Mitsubishi Corporation

At the group level:

Mitsubishi has a group-level Environmental Charter, Social Charter, Human Rights Policy and Policy for Sustainable Supply Chain Management that commit 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. Mitsubishi carries out environmental and social surveys and audits for subsidiaries to ensure compliance with these group-level policies.

Furthermore, Mitsubishi works with consultants to identify products with higher environmental and social risks, including tuna and shrimp, and an annual environmental and social due diligence is carried out for the suppliers of these products through its Sustainable Supply Chain Survey. During the call with investors and FAIRR, Mitsubishi confirmed that this survey covers all Tier 1 suppliers and Tier 2 Japanese suppliers, and Mitsubishi is expanding the scope to cover overseas Tier 2 suppliers. Mitsubishi also explained that it rates any new suppliers for IUU risk when onboarding them, and if necessary, carries out audits.

Mitsubishi’s group-level disclosure has improved this year, by comparison to last year, as it now mentions issues specific to seafood supply chains in its 2023 Sustainability Report. The company recognises that, as a major player in the marine products business, it plays a crucial part in conserving marine resources and ensuring a sustainable supply for future generations. Mitsubishi also mentions that its subsidiary Cermaq has identified biodiversity protection as a key part of its licence to operate, and asks its suppliers to ensure no marine feed ingredients originate from IUU fishing. In its Bluefin Tuna Sustainable Sourcing policy, Mitsubishi states it “avoids” sourcing bluefin tuna that originates from IUU fishing or is produced in ways that contribute to the violation of human rights and/or labour rights.

Mitsubishi also has Tuna Procurement Guidelines, stating that Mitsubishi holds workshops for suppliers on IUU fishing and human rights, and participates in collaborative initiatives such as multi-stakeholders platforms on human rights issues. These Guidelines have also been adopted at the subsidiary level by Toyo Reizo Co.
Mitsubishi has also conducted an analysis of the nature dependencies and impacts for its salmon farming subsidiary, Cermaq as recommended by the Taskforce on Nature-related Financial Disclosures (TNFD). Cermaq was chosen as the analysis identified the fisheries business as having the most material dependencies on nature. During the call with investors and FAIRR, Mitsubishi suggested that it is considering expanding this disclosure to cover other subsidiaries in the future.

At the subsidiary level:

• Toyo Reizo Co. refers to the above group-level policies in its Sustainable Use and Procurement of Marine Resources policy and further states that, to avoid exposure to IUU fishing, it will establish interoperable traceability and collect the “main data elements” recommended by the GDST by 2023.

• Cermaq’s Code of Conduct – Feed Suppliers states that no fish meal or fish oil used in the feed will originate from IUU catch. Cermaq also states that fighting IUU fisheries through the monitoring of boats and conducting risk assessments of regions and ports is one of the topics addressed by SeaBOS, one of Cermaq’s partnerships. We encourage Mitsubishi to disclose more information regarding the risk assessment carried out for the products identified as having higher social and environmental risks, such as tuna and shrimp, and including how the company identifies and mitigates the risk of IUU, overfishing, habitat conversion and human rights issues for these products. We also recommend that Mitsubishi discloses a group-level Sustainable Procurement Policy for marine products.

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

At the group level:

Mitsubishi has a group-level commitment to procure bluefin tuna that is traceable from catch to import. This target was set to be achieved by 2017 and reported to have been met in the company’s latest 2021 policy.

Mitsubishi responded to the investor letter stating it is “working to establish an interoperable, full-chain, digital traceability for the marine product business at the Mitsubishi Group level.” However, this appears to be in early stages and no further information including timelines has been provided.

At the subsidiary level:

Mitsubishi’s seafood subsidiaries disclose partial commitments to traceable seafood in their public reporting.

• Toyo Reizo Co. refers to implementing an interoperable traceability system aligned with the GDST. However, it does not specify whether this covers all seafood and feed ingredients (marine and terrestrial). During the call with investors and FAIRR, Mitsubishi stated that from the fiscal year 2024, it is planning to launch a centralised management system for farmed tuna, the main product of its subsidiary Toyo Reizo Co, to ensure traceability of the product.
• Cermaq states that its French customers can trace the salmon purchased to a farm through a QR code and blockchain system. The company also requires its feed suppliers to have a traceability system in place that is able to trace feed ingredients back to the source, such as the fishery or the region grown. Cermaq’s commitment specifically mentions both marine and terrestrial feed ingredients.

During the call with investors and FAIRR, Mitsubishi highlighted that tuna and salmon farming, which are covered by traceability commitments at the subsidiary level, account for most of the company’s seafood business. However, Mitsubishi does not disclose, at present, the percentage of products that are traceable or a breakdown of its seafood business by species and subsidiary.

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

At the group level:

Mitsubishi’s group-level target to implement traceability systems for all bluefin tuna by 2017 is reported to have been met in the company’s 2021 Bluefin Tuna Sustainable Sourcing Policy. However, no further details are disclosed on whether the traceability systems in place are digital, interoperable and aligned with leading standards such as the GDST and the ASC Feed Standard. Further, the commitment does not appear to cover all seafood, stock inputs and feed ingredients (marine and terrestrial).

At the subsidiary level:

• Toyo Reizo Co. commits to interoperable traceability and aims to confirm the collection status of “major data elements” in accordance with the GDST standards by 2023. Mitsubishi responded to the investor letter stating that Toyo Reizo Co. has now completed its exercise to “organise and confirm the status of collection of key data elements by the end of 2023” in accordance with the GDST standards, but this is not disclosed publicly. Toyo Reizo Co. states this policy applies to Atlantic/Pacific bluefin tuna, southern bluefin tuna, bigeye tuna, yellowfin tuna, albacore, and bonito, but not to other species they procure or to feed ingredients. The company does not quantify how these species compare to other species procured by Mitsubishi, so it is unclear what percentage of the overall seafood business is covered by this policy. Furthermore, the company states it “will actively cooperate to obtain Global Sustainable Seafood Initiative (GSSI) certification for feed resources” but does not mention whether all feed ingredients will be traceable in line with the GDST and the ASC Feed Standard.

• Cermaq is a member of SeaBOS but has not disclosed any time-bound commitments to implement the GDST standards. The company states that its French customers can trace the salmon purchased to a farm through a QR code and blockchain system. As part of its Code of Conduct for Feed Suppliers, suppliers are asked to have an ingredient traceability system in place that is audited and certified by a third party, and for Cermaq to be able to audit the system upon request. For marine ingredients, this policy only asks for traceability to the source fishery, therefore is not full chain back to the vessel. Cermaq requires the suppliers' traceability systems to be electronic and for the relevant data to be available on a regular basis or upon specific requests, in the data format specified by Cermaq. This includes an exhaustive list of ingredients and their origins on an annual basis. However, this policy does not mention interoperability or the GDST/ASC Feed Standard. During the call with investors and FAIRR, Mitsubishi pointed out that Cermaq is committed to increasing the proportion of its products that are ASC-certified, but Mitsubishi was unsure about Cermaq’s ambition to align with the GDST standards.

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

Mitsubishi or its subsidiaries do not disclose information relating to a traceability implementation plan including key milestones.

We encourage Mitsubishi to utilise any learnings from its traceability efforts for tuna (reported to have been achieved in 2017) to inform its approach for its wider seafood subsidiaries including feed ingredients (marine and terrestrial).

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

At the group level:

Mitsubishi states to have already achieved traceability in certain parts of its seafood business. However, no further detail is provided including for example the extent of these commitments.

At the subsidiary level:

• In its response to the investor letter, Mitsubishi stated that Toyo Reizo Co. has now completed its exercise to “organise and confirm the status of collection of key data elements” in accordance with the GDST standard and would consider disclosing this publicly. However, during the call with investors and FAIRR, Mitsubishi stated that Toyo Reizo Co. has a traceability system in place, collecting information such as the name of the fishing vessel and the catching period, but this system does not cover all the KDEs as prescribed in the GDST standards. Mitsubishi said it would consider adapting this system to include all the GDST KDEs in the future, but the company did not provide any timeline for this.

• Cermaq states that it has some full-chain and digital traceability systems in place but only for French customers. While the Code of Conduct for Feed Suppliers requires its suppliers to have traceability systems in place, there is no requirement for traceability to be full-chain (to vessel/farm/food source) and interoperable, or to align with the leading standards such as the GDST and the ASC Feed Standard. Cermaq discloses traceability information including the species and origin of marine resources used in its feed in its Sustainability Report. While the disclosure covers 100% of marine ingredients, it 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 universal list of KDEs.

Mitsubishi and its subsidiaries currently report some details on their operational traceability systems, but we encourage them to report annually on the scope, the depth and the breadth of the data collected by the various systems. Ideally, this data would be reported at the group level.

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

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 beyond industry certifications such as ASC and BAP.

Apart from this, Mitsubishi and its other subsidiaries do not disclose any third-party verification for its operational traceability systems, nor do they report on cases of non-compliance.

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