The Compliance Program The Compliance Management Department of the Mitsui Legal Division leads compliance efforts on a global basis under the direction and supervision of the Chief Compliance Offi cer (a member of the Board of Directors who is responsible for compliance) and with the support of the Compliance Offi cers appointed in each business unit in Mitsui’s Head Offi ce and the Regional Chief Compliance Offi cers of our three overseas business units—the Americas; Europe, the Middle East and Africa (EMEA); and Asia Pacifi c.