This document constitutes our modern slavery and human trafficking statement, as required by section 54(1) of the UK’s Modern Slavery Act 2015.
We have a zero tolerance policy with regard to modern slavery and human trafficking, and 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 Human Rights Policy1 and Mitsubishi Electric Group Code of Conduct2. These include our continuing commitment to respect international standards related to human rights and to respect the law, to act with highest integrity, and always to conduct ourselves with respect for human rights.
Mitsubishi Electric Corporation, and it’s UK group businesses, have an internal and external whistleblowing system in place. This includes protection for whistleblowers. Implications in terms of modern slavery can be brought via this system.
Mitsubishi Electric Europe B.V. is a wholly owned subsidiary of Mitsubishi Electric Corporation (based in Japan).
Our UK business operations include:
As of 31st March 2023, we employ 752 staff in the UK and our annual turnover to 31st March 2023 in the UK was approximately £371.2 million.
All raw materials and components are sourced from supply partners, both domestically and internationally, in compliance with Mitsubishi Electric Corporation’s “CSR Procurement Policy”3.
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.
Our UK terms and conditions of purchase include Corporate Social Responsibility compliance undertakings from the supplier to apply policies to ensure the supplier and any sub-contractor to the supplier:
Mitsubishi Electric Corporation have been seeking consent from suppliers to agreement on initiatives for social issues including human rights issues. In addition, Mitsubishi Electric Corporation have continued to promote efforts and give instruction to understand human rights violation risks by suppliers (i.e., forced labour using foreign labourers, dangerous and hazardous labour).
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:
(i) the Mitsubishi Electric Group Human Rights Policy: This confirms that protection of human rights and support for internationally agreed human rights are imperatives for the Mitsubishi Electric Group's business activities. Accordingly, as members of the Group, we recognize our duty to prevent any complicity with human rights violations. Our policy commitment includes the following:
During the term:
Mitsubishi Electric Corporation has a continuing programme for the evaluation of the sustainability initiatives of “business partners” (i.e., third party suppliers). Mitsubishi Electric Corporation’s policy is to evaluate all new suppliers.
As part of human rights due diligence required by the United Nations Guiding Principles on Business and Human Rights, the Mitsubishi Electric Group periodically carries out "Human Rights Impact Assessments" in order to assess the impact of the Group's business activities on human rights.
In 2021, Mitsubishi Electric Group carried out the second "Human Rights Impact Assessment" of Mitsubishi Electric, affiliates in Japan, and overseas affiliates, covering a total of 417 sites.
In addition, Mitsubishi Electric Group added a "Human Rights" category to the "General Control Self-Check," in which risks that may have material impact on management are inspected based on the decisions made by the Board of Directors. Mitsubishi Electric Group also checked the status of progress of the "Human Rights Impact Assessment."
In order to enhance the objectivity and transparency of the Mitsubishi Electric Group's human rights initiatives, in February 2022 we joined the Responsible Business Alliance (RBA), an alliance that promotes corporate social responsibility in the global supply chains. We commit to progressively align our own operations with the provisions of the RBA Code of Conduct, to promote continuous improvement of our sustainability efforts. This membership continues throughout 2023.
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.
During the term:
Suppliers to the Mitsubishi Electric Group are requested to gain an understanding of the Group’s Purchasing Policy and CSR Procurement Policy, and to disseminate these policies to their supply chain. They are especially requested to thoroughly comply with the points, which the Group has identified as priority issues to be addressed through the entire procurement supply chain. Additionally, new suppliers are asked to submit their agreement to comply with the CSR Procurement Policy and a completed survey form upon reading and understanding the guidelines.
Every Mitsubishi Electric Europe B.V. employee receives a copy of the Mitsubishi Electric Group Code of Conduct, 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.
Company-wide periodic eLearning training based upon the UK Modern Slavery Act 2015, is conducted, and all UK staff are compelled to partake in such training.
In addition, outside of the UK, Mitsubishi Electric Corporation have been conducting a sustainability-related eLearning program that includes themes on human rights for employees of Mitsubishi Electric and domestic affiliated companies.
Mitsubishi Electric Corporation will continue raising employee awareness of human rights within the Mitsubishi Electric Group.
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 31st March 2023 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.
President and CEO
Mitsubishi Electric Europe B.V.
Issue date: September 2023