Business Conduct Guidelines for Officers and Employees

Enacted: April 2002
Revised: October 1, 2024

These guidelines apply to all officers and employees of Mitsui & Co. Global Logistics, Ltd. (the “Company”). Whenever used in these guidelines, the “employees” include full-time employees, part-time employees, general contract employees, contract employees, fixed-term employees, and secondees to the Company, unless the context otherwise requires.

  • Compliance with the Law and Integrity

    • Officers and employees shall, with an awareness of being members of the international community, comply with all applicable laws and regulations, whether domestic or foreign.
    • Officers and employees shall maintain the highest levels of corporate and employee ethical standards, and, as members of society, conduct themselves with sincerity, in a responsible manner and with common sense and dignity.
  • Respect for Human Rights and Diverse Cultures

    • Officers and employees shall respect human rights and must not discriminate in any way whatsoever between persons based on grounds of race, creed, sex, social status, religion, nationality, age, or physical or mental disability, or any other grounds.
    • Officers and employees shall not engage in child labor, forced labor, or any other conduct that may lead to violations of human rights. In addition, officers and employees shall work together with business partners to ensure that they do not play any part in violations of human rights.
  • Office Environment and Harassment

    • In order that officers and employees, with individuality and diversity, can perform their duties to the best of their ability, they shall respect the character and individuality of one another, make every effort to cultivate an open-minded corporate culture, and create an open and comfortable workplace.
    • Officers and employees shall not, by taking advantage of their position or relationships in the workplace, engage in conduct that goes beyond what is necessary and appropriate for business purposes and causes mental or physical distress to others or worsens the workplace environment.
    • Officers and employees shall not engage in any sexual words or conduct against the will of a person or people around them.
    • Officers and employees shall not treat others in a disadvantageous or detrimental way for the reason of pregnancy, giving birth, and taking child-care leave or family-care leave, nor engage in any behavior regarding these matters that is harmful to the workplace environment. In addition to the foregoing, officers and employees shall not exhibit any language or behavior that can be harmful to the working environment of other workers through any discriminatory act or harassment in the workplace, such as language or behavior that pertains to sexual orientation or gender identity.
    • Officers and employees shall not disturb the sound discipline, environment or good order of the workplace by conduct that is contrary to public order and good moral standards.
  • Health and Safety

    • Officers and employees shall place the highest priority on the health and safety of themselves and all those working in connection with business activities, prevent occupational accidents, and create and maintain a healthy and safe working environment.
    • Officers and employees shall comply with all applicable labor laws and regulations of each relevant country and region and constantly pursue and comply with optimal safety standards for each business activity.
    • Officers and employees shall comply with all laws and regulations related to occupational health and safety, create an accident-free working environment, and actively engage in awareness-raising activities related to occupational health and safety.
  • Compliance with Antitrust Law, Etc.

    • Officers and employees shall not make any agreement or arrangement with the Company’s competitors regarding sales prices, sales volumes, production or supply volumes, sales territories, customers, or any other allocation of markets.
    • Officers and employees shall not collude with the Company’s competitors in any tender, such as by determining a successful bidder or contract price.
    • Officers and employees shall not engage in unfair trade practices, such as boycotts, resale price maintenance or tie-in agreements.
    • Officers and employees shall not unreasonably damage the interests of sub-contractors of the Company through the unjustified demand to reduce purchase prices, rejection of goods, return of goods or delay of payment for purchased goods.
    • Officers and employees shall promote fair, transparent, and free competition, and carry out appropriate business transactions that are compliant with the laws and ordinances observed in each country or region.
  • Conflicts of Interest and Distinction between Public and Private Matters

    • Officers and employees shall not engage in conduct that conflicts, or appears to conflict, with the Company’s interests, such as working for competitors or business partners, or conducting transactions with the Company for their own benefit.
    • Officers and employees shall not use the Company’s assets or information systems for any purpose other than that of the Company’s business.
    • Officers and employees shall not, without the prior consent of the Company, be engaged in any other occupation.
    • Officers and employees shall not, without the prior consent of the Company, acquire any stock of privately held business partners or investees, or prospective investees, of the Company.
    • On the basis of personal relationships, whether inside or outside the Company and including familial relationships, officers and employees shall not act in a manner that conflicts with the Company’s interests, such as by failing to perform their duties properly. Nor shall they harm the working environment or motivation of other officers and employees, such as by causing doubt in the workplace regarding the proper treatment of personnel.
  • Gifts and Hospitality

    • Officers and employees shall not provide public officials or persons in a similar position with any money, gifts, entertainment or other economic benefits in connection with their duties, for the purpose of securing any improper business advantage or in excess of the bounds of social courtesy.
    • Officers and employees shall not make any payment to any agent, advisor, consultant or similar party if they have reason to believe will be used for influencing public officials or persons in a similar position in an unlawful manner.
    • Officers and employees shall not provide officers or employees of business partners and other entities with any money, gifts, entertainment or other economic benefits beyond socially accepted standards. Officers and employees shall also not receive economic benefits beyond socially accepted standards from officers or employees of business partners, etc.
  • Treatment of Company Information

    • Officers and employees shall hold any secret information of the Company, customer information, and personal information as strictly confidential and shall not divulge such information to any third party, neither during or after their employment with the Company, nor shall they use the same for any purpose other than that of the business of the Company.
    • Officers and employees shall treat any secret information divulged by a third party in the same manner as they treat the secret information of the Company.
    • Officers and employees shall not infringe the intellectual property rights of any third party, including by copying computer software without permission.
    • If officers or employees become aware of any information of the Company or its business partners that may materially influence the investment decisions of investors in the Company or in such business partners, they shall not trade in the shares or other securities (insider trading) of the Company or of such business partners unless and until such information becomes public.
    • Officers and employees shall not illegally acquire or use any secret business information of a third party.
  • Compliance with Procedures for Export and Import, Applicable Laws and Regulations and Attention to International Situations, Etc.

    • Officers and employees shall comply with the export and import procedures and not engage in the export or import of prohibited goods.
    • For the purpose of securing international peace and security, officers and employees shall comply with not only all applicable laws and regulations but also with the Company’s internal compliance rules on security trade control when they export goods to any foreign country or engage in other such transactions.
    • Officers and employees shall understand the laws and regulations applicable to the business, goods and services, etc. in which they are engaged, and comply with the procedures related to any necessary permits and approvals.
    • Officers and employees shall comply with applicable trade, investment, and sanctions-related laws and regulations when forming and executing transactions and business. Officers and employees shall also cooperate with governments and related government agencies appropriately, and pay sufficient attention to the policies and measures of each country from the perspectives of international affairs and economic security.
  • Company Assets and Accounting Reports

    • Officers and employees shall properly manage the assets and funds of the Company and use them only for appropriate business-related purposes. Officers and employees shall not establish or maintain undisclosed or unrecorded assets or funds.
    • Officers and employees shall make timely and appropriate accounting reports, ensuring the accuracy of the reports, and shall not make any false or misleading entries in the Company’s books and records.
    • Officers and employees shall comply with the tax laws of each country and, in accordance with the spirit of the law, perform all obligations to pay taxes in an appropriate and fair manner.
  • Political Donations and Other Contributions

    • When making a political donation or other such contribution to various entities, officers and employees shall clarify its purpose and social significance and make such donations or contributions via the use of a method that is appropriate, as well as ensure transparency while complying with the Political Funds Control Act and applicable laws and regulations.
  • Social Contribution

    • As good corporate citizens, officers and employees shall make every effort to achieve harmony with local and international communities, establish relationships of trust with all stakeholders of the Company, and seek the continued improvement of corporate value. Officers and employees shall also actively promote social contribution for the realization of prosperous and comfortable local and international communities and contribute to the development of a sustainable society.
    • Officers and employees shall support the Company’s efforts to identify international exchange (regional contribution), education (human resource development), and the environment as priority fields, with a view not only to economic contributions but also to employee participation, and to promote the dissemination of these initiatives on a global consolidated basis.
  • Protection of the Environment

    • Officers and employees shall comply with all laws and regulations related to the protection of the environment and actively engage in awareness-raising activities regarding environmental protection and the efficient use of resources and energy.
    • Officers and employees shall strive to improve the procedures for evaluating the environmental impact of new business and to achieve the optimum balance between business activities and environmental protection.
    • Officers and employees shall contribute to the development and spread of environmentally friendly technology and always take into consideration issues of safety.
  • Action against Antisocial Groups

    • If sokaiya, organized crime groups, or other antisocial forces make unreasonable demands on the Company, officers and employees shall respond firmly and shall not seek an easy monetary settlement.
    • Officers and employees shall never deal with any antisocial group or any entity that is connected with such antisocial group.
    • Officers and employees shall not become involved in any way whatsoever in any act of terrorism, money laundering, the use of illegal substances, or any other such crimes.
  • Ensuring the Quality and Safety of Services and Products

    • Officers and employees shall pursue the appropriateness and safety of all logistics services and products provided by the Company, in accordance with laws, regulations, and relevant internal rules, through all processes and at every stage, from the purchase of raw materials, manufacturing, and distribution through to disposal.
    • If officers or employees receive information regarding an accident involving logistics services or products provided by the Company, or any other information concerning safety, they shall immediately and accurately report such information to their superiors and the relevant units. If damage occurs as a result of such accident, officers and employees shall respond promptly and appropriately in good faith.
  • Reporting and Disciplinary Action

    • If officers or employees discover conduct that violates these guidelines, they shall report or consult with the president, the relevant divisions including the Management & Administration Unit, or their superiors, including the general manager of their branch, department, or office.
    • Officers and employees who wish to report or consult anonymously regarding violations of these guidelines may report or consult with outside lawyers or third-party organizations designated by the Company.
    • Officers and employees shall cooperate in any investigation into whether a violation has occurred. If, as a result of the investigation, it becomes clear that a violation has occurred, the violator and his or her superior will be subject to disciplinary action in accordance with the Employment Regulations.
    • The Company will not treat officers and employees who report or consult regarding violations, or who cooperate in investigations, disadvantageously on that basis, and will exercise the utmost care to ensure that such treatment does not occur in any workplace. Officers and employees who treat such persons disadvantageously or retaliate against them will be subject to disciplinary action.
  • Abolition and Amendment

    • Any abolition or amendment of these guidelines shall be determined by the Board of Directors.
  • Other Matters

    • If a business contractor assigns its personnel to work on-site at the Company on a full-time basis, the Company shall request such business contractor to ensure that said personnel comply with these guidelines.
    • If a temporary staffing agency dispatches personnel to the Company, the Company shall request such temporary staffing agency to ensure that said personnel comply with these guidelines.