Code of Business Conduct

Komatsu is committed to maximizing its corporate value through pursuing “Quality and Reliability.” We at Komatsu believe our “Corporate Value” is the total sum of trust given to us by society and all stakeholders. To enhance this trust, we need to not only improve our business results and the soundness and transparency of management, but also become a company which enjoys an even higher level of trust from society. Therefore, it is becoming even more important for us to comply thoroughly with the rules of the business community (the “Rules”).

The Rules are not limited to laws and regulations applicable to our business activities. They also include those rules that are generally recognized and respected in society. Today, as companies’ role in the society grows more and more important, we should regard it as an essential part of the Rules that each constituent member of a company fully recognizes the notion of “Corporate Social Responsibilities” (CSR) and behaves in response to the trust of society.

From the wide-ranging Rules, we have picked up and embodied in this “KOMATSU’S WORLDWIDE CODE OF BUSINESS CONDUCT” (the “Code”) those basic principles and ways of thinking that should be observed and followed no matter where we are located in the world. Together with “The KOMATSU Way”, which conveys such values and strength as all members of Komatsu should inherit over generations, the “Code” constitutes an important set of guidelines as to how we can make Komatsu what it should be. The top management and employees of each Komatsu company around the world as a global corporate citizen must carefully read, understand and abide by the Code.

As I always state, all members of Komatsu are expected to make decisions regarding our business activities in accordance with the following principles, in the following order: Safety, Law, Quality, Delivery, and Cost.

Safety (and Health) and Law (Compliance) are given the highest priority over all other principles. You should find that in each workplace of Komatsu there are posters of the “MESSAGE CONCERNING OCCUPATIONAL SAFETY AND HEALTH” and “FIVE PRINCIPLES OF COMPLIANCE” on the office wall. The principles described therein are constant and unchanging.

The Code consists of two parts. Part I is to clearly establish Komatsu’s compliance policies and to declare that all of Komatsu’s executives and managers shall adhere to those policies. Part II contains the specific and concrete descriptions of actions that all members of Komatsu, including myself, must do or must not do to comply with the Rules. Obviously, this booklet has limited pages and it is not possible to cover all the Rules. Furthermore, details of the Rules may well differ from region to region or from country to country, even though the fundamental principles remain the same. Therefore, when handling particular matters, the executives and managers, as well as employees, of each Komatsu company are expected to reconfirm what exactly are the relevant Rules in light of Komatsu's basic stance and principles provided in the Code.

All members of Komatsu should strive to create and maintain a safe and comfortable work environment where all employees of Komatsu can do their jobs in good health, and comply with the Rules in order to make Komatsu be truly trusted.

 

Tetsuji Ohashi

President and CEO, Komatsu Ltd.
October 1, 2017