Mitsubishi Corporation

Group level:

Mitsubishi disclosed a group-level Environmental Charter, Social Charter, Human Rights Policy and Policy for Sustainable Supply Chain Management that commits the company and its suppliers to the sustainable use of natural resources, the protection of ecosystems and the respect of human rights and fundamental labour rights. Furthermore, the company highlighted the risk associated with Illegal, Unregulated, and Unreported (IUU) and human rights in its Tuna Procurement Guidelines, and its Bluefin Tuna Sustainable Sourcing Policy. Within these disclosures, the company also noted the risk of the depletion of natural resources and the need to conserve the environment, as well as the role of traceability in avoiding IUU fishing. The company also explicitly noted that enhancing supply chain traceability can help with identifying material risks within its Seafood Procurement Guidelines, including reference to alignment with the GDST standard. Mitsubishi has also formulated traceability guidelines for soy and palm oil.

The company details its application of the TNFD assessment framework when considering biodiversity risks, stating that it conducted a trial analysis based on the beta version (V0.1-0.4) and the final recommendations (V1.0) of the TNFD framework from FY2022 to FY2023. In the future, the company will utilise the knowledge obtained through this analysis in the management of individual businesses and continue to analyse and respond to nature-related issues while incorporating the latest frameworks and analysis methods, including the final recommendations of the TNFD, with the aim of further improving Mitsubishi Group's sustainability and corporate value. As the analysis identified the aquaculture business as having the most material dependencies on nature, Cermaq (100% seafood subsidiary) was selected as appropriate to use for analysis, which was conducted in accordance with the TNFD’s Locate, Evaluate, Assess, and Prepare (LEAP) approach. The company states that this trial analysis using Cermaq deepened its understanding of the TNFD framework, and provided insight into the dependencies, impacts, and nature-related risks and opportunities associated with its business operations (including aquaculture). While the company discloses that it intends to continue to identify and respond to nature-related issues using the TNFD framework in the future, there is limited evidence that the company will disclose this information in new TNFD reporting at the group level.

For suppliers, Mitsubishi highlights its Policy for Sustainable Supply Chain Management on supplier contracts and conducts human rights and environmental due diligence through the Sustainable Supply Chain Survey. However, only “products” identified by the company as “products with high environmental and social risks” (18 products, including tuna and shrimp) are subject to this annual survey. In 2024, the survey covered 870 suppliers, including 170 for tuna and shrimp. In addition to this, the company also highlights a grievance mechanism, enabling the company to receive consultations from external stakeholders regarding actual or potential adverse impacts on human rights and the environment caused by our business activities. During the call with investors in Phase 2 of this engagement, Mitsubishi indicated that its Sustainable Supply Chain survey focuses on tier one suppliers, but for certain products (such as shrimp and tuna) tier two suppliers are also included.

Subsidiary level:

Cermaq:

Cermaq publicly acknowledges the materiality of Illegal, Unreported, and Unregulated (IUU) fishing, overfishing (referred to as sustainable sourcing that promotes long-term health of fish populations), habitat conversion and human rights issues in its 2023 Sustainability Report, identifying these risks through its first double materiality assessment in preparation for Corporate Sustainability Reporting Directive (CSRD).

Furthermore, Cermaq clearly links traceability with certifications as a means of addressing material risks within its supply chain. The company communicates the importance of IUU fishing, overfishing, habitat conversion, and human rights issues in its Code of Conduct for feed suppliers (this addresses both marine and terrestrial sources). The company also highlights its requirements relating to traceability and sourcing – suppliers are expected to disclose the type of raw material and country of origin. Specifically, the company outlines additional requirements for sourcing fishmeal and fish oil, which included “Non IUU catch”, sourced from “either certified fisheries or fisheries that are undertaking a FIP1 process overseen by the Marine Trust”, “Fishmeal and fish oil sourced from certified fisheries under a scheme that is ISEAL member (e.g., Marine Stewardship Council) or IFFO Responsible Supply of Fishmeal and Fish Oil programs shall be at least the minimum requirement for certification of ASC and BAP”, and “Products that meet with the FishSource score acceptable levels for each species used as feed ingredient as required by the ASC standard”.

Toyo Reizo:

Toyo Reizo acknowledges the materiality of Illegal, Unreported, and Unregulated (IUU) fishing, overfishing, habitat conversion and human rights issues in its tuna supply chains. Furthermore, the company outlines its considerations of these risks in the Tuna Procurement Policy (adapted from Mitsubishi's “Tuna Procurement Policy” at the group level), where it details measures to address issues such as international overfishing, IUU fishing, and human rights violations. The company also has guidelines to establish interoperable traceability and prepare key data elements recommended by the GDST in order to avoid handling tuna caught through IUU fishing, as defined by the Food and Agriculture Organization of the United Nations.

In its Environment Report 2023, the company highlights traceability from the perspective of conserving fishery resources, adding that it is working to comply with requirements of the tuna Catch Documentation Scheme (CDS) for export markets and to ensure traceability of the catch.

All sources of information are available in the company assessment PDF.

Group level:

Three documents are relevant to assessing Mitsubishi’s approach to traceability:

• The Seafood Procurement Policy (new as of July 2025)
• The Tuna Procurement Guidelines (updated as of July 2025)
• The Bluefin Tuna Sustainable Sourcing Policy (created in 2017, last updated in 2021)

Seafood Procurement Policy (new as of July 2025): In July 2025, Mitsubishi released its Seafood Procurement Policy, which highlights a clear commitment to traceability across its seafood operations: “To contribute to the elimination of overfishing and IUU fishing, the conservation of marine habitats, and the respect for human rights and labour rights, MC aims to ensure transparent traceability in seafood trade in accordance with the internationally recognized Global Dialogue on Seafood Traceability (GDST) standards.

Tuna Procurement Guidelines (updated as of July 2025): In July 2025, the company also updated its Tuna Procurement Guidelines to include a commitment to “ensure transparent traceability in seafood transactions by applying the Key Data Elements (KDEs) recommended by the Global Dialogue on Seafood Traceability (GDST), an international standard, in order to mitigate procurement risks of tuna species linked to IUU fishing”.

Bluefin Tuna Sustainable Sourcing Policy (created in 2017, updated in 2021, last updated in 2021): The company discloses on the progress of its “2017 Action Plan for Bluefin Tuna Sustainable Sourcing” in its Bluefin Tuna Sustainable Sourcing Policy. Here, the company highlights its aim to create and implement a transparent traceability system to avoid IUU sourcing for all procured bluefin tuna by the end of fiscal year 2017. In a 2021 update, the company indicated that has developed a system that enables the tracking of traceability information from catch to import for all of the bluefin tuna it handles, and that 100% of the bluefin tuna procured by the MC Group “can be managed via this system”.

Whilst the two new policy updates are positive (Mitsubishi’s new Seafood Procurement Policy and updated Tuna Procurement Guidelines), it is unclear whether these traceability commitments cover feed ingredients, or other seafood ingredients/products beyond reference to “seafood trade” within its Seafood Procurement Policy. There is also no information regarding the implementation plan of this Seafood Procurement Policy or Tuna Procurement Guidelines.

Regarding certifications, the company disclosed a commitment to “expand our handling of certified seafood”, specifically certification programmes approved by the Global Sustainable Seafood Initiative (GSSI). Furthermore, within its Tuna Procurement Guidelines, the company outlines a target to achieve 30% GSSI-recognised certification for all tuna species that the company sources. The company also makes reference to the ASC and MSC certifications in its Sustainability Report 2024 and Bluefin Tuna Sustainable Sourcing Policy - though this does not provide information on the coverage of its business tied to a certification specifically, nor does it indicate whether Mitsubishi has a Chain of Custody certification (i.e. identified with the presence of eco-labels).

Subsidiary level:

Cermaq: Cermaq has a commitment to traceability that covers its entire feed ingredient supply chain in its Supplier Code of Conduct, and details some coverage of seafood for “marine ingredients traceable back to fishery source”, though an exhaustive list of traceable feed ingredients is not disclosed (Cermaq does request this information from its suppliers on an annual basis). Furthermore, the company underlined its partnership with SeaBOS and its engagement with partners to “improve the situation for marine resources” through “digital standards for seafood traceability”.

Regarding feed, the company committed to ensuring that all feed ingredients are traceable, including marine ingredients (traceable back to the source fishery), soy (traceable back to the region grown), pigments, vitamins, and minerals (traceable back to the producer). Cermaq added that these traceability systems must be electronic, audited by a third party, and provide relevant data to Cermaq regularly or upon request. Suppliers must also disclose ingredient origins annually and be able to trace feed shipments from manufacture to delivery to Cermaq.

Toyo Reizo: Toyo Reizo addressed traceability in two policy documents. In its Supplier Policy, the company stated that “each supplier shall ensure traceability and provide [Toyo Reizo] with key data elements for traceability as necessary”. In its Tuna Procurement Guidelines, the company stated that it will “establish interoperable traceability and prepare key data elements recommended by the GDST in order to avoid handling tuna caught through IUU fishing”.

The company has also obtained Chain of Custody certifications, listing alignment with the Marine Stewardship Council (MSC), ASC, and Marine Eco-Label (MEL). There is limited evidence of coverage of traceability in feed supply chains beyond certifications. The company also shared a graphic of its traceability system, though this was in relation to food safety.

All sources of information are available in the company assessment PDF.

Group level:

In July 2025, Mitsubishi released its Seafood Procurement Policy, which highlights a clear commitment to traceability across its seafood operations: “To contribute to the elimination of overfishing and IUU fishing, the conservation of marine habitats, and the respect for human rights and labor rights, MC aims to ensure transparent traceability in seafood trade in accordance with the internationally recognized Global Dialogue on Seafood Traceability (GDST) standards".

In July 2025, the company also updated its Tuna Procurement Guidelines to include a commitment to “ensure transparent traceability in seafood transactions by applying the Key Data Elements (KDEs) recommended by the Global Dialogue on Seafood Traceability (GDST), an international standard, in order to mitigate procurement risks of tuna species linked to IUU fishing”.

The traceability commitment contained in the Seafood Procurement Policy:

• Scope: appears to apply to all seafood (qualified as “seafood trade”). However, it is not specified whether this is applicable to feed ingredients (marine or terrestrial).
• Depth: does not explicitly state that seafood can be traced back to the vessel/farm/feed source.
• Breadth: is explicitly aligned with the GDST.
• Form: not time-bound, nor digital, nor interoperable.

The traceability commitment contained in the Tuna Procurement Guidelines:

• Scope: applies to all wild-caught or farmed tuna. However, it is not clear whether this also applies to feed ingredients.
• Depth: does not explicitly state that seafood can be traced back to the vessel/farm/feed source.
• Breadth: is explicitly aligned with the GDST and requires Key Data Elements (KDEs) to be collected in line with the GDST for both wild-caught and farmed tuna.
• Form: not time-bound, nor digital, nor interoperable.

The traceability commitment contained in the Bluefin Tuna Sustainable Sourcing Policy (last updated in 2021):

• Scope: applies to all wild-caught or farmed bluefin tuna. However, it is not clear whether this also applies to feed ingredients.
• Depth: explicitly states that bluefin tuna can be traced from “catch to import”.
• Breadth: is not explicitly aligned with the GDST.
• Form: time-bound, but not digital nor interoperable.

With regards to certifications, the company aims to increase the amount of certified seafood, when the certification is recognised by the GSSI. In addition, Mitsubishi has a quantified target only for tuna i.e. at least 30% of tuna sold by 2030 will be certified by a certification recognised by the GSSI.

There is no clear link between the company’s seafood traceability commitment and terrestrial feed ingredients, though the company has Soybean Procurement Guidelines (deforestation-free sourcing, with a mention of 100% traceability to farm within its Agrex do Brazil operations) and Palm Oil Procurement Guidelines (focused on RSPO certification).

Subsidiary level:

Cermaq: Cermaq’s traceability commitment is included in its Code of Conduct for Feed Suppliers:

• Scope: applies to all marine and terrestrial feed ingredients.
• Depth: explicitly states that the terrestrial and marine ingredients must be traced back to their source (back to the source fishery for marine ingredients, and region grown for soy.
• Breadth: is not aligned with the GDST. Though Cermaq is a SeaBOS member, its traceability commitment does not appear to be in line with the GDST data standard.
• Form: not time-bound nor interoperable. However, traceability systems “shall be electronic”.

Toyo Reizo: Toyo Reizo addresses traceability in two policy documents. In its Supplier Policy, the company states that “each supplier shall ensure traceability and provide [Toyo Reizo] with key data elements for traceability as necessary”. In its Tuna Procurement Guidelines, the company states that it will “establish interoperable traceability and prepare key data elements recommended by the GDST in order to avoid handling tuna caught through IUU fishing”.

• Scope: applies to all tuna handled by the company. However, Toyo Reizo also trades other products, such as tuna, salmon, shrimp and scallops.
• Depth: does not specify whether tuna should be traced back to the source fishery, or whether feed ingredients should be traceable in the case of farmed tuna.
• Breadth: is explicitly aligned with the GDST.
• Form: not time-bound, nor digital nor interoperable.

The company also states that it has obtained CoC (Chain of Custody) certification such as MSC and ASC.

All sources of information are available in the company assessment PDF.

Group level:

At the group level, neither the Tuna Procurement Guidelines nor the new Seafood Procurement Guidelines have clear milestones or strategy associated with the traceability commitments they contain. The only implementation measures at the group level refer to Mitsubishi’s commitment to traceable bluefin tuna.

Mitsubishi discloses a time-bound target for its traceability commitment relating to bluefin tuna in 2017, which it reports to have achieved in the latest update (2021). Furthermore, the company states that it holds workshops on IUU fishing and human rights to share risks and challenges with suppliers, and collaborate to consider and implement improvement measures as well as actively participate in initiatives such as multi-stakeholders platforms on human rights issues for workers in the seafood community - however, there is no explicit mention of traceability. Lastly, the company also shares that it undertook an exercise to develop Best Management Practices (BMPs) for bluefin tuna, though this was inconclusive due to a “lack of consensus”.

Regarding certifications, in its updated Tuna Procurement Guidelines, Mitsubishi indicates a time-bound commitment to GSSI-certified tuna – the company continues engagement in dialogues with relevant stakeholders ASC certification development, and endorsing and supporting efforts for the Southern bluefin tuna purse seine fishery, to obtain MSC certification.

Subsidiary level:

Cermaq: Cermaq requires its feed suppliers to have audited, electronic traceability systems and provides some traceability for salmon in selected markets (e.g. France). However, Cermaq has not published a comprehensive implementation plan with milestones for achieving traceability across all seafood or marine ingredients, nor does it specify plans to achieve alignment with leading standards like GDST or ASC.

Cermaq discloses that multiple sites are certified to ASC standard and it is working on expanding this, as well as indicating that it was a founding member of SeaBOS, but the company has not disclosed any time-bound commitments to implement the GDST, or other interoperable, traceability standards.

Toyo Reizo: Toyo Reizo does not disclose a clear implementation plan for traceability, though it details a time-bound milestone to organise and confirm the status of collection of key data elements in accordance with GDST standards by the end of 2023. While the company highlights its environmental management system, it does not explicitly link this with traceability.

All sources of information are available in the company assessment PDF.

Group level:

While Mitsubishi states that all bluefin tuna procured is traceable from catch to import in 2021, the company does not disclose any further information that would enable an assessment of the overall scope, depth, breadth and form of its operational traceability systems overall. In July 2025, the company outlined its actions and future direction in its “Tuna Procurement Guidelines”. The company discloses a target for 30% of the tuna it procures to have GSSI-recognised certification – adding that it has progressed from an initial 1% certification recognised by GSSI in 2022 to 20% in 2024. This change is attributed to an increased procurement from MEL-certified purse seine fleets. The company also indicates it will “actively support” suppliers that implement FIPs, as well as conduct third-party audits of its tuna supplier to identify risks in the supply chain. Lastly, the company highlights workshops on IUU fishing and human rights, its participation in multi-stakeholder platforms on human rights issues for workers in the “seafood community”, and cooperation with suppliers to create an environment of “decent work” as actions towards reducing social risks in its tuna supply chain.

Prior to this updated policy, the company disclosed in its Bluefin Tuna Sustainable Sourcing Policy results from its 2017 action plan, which aimed to implement a transparent traceability system to avoid IUU sourcing for all procured bluefin tuna by the end of the fiscal year 2017. In the 2021 update to this policy, the company shares that MC Group had developed a transparent system that enables the tracking of traceability information from catch to import for all of the bluefin tuna it handles - sharing that 100% of the bluefin tuna procured by the MC Group can be managed via this system. Additionally, the company discloses that it engages in dialogues with relevant suppliers to confirm the avoidance of IUU practices directly.

Subsidiary level:

Cermaq: Cermaq provides detailed information on its commitment to feed traceability, indicating in its Feed Suppliers Code of Conduct that it requires suppliers to have electronic, auditable traceability systems for all feed ingredients (marine ingredients traceable to source fishery, soy to region, pigments, vitamins, and minerals to producer).

Furthermore, the company states that it has product traceability guaranteed from its origin to the consumer due to a robust control system that uses unique codes corresponding to batch numbers. Suppliers are also requested to have certifications in place if a feed standard is available, such as the ASC Feed Standard. Cermaq highlights traceability for some salmon products (France) where blockchain is used to provide farm-to-shelf traceability for consumers. However, disclosure does not cover terrestrial ingredients and does not provide full-chain traceability information to vessel/farm/feed source. There is no mention of what other data is collected and whether this aligns with the GDST’s universal list of KDEs. There is limited evidence to suggest progress is reported annually for Cermaq’s traceability commitment.

Toyo Reizo: Toyo Reizo discloses that it “built a system for each product that connects product information from raw materials to the finished product”. Furthermore, the company requests that its suppliers ensure traceability and provide key data elements for traceability as necessary. There is limited evidence to suggest progress is reported annually for this traceability commitment, as well as limited evidence of coverage of traceability in feed supply chains.

All sources of information are available in the company assessment PDF.

Group level:

Mitsubishi does not provide evidence that its traceability systems are audited by a third party. However, the company indicates in its 2025 update to its Tuna Procurement Guidelines that it has developed a proprietary risk assessment tool referencing the Social Responsibility Assessment (SRA) Tool for the Seafood Sector and relevant domestic and international regulations. Using this assessment tool, third-party audits were conducted – one in FY2022, one in FY2023, and three in FY2024. It is unclear if such audits include traceability, instead focusing only on the social perspective.

The company indicates that it has conducted a survey on environmental and social initiatives with all primary tuna suppliers and some secondary suppliers (fishing vessels), though there was no mention of third-party audits when conducting such surveys.

While the company discloses a target for GSSI certification for its bluefin tuna (to increase its total procurement of GSSI-certified tuna to at least 30% by 2030), the company does not link this to a specific third-party certification (e.g. MSC or ASC), nor does it discuss the auditing process associated with acquiring such certifications.

Furthermore, in its Seafood Procurement Guidelines, Mitsubishi indicates measures in place to address “concerns” within its supply chain. These specifically relate to human rights and environmental due diligence - though traceability is not mentioned. Beyond this, cases of non-compliance are not reported.

Subsidiary level:

Cermaq: Cermaq asks suppliers to have an ingredient traceability system in place that has been audited and certified by a third party, and for Cermaq to be able to audit the system upon request. Cermaq does not disclose more detail about these audits and does not appear to have its own operational traceability systems audited or certified by a third party. The company’s Code of Conduct for Feed Suppliers (which contains the traceability requirement) explains that if a supplier is not compliant with requirements included in this Code, Cermaq may work with such suppliers to obtain improvement, or may choose to terminate its agreement with suppliers “in case of severe and systemic breach” of this Code.

Toyo Reizo: Toyo Reizo obtained MSC and ASC Chain of Custody (CofC) certification in 2016, and Marine Eco-Label Japan CoC in November 2024 - these certifications require a third-party audit. The company conducts external audits of its tuna suppliers, aiming to make this process a regular occurrence by 2025 - however, this does not explicitly reference traceability. There is also no explicit mention of non-compliance in disclosures linked with traceability.