Legal Notifications

ANTI-SLAVERY & HUMAN TRAFFICKING POLICY STATEMENT for the financial year ended 31 March 2019

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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 Human Rights Policy1 and Mitsubishi Electric Group Conduct Guidelines2. 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.

  1. 1 See: (open new window)
  2. 2 See link to the English language version at:
    (PDF. open new window)

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;
  • sales support activities for Mitsubishi Electric semiconductors, photo printers and display screen products marketed by other national branches of Mitsubishi Electric Europe B.V.;
  • 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 2019 we employ over 650 staff in the UK and our annual turnover to 31 March 2019 in UK was in excess of €500 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 UK sales and marketing business operations apply terms and conditions of purchase with our third party suppliers that include Corporate Social Responsibility compliance undertakings from the supplier to apply policies to ensure the supplier and any sub-contractor to the supplier:

  • do not permit any slavery or human trafficking in its business or supply chain and to take all reasonable steps to ensure no slavery or human trafficking takes place in its business or supply chain;
  • respect ILO (International Labour Organisation) Conventions protecting children and young workers and never use child labour; and
  • never use any forced or bonded labour or involuntary prison labour;
  • never mistreat or abuse their workers.

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:

(i) the Mitsubishi Electric Group Human Rights Policy, as implemented on 20 September 2017: 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:

  • The Mitsubishi Electric Group recognizes that, as a minimum, it must respect international standards related to human rights, such as the International Bill of Human Rights and the International Labour Organization's Declaration on Fundamental Principles and Rights at Work. On that basis, we shall respect human rights while making sure to adequately understand relevant laws and regulations in every country and region where we do business.
    If such laws and regulations do not conform to international standards related to human rights, we shall consult with local authorities on how to properly handle cases involving human rights in order to respect the international standards.
  • Based on the United Nations Guiding Principles on Business and Human Rights, the Mitsubishi Electric Group shall undertake human rights due diligence measures, such as specifying and assessing the impact of its business activities on human rights, and studying ways of proactively preventing or mitigating any negative impact of those activities. Furthermore, the Group shall put a framework in place for rectifying any cases in which its business activities are found to have negatively impacted human rights, or its members are found to have been clearly involved in violations of human rights.
  • The Mitsubishi Electric Group has identified CSR (Corporate Social Responsibility) materialities, has set concrete tasks and goals for those materialities, and works to achieve them, and, through that process, takes steps to ascertain the status of its initiatives related to respect for human rights, and properly discloses its findings.
  • The Mitsubishi Electric Group shall work to ensure that its initiatives related to respect for human rights are implemented with the participation of all executives and employees. Furthermore, the Group shall request cooperation from various stakeholders involved in its whole value chains such as business activities, products, and services, in order to help promote respect for human rights in society at large.
  • The Mitsubishi Electric Group shall implement training programs and awareness campaigns on a continuous basis for the purpose of ensuring that all executives and members of the Group understand initiatives related to respect for human rights, and conduct themselves accordingly.

(ii) 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.”

During the financial year ending 31 March 2019:

  • the Mitsubishi Electric Group assessed and evaluated the impact on human rights related to the Group’s corporate activities for a total of 336 sites, including Mitsubishi Electric group offices and affiliated companies both in Japan and internationally;
  • Mitsubishi Electric Corporation conducted human rights education for employees involved in CSR at offices of Mitsubishi Electric Corporation and at affiliated companies in Japan
  • Mitsubishi Electric Corporation checked the implementation of the Technical Intern Training Programme across the Mitsubishi Electric Group and that it is operating legally and in compliance to the Mitsubishi Electric Group Conduct Guidelines;
  • Mitsubishi Electric Corporation’s procurement divisions began ensuring that when dealing with transaction partners, agreements are reached with regard to social issues, including human rights; and
  • Mitsubishi Electric Group provided an e-learning programme to 71,588 employees of Mitsubishi Electric Corporation and its affiliated companies in Japan.

Mitsubishi Electric Corporation has a continuing programme for the evaluation of the CSR initiatives of “business partners” (i.e. third party suppliers). Mitsubishi Electric Corporation’s policy is to evaluate all new suppliers.

During the financial year ending 31 March 2019:

  • Mitsubishi Electric Corporation completed CSR evaluation surveys with over 1200 existing and new suppliers; 32 suppliers were given guidance to encourage their subcontractor suppliers to take up CSR compliance practices.
  • Across Mitsubishi Electric group affiliate companies in Japan and internationally, 360 supplier surveys were completed.
  • There were no suppliers whose business relationship with the Mitsubishi Electric Group was cancelled as result of a CSR evaluation survey during this financial year.

The Mitsubishi Electric Group launched its WΣ21II (Worldwide Strategic Integration for Global Markets in the 21st Century Advance to the Next Stage) activity in April 2017. This activity was continued throughout the financial year ending 31 March 2019. This includes initiatives to mitigate any perceived risks regarding a range of issues related to ensuring compliance to labour laws and regulations.

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.


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 2019 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:

Yoji Saito

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

Issue date: 25 September 2019