Code of business ethics

Ethics

Mitsubishi Electric Europe B.V. (“MEU”) is committed to the highest standards of ethics in our conduct of business. This commitment encompasses our company principles and our relationships with customers, suppliers and the communities in which we operate and with each other as employees of every organizational level.
We define business ethics as the moral values and principles of business conduct that are acceptable and appropriate for our society . This is more than simple compliance with the law: we also take account of contemporary moral values in European society, our corporate culture and our high reputation. We hope that our employees will see this Code as largely comprising statements of existing principles in our business practices.

MEU will promote this Code through practical training for all employees. MEU will also direct its managers to encourage awareness of this Code. Company work regulations and procedures in each Company office must take account of this Code and should be interpreted in the light of this Code.
This code is not intended or able to address every ethical situation which may confront employees. MEU recognizes that occasionally an ethical dilemma will arise for employees which requires a management decision as to how best to apply the Code. Employees are encouraged to be aware of the work regulations and procedures applicable in each Company office and to ask for advice and guidance from their managers on any ethical issue in conduct of business.

MEU also expects that employees who are subject to any code of ethics for their profession will respect such code: any conflict between any such code and this MEU Code of Ethics should be notified to the employee’s manager.

Corporate Mission:

The Company’s corporate mission has been set by our parent company, Mitsubishi Electric Corporation.

The Mitsubishi Electric Group of Companies will continually improve its technologies and services by applying creativity to all aspects of our business. By doing so we enhance the quality of life in our society. To this end all members of the Group will pursue the following Guiding Principles.

1. Trust

Establish relationships with all stakeholders based upon strong mutual trust and respect.

2. Quality

Provide the best parts and services with unsurpassed quality.

3. Technology

Pioneer new markets by promoting research and development and fostering technological innovation.

4. Citizenship

As a global player, contribute to the development of community and society as a whole.

5. Ethics and Compliance

Conduct always in compliance with applicable laws and high ethical standards in all endearvours.

6. Environment

Respect nature and strive to protect and improve the global environment.

7. Growth

Assure fair earnings to build a foundation for future growth.

MEU will reflect the principles of this Corporate Mission in its business conduct and in particular through this Code of Business Ethics.

Code of Business Ethics - Key Principles:

Each principle below is fundamental to our standards of ethics in our conduct of business:

a) Compliance with all laws and regulations:

We recognize that the law sets the base level of moral conduct for any community. Our business activities will be carried out in compliance with the applicable law and also with keen sensitivity to ethical standards in modern society and to common-sense.
We shall make no commitments which would have to be achieved by violation of the law or against common-sense, including this Code. Our employees are required to comply with applicable law. For any interpretation or clarification of legal or regulatory requirements, you should consult your manager or other competent advisor at your office.

b) Honest dealing with customer and suppliers:

We are committed to dealing honestly and with integrity with our customers and suppliers. Our employees shall not make any false or misleading representation concerning our products or services. Our employees shall take special care where any affirmative duty may exist as to the accuracy and completeness of information provided on behalf of MEU.

c) Spply of Quality Products and Services:

We are committed to maintain the Company’s high reputation for quality products and services. We are committed to supplying products and services that meet our contractual obligations and our quality standards. We shall ensure that each office maintains on-going product quality and safety assessments so that there is immediate internal review where any quality or safety concern is raised. We shall ensure that a product recall procedure (under control of senior management) is instigated where appropriate.

d) Compliance with competition law/controlled contact with competitors:

We shall not breach EU or applicable national competition law. We shall continue to implement and to improve MEU’s “EU Competition Law Compliance Policy”. We recognize that any breach of competition law could expose the employee and the Company to severe civil liability and potentially to criminal liability. We shall ensure that our employees do not involve the company in any cartel or other anti-competitive activity with competitors or others. Any contact with competitors shall be strictly controlled in accordance with MEU’s “EU Competition Law Compliance Policy”.

e) Use Company resources properly:

We shall ensure that employees use or authorize MEU’s corporate resources only for legitimate business purposes. Any gift, entertainment, drinks, meals, travel, accommodation or other business courtesies offered by MEU (“Corporate Hospitality”) must be lawful and proportionate. Corporate hospitality must never be tainted with any suggestion or implication of some unlawful conduct even if the hospitality is offered with all proper intentions. Corporate hospitality should not influence (or even appear to influence) a customer’s decision to purchase goods or services from MEU. Our employees will be directed to ensure that any corporate hospitality is offered only in the context of celebrating an existing business relationship. We acknowledge that it is essential for our reputation that any corporate hospitality offered be restricted to a level that can be regarded objectively as satisfying these tests.
Further, any corporate hospitality must also be within the limits acceptable to the recipient company: in any event, some companies or organizations forbid receipt of any corporate hospitality whatsoever by their employees.

Where MEU is a purchaser, our employees must never accept, directly or indirectly, anything of value where receipt could or might appear to influence any decision with respect to MEU’s purchasing from any third party. Where an MEU employee receives any gift which does not meet these standards, the employee must notify the local MEU office management and return the gift with an explanation as to MEU policy preventing acceptance. The MEU employee must also refuse any other form of corporate hospitality from a supplier which does not meet these standards.

MEU employees should be aware that it is very likely that applicable national law imposes severe penalties for any infringement of anti-corruption laws, including personal criminal liability. There is likely to be very strict control, or even absolute prohibition, of corporate hospitality to members or employees of any European, national or local government or authority. Similarly, MEU employees must refuse corporate hospitality from third parties in connection with any government or authority contract.

f) MEU’s responsibilities to its employees:

I) No discrimination or harassment: MEU shall ensure that each office implements policies and procedures to ensure there is no discrimination against any employee or applicant for employment on the basis of race or sex or for any other reason prohibited by applicable law. MEU shall ensure that each office applies policies and procedures to ensure there is no harassment in any form by one employee against another. MEU shall ensure that employees have an appropriate means of referring any complaint as to discrimination or harassment to their Human Resources Department or senior management.

II) Workplace Safety: MEU shall seek to establish a work productive working environment in each office. MEU shall ensure that each office establishes and maintains policies and procedures towards injury-free work. MEU seeks a workplace environment that is free from recognized safety and health hazards.

III) Employee Privacy: MEU makes a sharp distinction between its employees’ business and private affairs. MEU will respect employee privacy and dignity. MEU will comply with applicable national law regarding employee privacy. If applicable national law permits MEU to monitor an employee’s work performance, any monitoring shall not be unduly intrusive and shall respect the employee’s right to expect a degree of trust from MEU in conduct of work. If applicable national law (or MEU local office policy) permits employees some private usage of MEU’s communications systems, any monitoring of usage by MEU shall only be conducted to the extent permitted by law and shall not be unduly intrusive of employee privacy. MEU local branch offices shall maintain local policies and procedures regarding employee privacy in accordance with this Code.

IV) Respect for employee’s personal data: MEU will comply with all applicable laws regulating disclosure of personal data concerning employees.

g) Responsibilities of MEU employees:

Each employee’s contract of employment and/or the Company’s rules and regulations as may be applicable to that employee’s office will already specify the employee’s particular responsibilities. The following points in this Code do not seek to vary any established terms of employment relevant to any office. Subject to applicable law, where those terms of employment do not specify the following responsibilities, then employees should be aware that these would be applied as points of policy in the context of ethical business conduct:

I) No conflicts of interest: Employees must not allow any personal interest or other unearned benefits to accrue as a result of the employee’s job or position with MEU. Employees must take care to avoid any conflict of interest arising through any involvement with family members. Any actual or potential conflict must be disclosed by the employee to that employee’s manager. This disclosure is required even where the conflict has arisen or may arise unintentionally. Employees should not have any other employment, consultancy, or business relationship with any competitor, customer or supplier of the Company (unless specifically authorized by the Company).

II) Respect Company confidentiality: Employees must keep all MEU business secrets and information strictly confidential. Company information must not be used for employee’s own personal benefit. Company documents must be returned upon request at any time to the employee by MEU where these contain MEU’s proprietary or confidential information. Unless restricted or limited by applicable law, employees will have an on-going obligation of confidentiality in respect of any business secret or confidential information obtained during the course of their employment. The same points apply to any third party business secrets or confidential information obtained by the employee during the course of employment.

III) Do not misuse Company communication systems: If applicable national law or local MEU branch office policy permits any private usage of MEU communications systems, employees should comply with local office policies regarding access and usage to assure data security and for effective IT network operations.

h) Respect security export control regulations:

The Mitsubishi Electric group of companies has a proud record of security export control compliance. We recognise the importance of security export control for our company and for our communities. Each MEU office will maintain a effective compliance procedure to meet both compliance under applicable law and the higher standards as may be set through Mitsubishi Electric Corporation’s own Security Export Control policy.

i) Environmental issues:

We aim for a “recycling based society” and seek to conduct all MEU operations in the manner that safeguards the natural environment such as recycling of resources. Wherever possible, each office shall conduct its operations in a manner that safeguards the natural environment.

j) Respect intellectual property rights:

We recognise that enforceable intellectual property rights are essential for our technologically innovative societies and for our Company’s well-being. We will respect the intellectual property rights (such as patents, copyrights, trademarks) of third parties. Wherever possible, we will actively seek to protect MEU’s own intellectual property rights.

k) Contribution to society and good citizenship:

We seek reasonable profits as commercial company having the spirit to support social development as part of our social responsibilities. We will support organizations and activities of our communities through worthwhile civic and charitable causes

Conclusion:

MEU is committed to the spirit of this Code. The compliance of our employees to this Code of Business Ethics will define our reputation for honesty and integrity. Each MEU employee can strengthen this high reputation by adhering to the standards of business conduct confirmed in this Code and by encouraging all other MEU employees to act in the same way.