Internal Control System Basic Policy

The Company believes that the development and operation of an internal control system is an important management issue, and the Board of Directors has decided on the basic policy shown on the down to ensure the appropriateness, effectiveness, and efficiency of the operations of the Company and its subsidiaries(hereinafter referred to as the “Group”), to maintain and increase its corporate value, to earn the trust of the public and further expand the Group's functions, and to enhance business performance.
This policy applies to all officers and employees of the Company (including advisors, contracted employees,and loaned employees). It also applies, with the necessary changes having been made, to those who reside and work at the Company's offices based on outsourcing contracts or temporary staffing contracts.

1. Systems to ensure that the execution of duties by Directors and employees complies with laws and regulations and the Articles of Incorporation

In order to ensure the adequacy, effectiveness, and efficiency of Mitsubishi Shokuhin’s work and to achieve a sustainable increase in corporate value, a Sustainability Committee to undertake investigation and confirmation relating to measures pertaining to sustainability that focuses on solving problems faced by society and fulfilling social responsibility, an Human Resources Development Committee to undertake investigation and confirmation regarding HR strategy and human capital investment, and a Companywide Risk Management Committee to undertake investigation and confirmation relating to important matters concerning internal controls and risk management shall be established. Furthermore, in order to deal with individual risk issues, committees including an Investment Committee, Compliance Committee, Information Security Committee, Timely Disclosure Committee, and BCP Committee shall be established.
As well as always undertaking business activities while keeping the corporate philosophy in mind, Mitsubishi Shokuhin shall adhere to all laws, regulations, and other rules, and prioritize acting in a way that is in line with social norms. Furthermore, the company shall establish action guidelines concerning compliance for the purpose of implementing and supervising compliance, and shall ensure there is full awareness of these action guidelines throughout the group.
Any person who discovers a violation of laws, regulations, the Articles of Incorporation, or other compliance issues shall report the matter to either the Mitsubishi Shokuhin Group's consultation service established in-house or externally (lawyer) in accordance with the Compliance Action Guidelines. The Mitsubishi Shokuhin Group shall ensure the details reported are kept confidential, and shall not put the whistleblower or anyone who assisted them or who is otherwise involved at a disadvantage.
The Internal Audit Department shall be independent of the departments that undertake business, and monitor the adequacy, efficiency, and effectiveness of the business performed by the group.
Company auditors shall audit the duties discharged by directors, including the status of establishment and functioning of an internal control system, from an independent perspective.
Mitsubishi Shokuhin shall implement audits to contribute to the internal controls of subsidiaries by methods such as dispatching company auditors to the subsidiaries.

2. Systems for the storage and management of information related to the execution of duties by Directors

For information concerning the discharge of duties by directors and other such information, a system shall be constructed to enable appropriate storage and management of such information on the basis of laws, regulations, internal rules, or other rules, and to enable the viewing of the information.

3. Rules and other systems concerning management of risk of loss

The Mitsubishi Shokuhin Group shall control risk by identifying risks associated with the group’s corporate activities as well as establishing internal rules that stipulate procedures to prevent the occurrence of risks, manage risks, and deal with risks that occur.
In order to limit losses in the event of an emergency, the group shall promptly and appropriately communicate information and establish emergency arrangements, and shall also take measures to prevent any recurrence.

4. Systems to ensure that Directors execute their duties efficiently

As well as clearly setting out the authority of directors, meetings of the Board of Directors, the Executive Committee, and other such meetings shall be held to make decisions on basic policy for business and important management matters and to oversee the execution of work, with the intention of making these meetings serve as the basis for a system to ensure that duties are discharged by directors efficiently.
For the discharge of duties on the basis of decisions by the Board of Directors, the organizational structure, authorities, and division of roles shall be clearly set out in internal rules, and a structure for the efficient execution of work shall be put in place. We shall also have subsidiaries put in place a system that is compliant with Mitsubishi Shokuhin standards.

5. Systems to ensure the appropriateness of business operations within the Group

While respecting the independence of subsidiaries, with a focus on the appropriate exercise of shareholder rights, Mitsubishi Shokuhin shall build a close partnership through actions such as the dispatch of directors and company auditors and shall receive reports on important management matters at subsidiaries, and shall also put in place a structure that enables the efficient communication of information concerning internal controls, information sharing, and other such activities.

6. Systems to ensure the appropriateness of financial reporting

In order to ensure the adequacy of the Mitsubishi Shokuhin Group’s financial reports, an internal control system shall be put in place to assist the effective and appropriate submission of internal control reports on the basis of the Financial Instruments and Exchange Act, and this system shall be assessed on an ongoing basis to ensure it is functioning appropriately, with any revisions being made as necessary.

7. Matters concerning employees who are to assist in the duties of Audit & Supervisory Board Members, and matters concerning the independence of such employees from Directors

At the request of the company auditors, directors shall assign suitable employees, provide equipment and facilities, and set a budget for the employees to assist the auditors in the performance of their duties (auditor assistants).
In order to ensure auditor assistants can appropriately discharge their duties, directors shall obtain the agreement of company auditors with regards to human resource affairs (appraisals, transfers, etc.)
In order to ensure auditor assistants can appropriately discharge their duties, directors shall obtain the agreement of company auditors with regards to human resource affairs (appraisals, transfers, etc.)

8. Systems for Directors and employees to report to Audit & Supervisory Board Members, and other systems for reporting to the said members

If a director discovers something that has the potential to cause significant damage to the Mitsubishi Shokuhin Group, they shall immediately report it to the Audit & Supervisory Board.
The company auditors shall attend meetings of the Board of Directors as well as other important meetings, and put in place a system that enables the relevant documentation to be viewed. Furthermore, Mitsubishi Shokuhin’s directors and employees as well as the directors, company auditors, and employees of subsidiaries shall report to the auditors concerning company management and important business matters as well as the status of business execution and results. The aforementioned important matters include matters concerning compliance and risk, and matters concerning internal controls.
Whenever matters are reported to the Mitsubishi Shokuhin Group’s compliance consultation service, the department responsible for compliance at Mitsubishi Shokuhin shall report the matters to the company auditors. On the basis of the Compliance Action Guidelines, the Mitsubishi Shokuhin Group shall ensure the details reported are kept confidential, and shall not put the whistleblower or anyone who assisted them or who is otherwise involved at a disadvantage.
In order for reports to company auditors to be made honestly and without omissions, a structure shall be put in place to ensure reports are made sufficiently in writing, via email, face-to-face, or by other such means.

9. Other systems to ensure that audits by Audit & Supervisory Board Members are conducted in an effective manner

The representative director and accounting auditor shall hold regular discussions with company auditors.
The directors shall establish a system to enable communication, collection and exchange of information between company auditors and relevant parties at subsidiaries (directors, executive officers, company auditors, internal audit departments, etc.) and ensure that company auditors can appropriately discharge their duties.
Directors shall work to put in place an audit environment by taking actions such as making it possible for company auditors to collaborate with lawyers and outside experts as necessary in the performance of their duties.
Mitsubishi Shokuhin shall swiftly pay costs and other expenses pertaining to company auditors’ discharge of duties, except in cases where expenses are proven not to be necessary for the relevant auditors to discharge their duties.