We strive to ensure thorough compliance throughout MUFG by committing to earn trust of people in society in our Corporate Vision, adhering to laws and regulations and securing high transparent management.
Compliance management divisions are in place at the holding company (MUFG), as well as at Bank of Tokyo-Mitsubishi UFJ, Mitsubishi UFJ Trust and Banking, and Mitsubishi UFJ Securities Holdings (hereinafter "the three companies). The compliance management divisions at each company promote compliance policies by developing compliance programs and offering training, etc., and report the status of compliance to the Executive Committee and to the Boards of Directors of their respective companies.
MUFG has established the Group Compliance Committee, and the three companies have established their own respective compliance committees. These committees have been established for the deliberation of important compliance issues. MUFG has also established a Group CCO Committee comprising the Chief Compliance Officer of MUFG and the Chief Compliance Officers of the three companies. In the Group CCO Committee, MUFG deliberates important compliance issues as well as compliance issues that require a common understanding throughout the group. At the same time, MUFG shares problematic issues for the group as a whole, and works to prevent problems from occurring. MUFG also holds meetings with additional members for deliberations on compliance issues that are commonly shared among multiple group companies.
MUFG adopted its current Corporate Vision in April 2012, and revised its Principles of Ethics and Conduct in December that year, with the aim of providing concrete standards for decision-making and conduct under that Vision. To ensure that our Vision and Principles are well known and understood among directors and employees throughout the group, we engage in discussions about required policies and measures and continue to implement a variety of efforts.
MUFG also carries out regular compliance awareness surveys of group employees. The FY 2015 survey received responses from over 90,000 employees, and confirmed that there is still a high level of awareness regarding compliance. Individual group companies also grasp and analyze their own issues by raising their own questions, and take steps toward improvement.
Internal Reporting System
MUFG has established internal reporting system including an outside contact point to detect compliance incidents early so that it leads to the correction by taking self-cleansing action. Furthermore, MUFG Compliance Helpline has been set by the holding company. It is intended to supplement the existing system of group companies and accessible for executives and employees of group companies.
Major Compliance Policies and Measures
Conflicts of Interest Management
MUFG has announced Policy for Conflicts of Interest Management, and provide training for the education of officers and employees as well as conducting periodic reviews of the management system.
Response to Anti-Social Elements
MUFG has announced a Basic Policy regarding Anti-Social Elements, which includes organized crime exclusion clauses in contracts, transaction terms and other agreements, and is reinforcing efforts to ensure that anti-social elements cannot take advantage of the financial system.
Basic Policy regarding Anti-Social Elements
MUFG has adopted the following Basic Policy regarding Anti-Social Elements, and our executives and employees are striving to ensure the propriety and safety of all business operations by observing this Basic Policy.
Response as an Organization
In relation to anti-social elements, the Company has established the foundation of express provisions in the Principles of Ethics and Conduct and Internal Rules, etc., and will respond as an entire organization, from the top management downward. In addition, the Company will guarantee the safety of employees who would respond to anti-social elements.
Cooperation with External Specialist Organizations
Under normal circumstances, the Company endeavors to establish a close cooperative relationship with external specialist organizations such as the police, the Centers for the Elimination of Boryokudan, and lawyers.
Blocking of Relationships, including Business Transactions
The Company shall block all relationships with anti-social elements, including business relationships.
Civil and Criminal Legal Responses in Times of Emergency
The Company shall reject improper demands from anti-social elements, and take legal actions on both a civil and criminal basis, as the need arises.
Prohibition of Secret Deals and Provision of Funds
The Company shall absolutely not engage in secret deals with anti-social elements.
The Company shall absolutely not provide funds to anti-social elements.
Efforts to Prevent Bribery
In response to the tighten control over anti-bribery in the international community, MUFG has made the development of the necessary rules regarding the support of overseas anti-bribery regulations as one of the important issues. In addition to enacting the "MUFG Anti-Bribery Policy" on a groupwide basis, we are putting in place anti-bribery rules, regulations and procedures for each Group company and stepping up management preparedness. We conduct training and education in an effort to ensure that these measures are well known and to entrench rules.
(As of July 2017)