Compliance

Latest Update : May 29, 2026

Basic Approach

The MinebeaMitsumi Group believes that implementing compliance is an essential part of promoting CSR. Accordingly, we have established the MinebeaMitsumi Group Code of Conduct and MinebeaMitsumi Group Officer and Employee Compliance Guidelines, and on the basis of these policies, we strive to achieve fair, appropriate and highly transparent management.

Please refer here for detailed information regarding the MinebeaMitsumi Group Code of Conduct and MinebeaMitsumi Group Officer and Employee Compliance Guidelines.

Compliance Promotion Structure

The Representative Director, Chairman CEO of the MinebeaMitsumi Group has ultimate responsibility for compliance. The Compliance Committee, which reports directly to the President, meets twice a year and on a timely basis to ensure implementation of the Code of Conduct and make prompt decisions on emergency response measures in the event of significant violations of the code.
The Compliance Promotion Office acts as the administrative body for the Compliance Committee and implements various measures to promote compliance.
In FY2025, we appointed compliance officers as well as staff and sub-staff in charge of compliance at Minebea Liner Motion Inc. that were added to the Group as a result of business integration and reinforced structures throughout the Group.

Compliance Framework

image : Compliance Framework

Relevant Materiality

16. More robust risk management

Compliance Awareness Survey

The MinebeaMitsumi Group conducts compliance awareness surveys biennially to gauge employees' understanding of compliance.

Based on the results of the survey, which was conducted in November 2023, we confirmed that there are no problems regarding awareness and interest regarding compliance. Feedback on the survey results was provided to individual divisions, and we are reinforcing training based on the results. We are also broadly disseminating information on how to use consultations services, which was identified as an issue.

We plan to conduct the next survey in FY2025.

Compliance Education

image : Employees receive training

Employees receive training

The MinebeaMitsumi Group delivers comprehensive training programs to deepen compliance awareness among all executives and employees.
In FY3/2026 (Apr.2025-Mar.2026), we conducted compliance training (on topics such as harassment prevention) for 1,355 employees as part of rank-based training and onboarding for mid-career hires.
In the second half of this fiscal year, we conducted compliance training for approximately 14,000 executives and employees across all Group Companies in Japan (including temporary and contract employees),as well as our overseas expatriates.
The training program covered not only key laws and regulations such as insider trading regulations, antimonopoly (antitrust) laws, and labor laws, but also topics like preventing harassment and the appropriate use of our whistleblower hotline.
In addition to focusing on reaffirming the core principles of our corporate philosophy and Code of Conduct, the training program used recent social case studies to reinforce the importance of compliance. Participants solidified their grasp of practical, ethical measures to mitigate risks inherent in their daily operations.
Furthermore, the Compliance Promotion Office spearheaded various initiatives to advance compliance, including fostering a culture of integrity by publishing a quarterly newsletter on the internal portal site.
The MinebeaMitsumi Group views compliance not as a mere formality, but as an essential element for safeguarding the company's sustainable growth and public trust.

Whistleblower Hotline

The MinebeaMitsumi Group has established internal and external consultation services, allowing employees who suspect a violation of the MinebeaMitsumi Group Code of Conduct, or who need guidance on their own decisions, to submit anonymous reports. To ensure the system's independence, corporate auditors receive reports on all whistleblowing cases, monitoring the system's framework and its operational status.

The Code of Conduct and other internal regulations strictly prohibit retaliation against whistleblowers, and mandate the protection of such individuals' confidentiality and anonymity. If an investigation confirms a violation, the MinebeaMitsumi Group takes appropriate disciplinary and corrective actions.
In Japan, we operate under the Whistleblowing Reporting Rules, which we established pursuant to Japan's Whistleblower Protection Act.
We build trust in our reporting system through promotion, transparency, and oversight. We actively promote the whistleblower hotline and its procedures through our internal portal and other channels. We regularly share report volumes and the status of our responses with all employees. To ensure rigorous oversight, the hotline is closely monitored at the highest levels of leadership—all operational metrics, including the 58 reports received in FY3/2026 (Apr.2025-Mar.2026) by the Compliance Committee and the Board of Directors.

Number of whistleblower reports

(including reports that did not result in actual incidents or violations)

Harassment Time & labor
management
Information
management
Accounting &
bookkeeping
Corruption Health
and
safety
Quality
control
Others
FY 3/20263942200110
FY 3/20252570000211

Freight and Compliance Management in Logistics

The Logistics Division is primarily in charge of import and export matters for the MinebeaMitsumi Group. The division creates procedural manuals and guides for adhering to the Customs Law and other regulations and provides a management structure to ensure compliance. In FY2007, we received Authorized Importer and Authorized Exporter certification from Tokyo Customs in recognition of our outstanding freight and compliance management.

Anti-Corruption/Anti-Bribery Rules

In order to strengthen our anti-corruption efforts at a global level, the MinebeaMitsumi group has established the MinebeaMitsumi Group Anti-Corruption Policy, which applies to the entire group, as well as the Anti-Bribery Regulations, which prohibit bribery (including small payments such as facilitation payments) in all countries and regions in which we do business, and strives to prevent bribery by all directors and employees.

The group has established and implemented the "Internal Standards and Procedures Relating to Entertainment and Gifts for Public Officials" for the Asia region, where business practices are particularly complicated. We give utmost attention to risk management to ensure that there is no involvement in corruption, and we do not engage in any entertainment or gift-giving perceived to carry risk. Furthermore, we have established the CSR Procurement Guidelines, and require our partners to prohibit bribery.

Furthermore, the General Affairs Department conducts regular monitoring of these initiatives, and the Internal Auditing Office carries out periodic audits, including from the perspective of anti-corruption.

During the fiscal year ended March 31, 2026, there were no officers or employees who committed anticorruption violations, nor were there any fines, surcharges or settlements related to corruption.

We will continue working to enhance training content, revise internal regulations, and devote efforts to preventing corruption.

The group does not make political donations.

Future Compliance Promotion

The MinebeaMitsumi Group believes that employee awareness and knowledge of compliance should be deepened to establish a corporate culture in which each employee maintains an awareness of compliance in conducting business activities. Moving forward, we will enhance our training programs and thoroughly raise awareness of consultation centers, to strengthen collaboration with countries in order to improve our compliance structure covering the entire MinebeaMitsumi Group.

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