3-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANFY 2021 Modern Slavery Statement

Contents
1. Message from the Executive 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 2021
in Relation to the Prevention of Modern SlaveryA) Training and Awareness RaisingB) Loan and Investment Proposal ScreeningC) Supply Chain Managementa) Formulation of Guidelinesb) Review of our Purchasing Policyc) Supply Chain Surveysd) Communication with Supplierse) Dialogue with Stakeholders
7. Looking Ahead
8. Approval by MC’s Board of Directors

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3-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPAN1.

Message from Executive Vice President
Mitsubishi Corporation (hereinafter “MC”),
since its establishment, has held the Three
Corporate Principles as its corephilosophy, and aims to contribute to thesustainable development of society byconducting its global business activities
with integrity and fairness in line with theseprinciples.

Midterm Corporate Strategy 2024 sets forth "MC Shared Value (MCSV)" as the continuous
creation of significant shared value by elevating the MC Group’s collective capabilities inorder to address societal challenges. In addition, with six years having passed since our
Key Sustainability Issues were identified, stakeholder expectations of companies regarding
issues such as climate change have grown even higher, and the issues that companies
must address also continue to evolve. Therefore, with the aim of creating MCSV, weannounced the redefinition of our previous "Key Sustainability Issues" in the form of eight"Materiality" as the crucial societal issues that the MC Group will prioritize through ourbusiness activities. As we grapple with the challenges posed by the Materiality, MC will
strive to achieve sustainable growth, including in the financial sense, while more actively
pursuing business opportunities that add value to society. Furthermore, by responding toeach Materiality through these initiatives, MC is also contributing to the achievement of the
UN Sustainable Development Goals (SDGs).
The need to find solutions to the challenges facing the global environment and society is
becoming urgent, and expectations upon the private sector to be part of those solutions arealso increasing. With the expansion of ESG investment in recent years, investors are
increasingly looking at how the companies they invest in are addressing environmental andsocial issues from a long-term perspective in order to assess their potential for sustained
growth. Through proactive dialogue with our stakeholders, MC will work to grasp the needs
and expectations of society, and in addition to supporting the United Nations Global
Compact (*1) and Guiding Principles on Business and Human Rights (*2), MC hasestablished a Policy for Sustainable Supply Chain Management and by asking its suppliers13-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANto endorse, understand, and practice human rights considerations, such as the prohibitionof forced labor and child labor, we will fulfill our responsibilities as a member of the global
community.
The MC Group, which has achieved growth by boldly shifting our business models in linewith societal changes, will continue to help provide solutions, including with respect to
global agenda items such as human rights, etc. through our business.
*1

*2

2.

A United Nations initiative for businesses and other organizations to support 10 universal
sustainability principles in the fields of human rights, labor standards, environment and anticorruption. MC declared its support for this initiative in 2010.
Principles developed in 2011 to give effect to the United Nations “Protect, Respect and Remedy”
Framework" (2008) submitted to and unanimously endorsed by the UN Human Rights Council by the
UN Secretary-General's Special Representative, Professor John Ruggie of Harvard University. It
describes procedures for human rights due diligence that are important for companies to addresshuman rights issues.

About the Statement

As a company which carries out a portion of its business in the United Kingdom (hereinafter“UK”), MC has produced this Fiscal Year 2021 (hereinafter “FY2021”) Modern Slavery
Statement (hereinafter “this Statement”) in line with the requirements of Section 54 of the
UK Government’s Modern Slavery Act 2015 (hereinafter “the Act”).
This Statement is intended to communicate the steps that MC has taken during FY2021(from April 2020 to March 2021) to prevent any occurrence of modern slavery in any part ofits business or supply chains.
In recognition that modern slavery can manifest in many ways depending on local
circumstances, this Statement covers MC’s efforts to prevent any form of modern slavery;
ensuring that workers are safe throughout its business operations and supply chains; andthat 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
Yutaka Kashiwagi, Director, Executive Vice President for MC.
This Statement is publicly available on MC’s website and the Modern Slavery Statement
Registry of the UK Home Office.

23-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPAN

3.

About Mitsubishi Corporation

MC is a global integrated business enterprise that develops and operates businesses
together with its offices and subsidiaries in approximately 90 countries and regions
worldwide, as well as a global network of around 1,700 group companies, and global
workforce of approximately 80,000 professionals.
MC has 10 Business Groups that operate across virtually every industry: Natural Gas,
Industrial Materials, Petroleum & Chemicals Solution, Mineral Resources, Industrial
Infrastructure, Automotive & Mobility, Food Industry, Consumer Industry, Power Solution
and Urban Development. MC’s current activities have expanded far beyond its traditional
trading operations to include 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

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 core philosophy.
MC has constantly endeavored to enhance its compliance initiatives. Measures haveincluded establishing the Corporate Standards of Conduct to set forth expectations withregard to how business should 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 establishedby the United Nations (UN), the Guiding Principles on Business and Human Rights, and thecore labor standards of the International 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 conduct of their business.

33-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPAN5.

MC’s Commitments in Relation to Modern Slavery

MC is committed to respecting human rights and strives to ensure that its businessactivities do not cause or contribute to adverse human rights impacts, including modern
slavery. This commitment is expressed through a variety of channels including thefollowing:•

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

MC’s Basic Stance on Human Rights affirms MC’s commitment to various
international standards including the Universal Declaration of Human Rights, theILO 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 the Compact states that signatories should strive for “the eliminationof all forms of forced and compulsory labor.”•

MC has announced eight revised "Materiality" in Midterm Corporate Strategy 2024
as a set of crucial societal issues that we will prioritize through our businessactivities. 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 and supply operations while
taking into account environmental and social factors not only in MC’s own businessbut also throughout the supply chain.

43-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPAN•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 (hereinafter “the Policy”), which all
suppliers are expected to understand, embrace and abide by. Article (1) of the
Policy states that “suppliers shall employ all employees of their own free will with noemployee being subject to forced or bonded labor.” The Policy also addresses
issues such as child labor, freedom of association and suitable remuneration.

•

MC has established the Palm Oil Procurement Guidelines and the Timber andPaper Products Procurement Guidelines and which set out MC’s stance on humanrights in relation to the procurement of those products.

6.

MC’s Activities in FY2021 in Relation to the Prevention of Modern SlaveryA) Training and Awareness Raising
MC provides training on its corporate philosophy, including respect for human rights
and relevant 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. These policies and guidelines are also
conveyed to employees of overseas businesses and affiliated companies atvarious 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 totake every year, in order to cultivate a better understanding of modern slavery.
MC’s data related to training for FY2021 is as follows.
Scope

Total time spent

Non-Consolidated

Participation Rate (*3)

4 hours

99.2%

Officers and Employees*3•

Average rate of participants for each training course.

Spotlight on the UK: In the UK, MC has provided regular training throughworkshops and seminars to board members, management and employees. In

53-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANFY2021, due to the Coronavirus pandemic, MC conducted an online webinar forcertain regional subsidiaries regarding the Modern Slavery Act and other related
legal matters, in order to raise awareness of human rights issues.
Further details are available via the following link:
https://www.mitsubishicorp.com/gb/en/csr/slavery/B) Loan and Investment Proposal Screening
In order to ensure that the direct business operations and relationships that MC enters
into do not cause or contribute to adverse human rights impacts, all loan andinvestment proposals are vetted through 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, we conduct thoroughexaminations of potential negative impacts on stakeholders (size, scope and difficulty
to make improvements) and the likelihood that such risks will occur (procurement
country status, industry and region). These factors are all carefully scrutinized fordeliberation and consideration. By having the General Manager of the Corporate
Sustainability & CSR Department serve as a member of the Investment Committee,
MC has put in place a screening system that reflects potential environmental andsocial impacts in decision-making. MC’s ESG screening takes into account various
standards which emphasize 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 Bankfor International Cooperation (JBIC).

63-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANFurther details are available via the following link:
https://www.mitsubishicorp.com/jp/en/csr/management/framework/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 Policy,
which is made available to MC’s suppliers.
In addition, in the year ended in March 2020 (hereinafter “FY2019”) MC establishedthe Timber and Paper Products Procurement Guidelines (Revised in FY2021) and thePalm Oil Procurement Guidelines (Revised in FY2020), and started initiatives aiming toresolve specific issues related to those products.
b) Review of our Purchasing Policy
By sharing its Policy for Sustainable Supply Chain Management in the terms andconditions of its purchasing contract, MC ensures its suppliers abide by the Basic
Policy. MC may ask a supplier to correct their business behavior if there is a violationof the Policy. MC will continue to work with our suppliers to ensure that environmental
and social considerations are taken into account.
c) Supply Chain Surveys

73-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANIn order to confirm that its policies and guidelines are being upheld, MC conducts
regular supplier assessments (hereinafter “the Supply Chain Surveys”) for productsthat are considered to have high levels of environmental and human rights risks,
including modern slavery.
MC selects “products to be monitored” from among all of its business products basedon various international supply chain management declarations and international
norms such as the UN Guiding Principles on Business and Human Rights andprioritizes 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 FY2021 the number of “products
to be monitored” has increased to 14 from the original 8 that were identified in FY2016.
Current “products to be monitored” are as following;
Shrimp, Cacao, Coffee, Sugar (cane/raw sugar), Chicken, Palm oil, Tuna, Apparel,
Tea, Tires (natural rubber), Natural Gas/LNG, Plastics (PP, PE etc.), Crude oil, Wood(biomass)

MC asks suppliers questions that take into account the specific issues and risks of the
products handled by each supplier, with a focus on aspects including “existence ofpolicies, compliance with laws and regulations”, “prevention of forced labor, child laborand discrimination towards workers”, “environmental protection” and “information
disclosure”. We have also established our own web system to improve convenienceand 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
suppliers in terms of their governance and operations, identify high-risk suppliers, anddetermine 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 andimprovement plans are implemented. Should a supplier fail to take the necessary steps

83-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANto cease or prevent the adverse impacts identified, MC will reevaluate 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 as necessary.
Furthermore, in order to improve the effectiveness of the Supply Chain Surveys, MC
continuously reviews the content of the questionnaire. In FY2021 the survey was
conducted with additional items such as how human rights policies are communicatedto employees, and whether or not there are mechanisms for reporting and consultation
regarding human rights.
For the survey conducted in FY2021, MC received replies from approximately 1000
companies in 40 countries including China and Thailand. For apparel, the scope of thesurvey was expanded to include Tier 2 suppliers, whereas previously the survey was
conducted on first-tier (Tier 1) suppliers. As previously, the results of this assessment
are shared with stakeholders via MC’s website. MC also began disclosing the number
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 FY2021 are as follows.
Area
North/Central/South

Number of survey

The number (%) of suppliers MC is working

responses

with to share concerns, solve issues, etc.(*4)
42

13 (2%)24

1 (0%)

East Asia274

6 (1%)

Asia/Oceania

193

18 (2%)

Japan

289

60 (7%)

America
Europe, Middle
East, Africa

93-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPAN*4

As of January 2022 (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:
https://mitsubishicorp.disclosure.site/ja/themes/126#1039
d) Communication with Suppliers
In FY2021, MC conducted an online meeting interview (*5) with the management
and employees of Fisheries Cooperative Association of Mitsushima-cho, a supplierof tuna (located in Nagasaki prefecture, Tsushima city) to one of MC’s subsidiarycompanies, Toyo Reizo.
*5 This meeting and interview were conducted online due to Coronavirus
pandemic.
In the meeting, in addition to the external environment related to sustainability, we
also explained our sustainability initiatives (our basic stance on human rights andour efforts to identify and address sustainable supply chains as one of our key
management issues). The meeting provided an opportunity to deepen theirunderstanding of sustainability and our company's initiatives importance.
In the online interview, MC learned that the company is engaged in activities thatlead to sustainable fishing such as collecting debris from the ocean, that there
have been no human rights violations or other problems due to its efforts to create
an open work environment, and that employees engaged in work that involves
occupational health and safety concerns are not only provided with appropriate
training, but that their personnel assignments are made such that workloads are
not unevenly distributed.
Through the interview, MC confirmed that the company’s internal policies onenvironmental and social considerations mentioned above were not clearly
documented in writing. MC therefore requested that these policies be clarified inorder to ensure thorough awareness of the policies and to deepen efforts related tosustainability initiatives.

103-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANd)

Dialogue with Stakeholders

In order to respond to the ever-changing demands of society, MC believes it isimportant to conduct dialogues with all stakeholders, formulate policies, and follow up
with implementation plans. The main content of dialogue with stakeholders is asfollows.
•

Sustainability Advisory Committee: MC has established a Sustainability Advisory
Committee which consists of external experts representing the perspectives ofMC’s diverse stakeholders including NGOs, international agencies and the ESG
investment sector, as an advisory body to the Corporate Functional Officer(Corporate Sustainability & CSR). MC conveys its stance on sustainability policies
to Committee members and, with the aim of improving stakeholder engagement,
receives advice and recommendations from them. Moreover, MC conducts toursof business sites for committee members in order to deepen their understandingof MC’s businesses.

•

NGO engagement: As representatives of the global community and the generalpublic, NGOs are recognized as important stakeholders by MC, and the company
takes seriously the opinions and requests it receive through close communication
on a daily basis to improve our policies. MC is also working together with NGOs toresolve environmental and social issues. In FY2021, we conducted 70 direct
dialogues with NGOs, including 2 in Japan, 48 in Europe and 20 in Americas.

•

Investors and shareholders: In order to accurately grasp and respond to the everchanging demands of society, we place great importance on constructive dialogue113-1,MARUNOUCHI 2-CHOME, CHIYODA-KU, TOKYO 100-8086, JAPANwith our investors, including our shareholders. In FY2021, we held approximately
30 direct dialogues with investors on sustainability issues. We take into accountthe opinions on environmental and social issues obtained through these dialogues
and reflect them onto our policies and measures, and promote timely andappropriate disclosure of the policies we have formulated. To further strengthen
dialogues, in FY2021 we updated the "Human Rights" and "Supply Chain
Management" pages of our Sustainability Website in cooperation with an outside
consultant to expand the disclosure of sustainability-related information to
stakeholders.
7.

Looking Ahead

Within the context of its broader human rights commitments, MC recognizes the importanceof maintaining constant vigilance to identify and address any impacts associated withmodern slavery throughout its global operations and supply chains. In recognition of thesalience 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 isfactual and has been approved by MC’s Board of Directors on 15th July 2022.

July 19th, 2022_________________________________________
Yutaka Kashiwagi
Director, Executive Vice President
Mitsubishi Corporation

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