Our business partners, who supply materials, parts, components and other items, are important partners that support Komatsu’s manufacturing activities. Based on relationships of mutual trust, Komatsu aims to build Win-Win relationships with its business partners through mutual efforts. As our business activities expand globally, our supply chain has also extended worldwide. Taking seriously the growing social expectations for promoting CSR throughout the entire supply chain, we are working to achieve global CSR procurement by proactively supporting the CSR initiatives of our business partners.
Komatsu's procurement policy is based on the philosophy of aiming to build a Win-Win relationship with our business partners, who are on an equal footing with us, and encouraging each other. The policy aims to evaluate and select suppliers in a fair and equitable manner from a SLQDC (Occupational health & Safety, Compliance with the Law, Quality, Production capacity & delivery and Cost competitiveness) and ESG perspective.
As evaluation criteria for selecting suppliers and reviewing ongoing transactions with them, the General Manager of Komatsu’s Procurement Division has established the CSR Procurement Guidelines and Green Procurement Guidelines based on the basic policy approved by the Sustainability Promotion Committee, and Komatsu publishes these guidelines on its website. Komatsu also communicates these guidelines to its business partners and requests that they act in accordance with the intent of the guidelines in their business activities. In addition, Komatsu’s basic transaction agreements clearly stipulate, as contractual compliance obligations, compliance with Komatsu’s Human Rights Policy, CSR Procurement Guidelines, and Green Procurement Guidelines. Komatsu also provides support and guidance necessary for compliance with both guidelines. Examples of such support and guidance include the following:
To promote CSR activities throughout the supply chain, Komatsu established and published the “CSR Procurement Guidelines” in 2011. These guidelines summarize the matters that Komatsu requests its business partners to address, in line with international guidance such as ISO 26000 and the Ten Principles of the United Nations Global Compact, while also incorporating Komatsu’s Worldwide Code of Business Conduct and the concept of the Komatsu Way. The guidelines cover a broad range of ESG-related issues, including corporate governance, compliance, the environment, human rights and labor, information security measures, corporate ethics, social contribution, and coexistence with local communities. Efforts to comply with these guidelines are also incorporated into transaction agreements with business partners. If a clear violation of, or situation of non-compliance with, these guidelines is identified at a business partner and appropriate corrective measures are not taken within the designated timeframe, Komatsu may suspend or terminate transactions with that business partner.
In accordance with the Komatsu's Worldwide Code of Business Conduct (established in 1988), all companies of the Komatsu Group have worked together in pursuit of thorough compliance. Moreover, Komatsu has focused on corporate social responsibility (CSR) in its business management with the aim of coexisting with society and achieving sustainable growth. As part of this effort, Komatsu has participated in the Global Compact, a voluntary principle of action in relation to “human rights, labor, environment and prevention of corruption” advocated by the United Nations, since November 2008 and has also expressed its position as a global enterprise on critical issues confronting international society faces.
Against this backdrop, ISO26000 was officially issued in November 2010 to provide international guidance on social responsibility. Komatsu sincerely reacts to the issues set forth in ISO26000 and will exercise leadership so that social responsibility will be borne throughout the entire value chain.
According to the Komatsu's Worldwide Code of Business Conduct, we shall “seek to establish long-lasting stable relationships on the basis of mutual trust” by considering business partners to be important partners of the Komatsu Group. The revision in April 2011 added statements that we shall encourage business partners to follow the spirit of Komatsu's Worldwide Code of Business Conduct and that the criteria for the selection of business partners shall include their compliance with rules of business society.
The CSR Procurement Guidelines contain a list of practices recommended for our business partners in line with the basic policy above, covering compliance and CSR. Since its establishment in 2011, we have revised it to address new issues that meet the social needs. Companies of the Komatsu Group are kindly requested to take note of and incorporate the guidelines into their management principles and unfailingly promote CSR. Moreover, we hope that these companies make similar requests to their suppliers.
April 1, 2025
Daisuke Ban, President of Komatsu Procurement Division
(Established on August 30, 2011; revised on April 1, 2019; revised on April 1, 2021; revised on April 1, 2024; revised on July 1, 2026)
(1) Build a system or operational structure designed to meet various risks.
(2) Establish legal and transparent decision-making processes concerning management.
(3) Conduct appropriate accounting procedures, tax filing and settlement of accounts.
(4) Place importance on communication with stakeholders (customers, shareholders, business partners, employees, community etc.).
(5) Ensure that top management will be notified promptly when any abnormal condition develops and that your company will be able to promptly and accurately respond to the situation(s).
(6) Fulfill accountability to society through active disclosure of corporate information.
(7) Properly handle the personal information of customers, business partners and employees. Take appropriate measures for information security to ensure that the confidential business information provided by Komatsu or by business partners will not be leaked, lost or destroyed.
(8) Create an effective BCP so that, even in the event of large-scale natural disaster, infectious disease pandemic or any other emergency, we can appropriately take initial measures to ensure the safety of employees, quickly restore business operations and fulfill our responsibility to supply customers with products.
(1) Engage in business operations while complying with the laws and regulations, as well as the rules of the business community in the countries and regions where we conduct business operations. In addition, make efforts to respect internationally accepted standards.
(2) Define a code of conduct, comprising company rules, under the leadership of senior management, and develop a corporate climate that places top priority on compliance.
(3) Establish a compliance regime, in accordance with the scale and characteristics of the company, that prevents the company, executives, and employees from engaging in illegal conduct, and promptly addresses situations where issues have occurred (e.g. a whistle-blowing system).
(4) Prohibit all forms of corrupt conduct, including fraud, extortion, collusion, money laundering, misleading representation, and false reporting.
(1) Comply with the laws and regulations concerning product safety and deliver products and services which will offer safety and peace of mind to customers.
(2) In addition to maintaining the quality and cost competitiveness of products and services which your company delivers to customers, stand by the agreed upon date of delivery and supply your products in a stable manner.
(3) Establish a quality management system and make efforts to maintain and improve it.
(4) Constantly engage in technology development and provide innovative, safe and environmental-friendly products and services.
(1) Continue efforts to reduce environmental impact resulting from business operations.
(2) Appropriately manage chemical substances contained in products.
(3) Build up environmental management systems such as the ISO14000 series and "Eco Stage."
(4) Pollutant air and water, other wastes, noise, vibration, etc. that affect the health and living environment of community, must be appropriately managed and disposed of in accordance with relevant laws and regulations.
(1) Respect human rights including the rights to freedom of association and collective bargaining.
(2) Never get involved, directly or indirectly, in any child or forced labor.
(3) Create a work environment where there is no discrimination or harassment in any aspect of employment.
(4) Respect the rights of workers, through payment of fair wages and proper working hours management.
(5) Establish a system for occupational labor health and safety, under the leadership of top management, and create a working environment where all employees can work safely and healthily.
(6) Establish fair and equitable human resource system, and pay attention to human resource development and employee education as well.
(7) Give consideration to improving communication between top management and employees.
(8) Prevent using raw materials (such as conflict minerals, deforestation, etc.) that may cause social issues by combining environment and human rights.
(1) Comply with all related laws and regulations and engage in free and fair competition and business transactions.
(2) Respect intellectual properties of other parties and work to prevent infringement thereof.
(3) Never offer, provide, or accept bribes, facilitation payments, excessive entertainment or gifts, or any other inappropriate money, goods, or benefits to or from public officials or stakeholders, including customers, transaction partners, and other business partners, either domestically or internationally.
(4) Carry out proper foreign trade transactions (goods and technologies) while complying with the related laws and regulations.
(5) Never have any relationship with antisocial forces or groups.
(6) Never engage in any transactions that may result in a conflict of interest or that may have the potential.
(1) Engage in social contribution activities based on your company's management principle(s) and support employees' volunteer activities.
(2) Place importance on co-existence with local communities which is the foundation of your business, and proactively support the growth of local communities.
(1) Encourage the company’s own business partners to comply with the items stipulated in these guidelines, and make efforts to ensure that the guidelines are disseminated throughout the entire supply chain.
(2) Understand the purpose of these guidelines, and communicate and disseminate them to the company’s officers and employees, affiliated companies, contractors, and secondary and subsequent suppliers.
(3) If Komatsu determines it necessary, actively cooperate with self-inspections, surveys, submission of materials, interviews, and other activities related to the status of compliance with these guidelines.
(4) If any fact that violates these guidelines, or any risk thereof, is identified, promptly report it to Komatsu, investigate the cause, and implement corrective measures and measures to prevent recurrence.
(5) If a serious violation is identified, or if corrective measures are not taken within a reasonable period, Komatsu may review the transaction.
The Green Procurement Guidelines are a supplementary addition to the environment-related issues included in the CSR Procurement Guidelines. In 1992, Komatsu established the "Komatsu Earth and Environment Policy," declaring its commitment to environmentally conscious business activities to achieve a sustainable society.
Through these guidelines, we prioritize green procurement of raw materials and procured components/parts, which are essential elements in our production. We also encourage our business partners to engage in environmental management and activities to reduce environmental impact.
In relation to these guidelines, we have also conducted the following surveys in our supply chain.
From a CSR perspective, Komatsu has established a policy of not using “conflict minerals,” such as tin, tantalum, tungsten and gold (3TG), originating from the Democratic Republic of the Congo and its adjoining countries. Komatsu communicates this policy to its business partners through its Green Procurement Guidelines.
From 2011 to 2014, Komatsu conducted surveys using the Japan Auto Parts Industries Association (JAPIA) survey template, known as the JAPIA Sheet, for each part supplied by its business partners. The surveys examined the quantities of the relevant minerals contained in each part and their countries of origin, including the identification of upstream smelters/refiners.
As a result, Komatsu determined that the quantities of the relevant minerals used in its products were negligible and that there had been no use of “conflict minerals” in its products. Since then, under the direction of the Head of the Procurement Division, the Procurement Planning Department has continued to follow up on this matter by including relevant questions in CSR-related SAQ surveys, human rights due diligence surveys and other surveys. Komatsu has also expanded the scope of matters that can be reported or raised for consultation through Komatsu’s whistleblowing system for suppliers to include matters concerning conflict minerals.
Going forward, if Komatsu or any of its business partners is found to be using “conflict minerals,” Komatsu will promptly take steps to ensure that sourcing is switched to RMI-certified smelters/refiners.
Procedures for identifying and responding to risks related to the use of conflict minerals
The REACH Regulation governs the registration, evaluation, authorization and restriction of chemicals in the EU. Companies that manufacture substances subject to the Regulation within the EU or export finished products containing such substances to the EU are required to comply with the Regulation, including by registering the substances and applying for authorization where the annual volumes used exceed prescribed thresholds.
The substances subject to the Regulation are continually expanded, with additional Substances of Very High Concern (SVHCs) contained in products being designated each year.
As with its response to conflict minerals, Komatsu uses JAPIA Sheets to survey, on a part-by-part basis, the quantities of regulated substances contained in parts supplied by its business partners and reports the results to the relevant EU authorities. In collaboration with its business partners, Komatsu is also working to reduce the use of SVHCs and replace them with alternative substances whose safety has been confirmed.
The Declaration of Partnership Building is a voluntary code of conduct under which large companies, as parent enterprises, declare that they will collaborate and cooperate with small and medium-sized enterprises (SMEs) through fair transactions, with the aim of enhancing added value across the entire supply chain and achieving coexistence and co-prosperity between large companies and SMEs.
In support of this initiative promoted by the Cabinet Office, the Small and Medium Enterprise Agency, and various economic organizations, Komatsu announced its own declaration in August 2020. Since then, Komatsu has revised the declaration by adding items such as the basic principles for transactions involving molds and dies and efforts to disseminate the content of the declaration throughout the entire supply chain.
Komatsu complies with the provisions set forth in the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors and in the Promotion Standards under the Act on the Promotion of Subcontracting Small and Medium-sized Enterprises. Komatsu will also continue to support the strengthening of its business partners’ business foundations by helping them enhance productivity and improve operational efficiency through the use of ICT, as well as by providing various training and education programs.
In July 2022, the basic principles (Article 3) of the Act on the Promotion of Subcontracting Small and Medium-sized Enterprises were revised. In response, Komatsu issued a letter to all domestic Tier-1 suppliers, including sub-materials suppliers, encouraging them to reflect fluctuating raw material, energy, and labor costs in product prices. We are actively promoting the optimization of purchasing prices. In 2024, we also held price negotiations with 1,207 suppliers and actively implemented necessary price revisions. Since 2025, we have continued to hold price negotiations with our suppliers at least once a year.
In January 2023, we launched the "Supplier Portal (KOMATSU Global portal)," a website for sharing information with our business partners. This site allows both our employees and business partners to share daily order and production data, and utilize tools that facilitate data processing and analysis. By using this portal, it is possible to detect fluctuations in production and orders, and anticipate the demand for intermittent production parts. Additionally, it enables the monitoring of management indicators such as delivery date achievement rates and defect rates. As of May 2026, approximately 1,100 companies are using the portal. Going forward, we will continue to enhance its functionality and expand its content as we work to strengthen information sharing.
The “Declaration of Partnership Building” is also available on the website below.