Basic Policy
We have established the MUFG Group Code of Conduct as a set of guidelines for how the Group’s directors and employees should make decisions and act on a daily basis to realize the MUFG Way. The code expresses our commitment to complying with laws and regulations globally, to acting with honesty and integrity, and to behaving in a manner that supports and strengthens the trust and confidence of society.
In addition, as we expand the geographic scope of our business globally, we are committed to keeping abreast of developments in laws and regulations of the jurisdictions in which we operate, including anti-money laundering and antibribery rules as well as competition laws, while paying attention to trends in financial crimes.
Compliance Framework
Management and coordination of compliance-related matters are the responsibility of separate compliance management divisions established at the holding company and the major subsidiaries, namely, the Bank, the Trust Bank and the Securities (hereinafter, the “three subsidiaries”). Each compliance management division formulates compliance programs and organizes training courses to promote compliance, and regularly reports to each company’s board of directors and Executive Committee on the status of compliance activities.
The holding company has established a Group Compliance Committee while the three subsidiaries have Compliance Committees under their executive committees to deliberate key issues related to compliance. Additionally, the holding company has a Group Chief Compliance Officer (CCO) Committee, which consists of the CCO of the holding company and the CCOs of the three subsidiaries. The Group CCO Committee deliberates important matters related to compliance and compliance-related issues for which the Group should share a common understanding. Furthermore, the CCO of the holding company reports on the status of its initiatives to the board of directors on a semi-annual basis (twice a year) as a general rule.
Reporting on Compliance-Related issues
Reporting System
Whistle-Blowing System
Having positioned its whistle-blowing systems as an important governance tool, MUFG has helped each Group company develop such a system to ensure their ability to identify compliance issues early so that any problems can be quickly rectified. Moreover, the MUFG Compliance Helpline, which has established as group–wide reporting channel outside the workplace, operates year-round and is capable of handling a report from any Group member no matter what their location on an around-the-clock basis.
The Code of Conduct and the internal policy of each Group company ensure anonymity of the whistleblower and confidentiality of the report, so that whistle-blowers will not be subjected to detrimental treatment. We are thus ensuring thorough protection for whistle-blowers even as we carry out investigations into issues being reported and conduct corrective measures, as well as follow-up inspections.
In addition, we aim to ensure that each employee is able to quickly access the Helpline without hesitation whenever he/she has even the slightest suspicion regarding compliance. To this end, we strive to enhance our reliability by making sure the Helpline contact point is well known and our activity well understood by showing the numbers we took care of, and moreover, sharing actual compliance-related cases in a manner that protects the anonymity of individual whistle-blowers.
In fiscal 2022, a total of 411 reports were accepted at MUFG and main Group companies. None of the reports had a material impact on our Group’s management that could have led to a large-scale media coverage.
In line with the revised Whistleblower Protection Act, which came into effect in June 2022, we have upgraded whistle-blowing systems in place at MUFG as well as Group subsidiaries and affiliates, so that employees can feel more secure about using the systems.
MUFG Accounting Auditing Hotline
MUFG has set up an accounting auditing hotline to be used to make reports related to instances of improper practices (violations of laws and regulations) and inappropriate practices, or of practices raising questions about such impropriety or inappropriateness, regarding accounting and internal control or audits related to accounting in Group companies. The audit committee oversees the reporting process to ensure the appropriateness and effectiveness of the reporting process and monitors the reports received through the hotline. The reporting process works as follows, and may be carried out via letter or e-mail:
Hokusei Law Office, P.C.
Address: 8F Sanshi Kaikan, 1-9-4 Yurakucho, Chiyoda-ku, Tokyo
e-mail: MUFG-accounting-audit-hotline@hokusei-law.com
When reporting information please pay attention to the following:
- Matters subject to reporting are limited to those related to accounting, internal control regarding accounting and accounting auditing of MUFG Group. Please note that other inquiries may not be answered.
For any inquiries about the products and services of Group companies, please refer to the inquiries listed on each company's website. - Please provide detailed information with respect to the matter. Without detailed factual information there is a limit to how much our investigations can achieve.
- Anonymous information will be accepted.
- No information regarding the identity of the informant will be passed on to third parties without the approval of the informant him- or herself. However, this excludes instances where disclosure is legally mandated, or to the extent that the information is necessary for surveys or reports, when data may be passed on following the removal of the informant's name.
- Please submit reports in either Japanese or English.
- If the informant wishes, we will endeavor to report back to the informant on the response taken within a reasonable period of time following the receipt of specific information, but cannot promise to do so in all instances.