Mitsubishi 2009 Annual Report Download - page 24

Development of Internal Control Systems
Based on the “Basic Policy on the Establishment of Internal
Control Systems,” MMC is continually working to ensure com-
pliance with laws and regulations and to promote proper, effec-
tive business execution, in line with changes in the domestic or
overseas environment.
In April 2008, MMC augmented this Basic Policy with policies
concerning financial reporting and the elimination of criminal or
unethical organizations. With regards to ensuring the reliability of
financial reporting pursuant to the Financial Instruments and
Exchange Act, which came into force from fiscal year 2008, MMC
is implementing company-wide measures under the leadership of
the Internal Control Promotion Committee.
Development of Risk Management Framework
MMC is establishing infrastructure for company-wide risk man-
agement systems centered on the Risk Management Promotion
Team in the Corporate Affairs Office, and is also promoting the
sharing of risk information within the company.
To promote systematic risk management and more frequent
initiatives, MMC formulated the “Risk Management Rules” and
appointed a total of 19 risk management officers (as of May 31,
2009) to each operational group.
Based on the core role of these officers, MMC is working to
establish and bolster its risk management systems.
In addition, from fiscal year 2008, MMC has conducted
repeated cycles of risk identification, evaluation, devising and
implementing countermeasures, and monitoring in each depart-
ment, while identifying material risks at the company-wide level
and reporting them to senior management.
In addition, to prepare for unforeseen contingencies, MMC
has developed systems that enable the rapid communication of
information to directors and other key personnel, as well as a
swift and accurate response. On responding to earthquakes and
other natural disasters as well as other crises, MMC provides
regular educational programs and training based on company
rules and standards to ensure safety and minimize damages in
the event of an emergency.
Data Security Management
MMC recognizes that the protection of data assets (information
as well as information systems, machines, media, and equipment
used to handle that information) is vital to fulfilling its social
responsibility and earning the trust of stakeholders.
MMC implements physical, technological, personnel and
organizational measures to maintain and improve data security
management based on its information security policy and internal
rules that conform to ISO 27001.
Protection of Personal Information
MMC formulated a policy for the protection of personal information
in April 2005, and built a management framework to establish inter-
nal rules. MMC also appointed a person responsible for personal
information management at each department under the direction
of the Personal Information Officer. MMC educates staff on the
subject through ongoing e-learning seminars and other programs,
and makes efforts to safeguard personal information in practice.
Security Trade Control
From the viewpoint of maintaining international peace and secu-
rity, MMC profoundly believes in the importance of strict trade
controls to prevent the proliferation of weapons of mass destruc-
tion and the excessive accumulation of conventional weapons.
In order to ensure the appropriate trade control, MMC has
established an Internal Security Trade Control Standard as a
management regulation. In accordance with the standard and in
order to ensure compliance with laws and regulations regarding
security trade control the “Supervisory Committee for Security
Trade Control” was established under the direction of the presi-
dent, who acts as Chief Security Trade Control Officer. Legality of
export transactions is guaranteed by a management system
centered on the committee.
Internal Control Promotion Framework
President
Internal Control Promotion Committee
Evaluation Team Company Law Subcommittee
Evaluation Department Personnel in charge
Departments
(develop internal
controls)
Departments
Departments
(develop internal
controls)
Departments
Affiliated
companies
(develop internal
controls)
Affiliated
companies
Affiliated
companies
(develop internal
controls)
Affiliated
companies
Response to the Financial Instruments and
Exchange Act
(Development and evaluation of internal controls
over financial reporting)
Response to Company Law
(Development of systems in line with basic policies)
Evaluation Department Personnel in charge
Internal Control Systems and Risk Management
22 MITSUBISHI MOTORS CORPORATION Annual Report 2009