Marubeni-Itochu Steel Inc.
Chief Compliance Officer
Executive Vice President
Tatsuhiko Toshita

In September 2002, we established a compliance committee and established fourteen items under our compliance program, which have governed our actions ever since.

Under the mandate of group compliance management, we monitor the status of compliance conformance every six months and extend compliance to domestic and overseas group companies, thereby ensuring thorough compliance even from employees of group companies.

The realm of corporate endeavor includes shareholders, customers, suppliers, consumers, employees, and other types of stakeholders. To address the interests and demands of these stakeholders, a company must both pursue profit and engage in sound corporate activities that ensure the survival and continuation of its business.

Basic policies for compliance are established at the start of all activities, with measures followed to avoid any deviation from these principles. More specifically, we are aggressively attempting to prevent bid rigging, pricing cartels and other violations of antimonopoly laws, and to strengthen anticorruption measures through bans on offering illegal profits to public servants and persons in corresponding positions (reflecting the recent global trend toward tougher crackdowns on bribery). Strict security trade controls are established to lawfully, safely and smoothly maintain trade operations, which is a vital pillar of sales activities.

Compliance Program (Observation Matters)

(1)  Respect for Human Rights, Intolerance of Discrimination and Harassment

Respect human rights; refuse to tolerate acts of harassment.

(2)  Compliance with the Antimonopoly Law, Subcontracting Law and Related Legislation

Avoid private monopolies, unfair trade restraints (cartels) and unjust trade practices.

(3)  Prohibition Against Unfair Competition

Avoid the manufacture and sale of products that infringe on copyrights, trademarks, etc.; the unfair acquisition and use of business secrets; and unfair competitive behavior.

(4)  Observance of all Business Laws

Acquire the necessary permits and licenses, and observe all business laws when conducting business activities.

(5)  Observance of Insider Trading Regulations

Avoid actions that violate insider trading regulations.

(6)  Implementation of Appropriate Import/Export Procedures and Security Trade Controls

Observe laws and regulations, international treaties and other trade-related controls during the practice of appropriate import and export procedures. To maintain global peace and security, implement strict trade controls and refuse to handle cargo that may be used or diverted to proliferate weapons of mass destruction and other unsuitable transactions.

(7)  Observance of Intellectual Property Rights Laws

Show zero tolerance for violations of intellectual property rights owned by other parties.

(8)  Prohibition on Bribes and Gifts and Entertaining, etc.

Avoid bribes and the granting, requesting or pledging of unfair gains to overseas civil servants. Avoid gifts, entertainment or the supply of other services to customers outside the appropriate sphere of conventional wisdom.

(9)  Prohibition Against Provision of Favors to Anti-Social Groups

Adopt firm attitudes toward and refuse to associate with antisocial activities and forces.

(10)Environmental Preservation

Maintain a clear awareness of the company’s responsibilities as a good corporate citizen. Contribute to the prosperity and harmony of human society, and devote the utmost efforts to preserve a sound global environment.

(11)Appropriate Control of Information

Exercise reliable control over the company’s confidential information and confidential information disclosed by third parties.

(12)Appropriate Use of Information System

Show zero tolerance for inappropriate use of or damage to the company’s information systems.

(13)Prohibition Against Conflicts of Interest, etc.

Faithfully carry out the company’s business operations; avoid actions that go against the company’s best interests.

(14)Implement Fair and Accurate Financial Procedures

Implement fair and accurate financial procedures pursuant to clearly defined accounting facts.

MISI’s Compliance Comittee