
•

MC regularly participates in the UN Forum on Business and Human Rights in order to keep
abreast of the latest developments in this field. At the November 2022 meeting of theforum in Geneva, Switzerland, staff from MC engaged in discussions on human rights
initiatives with human rights experts and other attendees.

10•Through its participation in the World Business Council for Sustainable Development(WBCSD) and the Global Compact Network Japan (GCNJ), MC exchanges information withother companies and participates in initiatives to strengthen the exchange of information
and best practices with leading companies and apply such information to businesspractices.

•

Staff from MC also participated in the B+HR Academy in October 2022, together withrepresentatives from MC Group subsidiary companies Toyo Reizo Co., Ltd., MC Agri
Alliance Ltd., and MC Fashion Co., Ltd. The B+HR Academy is a human rights due diligence
training program for Japanese companies run by the United Nations Development
Program. It consists of a two-day course of lectures from both Japanese and overseas
experts as well as group discussions among participants. The MC staff who participatedin this program were able to gain an overall appreciation of the various international
standards that serve as the foundation for human rights due diligence, as well as a deeper
understanding of the specific processes that are used in this field.

7.

Looking Ahead

Within the context of its broader human rights commitments, MC recognizes the importance of
maintaining constant vigilance to identify and address any impacts associated with modern slavery
throughout its global operations and supply chains. In recognition of the salience of these issues, MC
is committed to continuing to enhance its capacity to identify, prevent and mitigate any actual or
potential impacts in this field including the following initiatives.
•

We will work to strengthen our engagement with suppliers and strengthen the risk
associated with Supply Chains.

•

We will strengthen training and educational activities related to Supply Chain
Management and promote stronger Supply Chains Management.

•

We will strengthen information disclosure related to Supply Chains and enhancetransparency related to Supply Chain Management.

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8.

Approval by MC’s Board of Directors

I, Yutaka Kashiwagi, hereby certify that the information contained in this Statement is factual and has
been approved by MC’s Board of Directors on July 24, 2023.

July 24, 2023_________________________________________
Yutaka Kashiwagi
Representative Director, Executive Vice President
Mitsubishi Corporation

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