ANTI-SLAVERY & HUMAN TRAFFICKING POLICY STATEMENT for the financial year ended 31 March 2017

Our Policy

We have zero tolerance policy with regard to modern slavery and human trafficking.
We are committed to monitoring, developing and improving our operations to combat slavery and human trafficking.
We seek to ensure there is no modern slavery human trafficking or other abuse of human rights in our business operations or in any of our supply chains.
As a member of the Mitsubishi Electric Corporation group of companies, we apply the Mitsubishi Electric Group Conduct Guidelines1. These include our continuing commitment to respect the law, to act with highest integrity, and always to conduct ourselves with respect for human rights.

Our Organisation’s structure

Mitsubishi Electric Europe B.V. is a wholly owned subsidiary of Mitsubishi Electric Corporation.

Our UK business operations include:

-
sales and marketing of Mitsubishi Electric air conditioning, heating, cooling and ventilation products and services, automation and control products and services, automotive parts, lift and escalator systems and services;
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sales support activities for Mitsubishi Electric semiconductors, photo printers and display screen products marketed by other national branches of Mitsubishi Electric Europe B.V.;
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supply of goods and services to the power engineering sector, including supply of gas insulated switchgear systems and wind turbine switchgear and associated R&D activity;
-
purchase of materials and products within Europe for export to our parent company.

As of 31 March 2017 we employ over 600 staff in the UK and our annual turnover to 31 March 2017 in UK was in excess of €400 million.

Our supply chains

Our principal supplier of goods and services is our parent company Mitsubishi Electric Corporation. We also buy goods and services from other Mitsubishi Electric group companies.
We may source other goods and services to meet our business needs―whether for onward supply to our customers in conjunction with our supply of Mitsubishi Electric goods and services or for export to our parent company.

Our Due Diligence processes for slavery and human trafficking

  • Procurement of goods or services from Mitsubishi Electric Corporation or a member of its group of companies (together “Mitsubishi Electric Group Supplier”):

    We rely on each Mitsubishi Electric Group Supplier’s own Due Diligence processes for risk assessment and verification and its contractual compliance requirements as applicable to its sub-contractors to support compliance within the procurement supply chain.
    As part of these processes, Mitsubishi Electric Europe B.V. and Mitsubishi Electric Group Supplier each apply the Mitsubishi Electric Group Conduct Guidelines and in particular the Group’s Corporate Ethics and Compliance Statement at page 5 of those Guidelines which states:
    “In all countries and regions where we operate, we will always conduct ourselves in compliance with the following principles:….

    Respect for Human Rights:
    We will conduct ourselves always with a respect for human rights. We will not discriminate based on nationality, race, religion, gender, disability or any other reason prohibited by applicable laws nor will we violate international laws providing protection for individual and human rights or any treaties providing such protection to which the country where any of our companies is located is a party. “
    These Guidelines further state at page 6:
    “We will not allow any form of child labour or forced labour in any of our companies.“

    Mitsubishi Electric Corporation has a continuing programme for the evaluation of the Corporate Social Responsibility (“CSR”) initiatives of “business partners” (i.e. third party suppliers). Mitsubishi Electric Corporation’s policy is to evaluate all new suppliers. In the financial year ending 31 March 2017:
    - approximately 1,000 suppliers were evaluated by Mitsubishi Electric Corporation as to the status of their CSR initiatives; and
    - Mitsubishi Electric Corporation’s CSR evaluations identified forty-five suppliers who were given guidance on various CSR compliance issues including the need to improve the management of working hours to ensure compliance with applicable laws.

  • Procurement of goods and services from third party suppliers

    We apply a proportionate approach to our Due Diligence processes for risk assessment and verification with regard to slavery and human trafficking.
    For our risk assessment we take into account the relevant products, components, packaging materials and services, production location and supply chain data.
    We also take into account a supplier’s self-declaration of compliance and any compliance policy and/or other compliance representations.
    Should we identify any higher risk supplier, then we would consider deeper verification processes to assess compliance and for remedy of any non-compliance.

Our Internal Accountability & Training

Every Mitsubishi Electric Europe B.V. employee receives a personal copy of the Mitsubishi Electric Group Conduct Guidelines and must conform to those Guidelines and with all applicable laws.
We have briefed our purchasing staff with regard to the requirements of the legislation, our corporate policies and this Anti-Slavery and Human Trafficking Statement.
During the financial year ending 31 March 2017 we have conducted an eLearning compliance training module for the UK Modern Slavery Act 2015 to our staff.
In UK, 573 members of our staff completed this eLearning, along with a further 51 employees based outside UK.

Whistleblowing

We have a whistleblowing system in place for our staff. This includes protection for whistleblowers.

UK Statutory Compliance

This statement outlines the steps we have taken during the past year to seek to ensure that slavery and human trafficking is not taking place (i) in any of our supply chains, and (ii) in any part of our own business.
This statement is approved by our Board of Directors and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2017 as required by section 54(1) of the UK’s Modern Slavery Act 2015 for ‘Transparency in supply chains etc.'.
This statement is for publication on our website.
Our website’s homepage carries a prominent link to this statement.

Signed by:

Y Saito

Yoji Saito
President and CEO
Managing Director
Mitsubishi Electric Europe B.V.

Issue date: 29 September 2017