Commitment of
Top Management

Sustainability Strategy

FeatureEnvironment

SocialGovernanceComplianceTargetl 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 ourefforts to enhance our compliance framework andemployee training, including those at our major affiliates in Japan and overseas.

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 2023

ESG Data

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112▶ 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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Commitment of
Top Management

Sustainability Strategy

FeatureEnvironment

SocialGovernance

ESG Data

Targetl 8.7

ed to the Executive Officer for Internal Control.
Major subsidiaries and associates in Japan and overseas also appoint compliance officers. To help prevent
compliance infractions, in FY2018 we established andstarted operating MITSUBISHI MOTORS Global Hotline.
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.

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,
corrective actions are taken, measures to prevent
recurrence and its’ effectiveness are confirmed, andhorizontal dissemination is implemented, then reportOrganizational 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

DirectSupervise
Coordination

Compliance Officers
Consult/
reportComplianceDepartment

Thoroughly implement focus on complianceprioritization

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

Complianceproblem
consultation

Coordination

Thoroughly
implement
focus oncomplianceprioritization

MITSUBISHI MOTORS
employees

Employee
Consultation
OfficeReportAffiliates
Compliance Officers
Consult/
ReportInformation
Security
Management
OfficeConsultation,
Reporting

Coordination

Outsideattorney
consultation

Consultation,
Reporting

MITSUBISHI MOTORS CORPORATION Sustainability Report 2023

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

Reporting Consultation,
ReportingThoroughly implement
focus on complianceprioritization

Affiliates employees

MITSUBISHI
MOTORS
GlobalHotline

MITSUBISHI
MOTORS and
Affiliates
employees(in Japan
and overseas)

113▶ NextBusiness
partners(in Japan)

Targetl 16.5

As for internal controls related to financial reporting, we verify compliance structures and proceduresfor financial summaries. If inadequate controls arefound at us being evaluated, we request reporting on
the nature of the problem and improvements being
made. In FY2022, we checked the status of 19 Group
companies (MITSUBISHI MOTORS, 6 domestic subsidiaries, and 12 overseas affiliates).
In FY2022, we experienced no serious complianceinfractions that might damage our credibility withcustomers, 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. Outside us, we have set up a consultation office,the “MMC Hotline,” staffed by outside attorneys, as wellas the MITSUBISHI MOTORS Global Hotline, accessible toemployees both in Japan and overseas. We have alsoestablished 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 FY2022, these offices fielded 94 reports or
consultations. Offices endeavor to swiftly resolve
issues raised in reports and consultations after firstseeking to confirm the facts through an investigation
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Commitment of
Top Management

Sustainability Strategy

FeatureEnvironment

SocialGovernance

ESG Data

Targetl 8.7

by the Employee Consultation Office or by enlisting
the assistance of relevant compliance officers. Any
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.
MITSUBISHI MOTORS CORPORATION Sustainability Report 2023

“The MITSUBISHI MOTORS Global Hotline”
established in FY2018 was set up within an outside
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 (FY2022, 94 reports)
Item
Corporate/business proposals
Workplace environment
Labor relations
Human relations/harassment
Compliance, violations of operational rules,
fraud
OthersNumber
4
14
13
29
26
8

Out of total 94 reports and consultations received
in FY2022, the results of the investigation revealed
four cases of compliance problems, including
violations of laws 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.
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114▶ NextTargetl 16.5Specifically, in order to improve the complianceawareness of all employees, when new graduates
or mid-career recruits join us, they receive training
regarding the our history of compliance problems
and the lessons 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 someJapanese subsidiaries, fostering such sense for thegroup 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 and on working overtime and on holidays.
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.
As well as the activities outlined above, in FY2022
outside lecturers taught courses on risk management
for executives to raise their awareness of this topic.
For managers at the general manager level or higher,
an external lecturer provided compliance lectures tohelp improve workplace operations. Outside instructors
also provided communication training to managers at
the level of section manager and above 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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Commitment of
Top Management

Sustainability Strategy

FeatureEnvironment

SocialGovernance

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-BRIVERY POLICY” as a global guideline
for the prevention of bribery and corrupt practices.
This policy states clearly that we tolerate absolutely nobribery or corrupt practices. In our efforts to reinforce
measures for preventing bribery and corrupt practices
throughout the Group, we require affiliated companies
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.
In particular, we have formulated control regulaMITSUBISHI MOTORS CORPORATION Sustainability Report 2023

Targetl 16.5

tions and operational standards on the provision andWe work to thoroughly prevent corruption atreceipt 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, apreemptive application must be made to the generalmanager of the Legal Department, and must be provided only if approval is received.
We have put in place management and operational standards in addition to those for public servants.
These standards expressly prohibit the provision ofgifts or business entertainment that is illegal or goesbeyond generally accepted bounds and the receipt ofillicit payoffs. In addition to this, we provide guidelines
for the scope of exceptions to the above and makefiling of an application compulsory to ensure transparency. In case these standards are violated, a system isin place for internal reporting and the formulation andimplementation of measures to prevent recurrence.
Since many employees in sales sites directly handle money with customers, there is a heightenedrisk of improper conduct such as embezzlement. At
our domestic sales subsidiaries we conduct regular

overseas affiliates by assigning oversight to their
executives and employees. Prior to their 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 FY2022, no fine or any other punishment was
imposed on us by regulatory authorities for corrupt
practices.
No executives and employees have been disci-

education and training to instill thorough awarenessof our compliance policies and prevent improper
activity. Each sales subsidiary implements site audits
regularly. As part of our internal auditing of affiliatedcompanies in Japan, our Internal Audit Division also
conducts operational audits of 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 actionplans for improvement.
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115▶ Nextplined 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,” “beimpartial and fair” and “be transparent and accountable,”and maintain appropriate relationship with 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 FY2022, we donated ¥13.9 million to the People’s
Political Association.

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Commitment of
Top Management

Sustainability Strategy

FeatureEnvironment

SocialGovernance

ESG Data

Targetl 8.7

Information Security

Security Export Control

MITSUBISHI MOTORS recognizes its social responsi-

We sincerely believe in the importance of strict se-bility to adequately protect its important information

curity export controls to prevent the proliferation

assets (information and the IT systems, equipment,of weapons of mass destruction and the excessive

media, facilities, and products that handle this infor-

accumulation of conventional weapons in order tomation) in the course of its business activities in ordermaintain international peace and security.

to gain the trust of all its stakeholders. We are pro-

To conduct strict export controls, we have estab-moting the following information security measures.

lished “Security Export Control Regulations.” We en-• Putting in place and reviewing internal regulations

sure the legality of our export transactions throughrelated to information security

our management system, with its the Security Ex-• Managing information assets and strengthening

port Control Committee, led by the Executive Officer,

measures against computer viruses and cyberattacks

President & CEO, who serves as chief security export• Providing education and inform employees throughcontrol officer.

e-learning, the internal intranet and other measures• Monitoring information security activities by the
Information Security Committee

Approach to Taxation
We recognize that proper tax payment in all operating

Protection of Personal Information

countries is one of key elements of corporate social

Based on our Privacy Policy, we have built a man-

We have established the following Global Tax

agement 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 information
protection are being strengthened around the world.

responsibility for multinational companies.
Policy to promote tax compliance in business activities. In line with this policy, we have created a governance system and strive to maintain proper tax
payments in compliance with international rules andnational regulations.

We coordinate with our bases in individual countries,
putting in place systems to respond appropriately

Targetl 16.5Global 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.

with their laws and regulations on the protection of
personal information. We did not receive any appeals
related to breaches of customer privacy or loss ofcustomer data in FY2022.
MITSUBISHI MOTORS CORPORATION Sustainability Report 2023

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