To ensure that all employees, including those of Group companies, are aware of and share in our common set of values and our ethical approach to basic compliance, we issue to all employees a copy of the Compliance Manual, which contains the Mitsubishi UFJ Lease & Finance Group Code of Ethics and Code of Behavior.
Code of Ethics
The Mitsubishi UFJ Lease & Finance Group Code of Ethics establishes fundamental values and ethics to be embraced by all members of the Group, and shall serve as basic guidelines for the Group's directors and employees.
1. Establishing Trust
In recognition of the importance of the Group's social responsibilities and mission, we will ensure strict information security, while winning the unwavering trust of society through sound and appropriate business operations, including timely and fair disclosure of corporate information.
2. Taking a Customer-first Approach
We will work tirelessly to satisfy customers and earn their support by taking a customer-first approach and effectively communicating with them to offer products and services that best meet their needs.
3. Strict Compliance With Laws and Regulations
We will strictly comply with all laws, regulations and rules to implement fair and sincere corporate activities that do not fall short of social norms. We will also respect international rules and norms as a group of companies with a global presence.
4. Respect for Human Rights and the Environment
We will respect one another's character and individuality as we seek to remain in harmony with society, with an emphasis on protecting the common legacy of humankind that is Earth's natural environment.
5. Confront Anti-social Forces
We will resolutely stand up to anti-social forces that threaten to disrupt the order and safety of our community.
Compliance Promotion System
Our company's compliance system is supervised by the Chief Compliance Officer (CCO), who is responsible for building and operating a company-wide compliance system. Under the leadership of the CCO, the Legal & Compliance Department plans and manages internal systems, and provides guidance and supervision for divisions and Group companies, as well as guidance on correction of non-compliance activities. In the event that a compliance violation is brought to light through a hotline or other means, the Legal & Compliance Department shall act as the secretariat and take action according to the basic policy to ensure prompt reporting to the management team, fulfillment of corporate social responsibility, and prevention of secondary damage and recurrence. Depending on the nature of the compliance violation, a third-party organization may be involved in investigation. We shall strive to investigate the cause, consider and implement measures to prevent recurrence, and re-educate employees to further raise compliance awareness.
Raising Compliance Awareness among Employees
As part of the internal compliance education program, our company holds regular training sessions for officers and employees, including those of Group companies in Japan and overseas, and conducts self-checks twice a year through e-learning.
Training sessions by job class are held for new employees, newly appointed managers, Compliance Promotion Members, and others to acquire knowledge necessary for their respective duties. At Group companies, employee training is conducted based on the characteristics of the industry to which each company belongs, and overseas laws and customs.
Self-checks cover a wide range of topics including code of conduct related to anti-corruption in general and laws and regulations related to financial operations (Money Lending Business Act, Financial Instruments and Exchange Act, insider trading regulations, response to anti-social forces, measures against money laundering/financing of terrorism, etc.). The results of self-checks are reflected in subsequent in-house training and education to strengthen the compliance system and anti-corruption.
Internal Reporting System
Mitsubishi UFJ Lease & Finance Group has set up a Compliance Hotline System as an whistle-blowing system for officers, employees, etc. to report and consult about illegal acts, etc. (any act of violation of laws and regulations, internal rules, Code of Ethics, or acts deemed likely to be such by officers, employees, etc.), including corruption.
Under the Compliance Hotline System, there are (1) the General Manager of Legal & Compliance Department, or a person designated in advance by the General Manager of the Legal & Compliance Department, (2) an Audit & Supervisory Board Member, (3) an Outside lawyer, and (4) an External Consultation Desk. These serve as contact points for officers and employees to report and have consultations with a sense of assurance. Anonymous reports and consultations are also received by the External Consultation Desk.
Reports and consultations from our business partners and other external stakeholders are received at the "Contact Us" section of our corporate website.
[Matters subject to consultation and reporting]
These refer to any acts engaged in by officers, employees, and others in violation of laws, regulations, internal rules, and the Code of Ethics, or acts suspected of being a violation thereof.
- Acts affecting the protection of customers' interests
- Acts impacting the protection of the environment
- Acts affecting fair competition such as a violation of the Anti-Monopoly Act
- Acts related to provision of illegal benefits, including bribes, to government officials and the like in Japan and overseas
- Other inappropriate acts of violating laws and regulations and social justice
Officers, employees, and others who report or consult shall never be treated disadvantageously for the reason of reporting and consulting.
Basic Policy on Antisocial Forces
The Mitsubishi UFJ Lease & Finance Group has established the following basic policies on antisocial forces and shall endeavor to secure the appropriateness and safety of its operations by ensuring that all officers and employees comply with these policies.
Action against antisocial forces shall be taken as an organization led by the management team pursuant to our Code of Ethics and the provisions of internal regulations. We shall also ensure the safety of employees who respond to antisocial forces.
2.Coordination with external expert organizations
We shall strive to develop close relationships at all times with external expert organizations such as the police, the National Center for the Elimination of Boryokudan, and lawyers.
3.Blocking of all relations including transactions
We shall block all relations with antisocial forces, including business relations.
4.Legal action in civil and criminal cases
We shall reject any unreasonable demands made by antisocial forces and take legal action in both civil and criminal cases as necessary.
5.Prohibition of illegal transactions and funding
We shall never engage in illegal transactions with antisocial forces.
We shall never finance antisocial forces.
Basic Anti-corruption Policy
Mitsubishi UFJ Lease & Finance Group ("MUL Group") ensures compliance with anti-bribery laws and regulations applicable to countries and jurisdictions in which MUL Group performs its business, including the Penal Code, the National Public Service Ethics Act, and the Unfair Competition Prevention Act of Japan, the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and the Chinese Commercial Bribery Regulations, and prohibits provision and receipt of bribery payments that give rise to public suspicion or distrust.
In addition, all officers and employees of MUL Group shall:
- not engage in corruption of any form, including money laundering, embezzlement, and obstruction of justice;
- fully understand applicable laws and regulations, and shall not provide any entertainment or gift that gives rise to public suspicion or distrust, or provide money or any other benefit to make an improper advantage, to any national or foreign public official or any person similar thereto;
- not provide or receive any entertainment or gift from business partners or the like, which deviates from common sense or fair business practice; and
- not make any request to receive personal benefits from business partners or the like by utilizing their position/authority at their company.
Further, in order to prevent bribery in relation to businesses in which MUL Group is involved and to ensure fair business performance, MUL Group kindly asks its business partners also comply with anti-bribery laws and regulations, and asks for their understanding and cooperation with MUL Group's Basic Anti-corruption Policy.
Policy for Security Export Control
From the viewpoint of maintaining international peace and security, security export control is intended to regulate and control trade with regard to not only weapons but also catch-all goods and technologies, in view of concerns that they may be used for the development of weapons of mass destruction (WMD) and the activities of concern by terrorists. We, Mitsubishi UFJ Lease Group, in reinforcing our overseas business base and enhancing functions in our overseas business, hereby set forth this Policy for Security Export Control and shall comply with relevant law and ordinances, so that we will endeavor to maintain international peace and security.
- We comply with applicable laws and regulations relevant to export control in the countries and regions in which we operate our business. We set forth procedures for confirmation and control necessary for that purpose, and practice them.
- We set forth confirmation procedures on final end-use and end-users, and practice them. We will not engage in any transaction with regard to goods and technologies which are concerned with or to be used for military purposes or the expansion of WMDs.
- We have established a control system necessary for export control, including auditing, internal education, and documentation management, etc.
- We guide and assist our group companies so that appropriate procedures will be taken in our group companies.