1. Scope of application
   This policy applies to all business activities and all employees of the Group worldwide.
   Furthermore, our suppliers, distributors, and other business partners are also expected and encouraged to comply with the policy and to implement initiatives in place to respect human rights in their own operations.
2. Respect for human rights
   Our purpose is “Creating value through manufacturing and technology innovation to empower a sustainable future where people, businesses and our planet thrive together.” The sustainability policy based on this purpose advocates the realization of a sustainable society and growth of business, and clearly declares that as Komatsu Group, we shall respect human rights related to all of our business activities.
   We believe that it is essential to ensure that respect for human rights is firmly embedded within our company and therefore applies the human rights policy to Komatsu’s worldwide operations to conduct its business. This policy is formulated based on international human rights principles encompassed by the Universal Declaration of Human Rights. In addition to promoting business activities in line with this philosophy, we promote activities that respect human rights in accordance with the “International Bill of Human Rights,” the “United Nations (UN) Guiding Principles on Business and Human Rights,” the “OECD Guidelines for Multinational Enterprises on Responsible Business Conduct,” and the “ILO Core Labour Standards”. Komatsu Group will comply with the laws and regulations of all countries where it conducts its business activities. Where established international human rights norm exists as well as national laws, we will follow the higher standard; where they are in conflict and will seek ways to respect internationally recognized human rights to the greatest extent possible. When utilizing digital technologies, AI, and other tools, we also give consideration to respect human rights, including privacy and personal information protection.
   • Health safety
     We will, first of all, strive to “ensure a safe and comfortable work environment” and “maintain and promote employees’ health”, aiming to create a bright and vibrant work environment ensuring mental and physical health.
   • Prohibition of discrimination and harassment
     We shall respect diversity and treat and appraise each and every employee in a fair and impartial manner. We shall not discriminate against any employee on the basis of race, ethnicity, color, sex, sexual orientation, gender identity, age, religion, national ancestry, disability, marital status or other legally protected status. We shall vigorously promote equal opportunities for employment. We shall not tolerate inappropriate behavior and speech which prevents employees from working effectively and comfortably, or any type of harassment including harassment towards subordinate personnel, sexual harassment, or harassment related to pregnancy, childbirth, parenting, or nursing care, in and outside of workplace.
   • Prohibition of child labor
     We shall not tolerate all forms of child labor. Furthermore, we will not assign young workers to late-night or overtime work, or to tasks that threaten their health or safety.
   • Prohibition of forced labor
     We shall not tolerate all forms of forced labor including bonded labor and human trafficking.
   • Freedom of association and right to collective bargaining
     We respect the rights of workers concerning activities related to freedom of association and collective bargaining in accordance with the laws and regulations applicable to the countries and regions where it conducts business activities. Even in cases where freedom of association and the right to collective bargaining are restricted by the laws and regulations of each country or region, we will faithfully accommodate, whenever applicable, dialogue and discussion with employees or their representatives.
   • Working hours and wages
     We comply with all the laws and regulations on working hours, leave systems, and wages applicable to the countries and regions where it conducts business activities and pays wages above the level at which employees can fulfill a minimum level of living. We also apply a compensation system that is not influenced by gender. Furthermore, we continuously set working conditions including wage levels that are competitive in each region.
3. Stakeholder engagement
   When we talk about “stakeholders”, we refer collectively to all parties that are affected by our business activities. Stakeholders include customers, shareholders, investors, distributors, suppliers, local communities and employees. We will consult with independent external knowledge on human rights issues and respect dialogue and discussions with internal and external stakeholders to understand human rights related issues. We will regularly and publicly communicate our activities on human rights based on this policy through our reports and/or Group website.
4. Local communities
   Companies cannot continue to exist without maintaining good harmony with the local community. We wish to be the most transparent company which actively seeks harmonious balance of interests with the local communities through close communication and contributes to the local communities as a valued corporate citizen. Recognizing that our business activities may affect local residents’ land rights, as well as the rights, cultures, and livelihoods of indigenous peoples, we will strive to coexist with local communities.
5. Human rights due diligence
   We conduct human rights risk assessments for our existing and new construction/mining equipment and forestry machinery businesses worldwide based on international norms such as the “UN Guiding Principles on Business and Human Rights” with the help of external experts. When a company joins the Komatsu Group through a merger, acquisition, joint venture, or similar transaction, we incorporate a preliminary assessment of human rights measures into the investment screening process. In addition to these risk assessments, we will conduct CSR procurement assessments for suppliers and promote CSR procurement through improvement activities based on the results of the assessments. We will also perform risk assessments downstream in the value chain with the aim of proceeding with dialogue with all relevant stakeholders including distributors, and building an approach directed at responsible sales. Bearing in mind that our business activities may impact local communities and those involved in our value chain, including people who are particularly vulnerable, we will continuously conduct human rights due diligence and strive to identify, prevent, mitigate, correct, and monitor any negative impacts on human rights.
6. Guidance for employees
   In order to ensure the effectiveness of this policy, we will conduct appropriate training and activities to raise awareness in employees throughout the Group. In addition to officers and employees, we will also strive to disseminate this policy to suppliers, sales and service distributors, and other business partners, and promote their understanding of it.
7. Remedy
   We have established and maintained a Global Compliance Hotline at our headquarters to take reports relating to non-compliance, including regarding human rights issues and make this Hotline number known to all Komatsu Group employees. Any employee who believes a conflict arises between this policy and the laws, customs, or practices of the place where they work, or who has questions about this policy or would like to confidentially report a potential violation of this policy, should raise those questions and concerns with the Hotline anonymously. In addition to the Hotline for Komatsu Group employees, anyone other than Komatsu Group employees who become aware of any circumstance or action that violates or appears to violate this policy or applicable law with respect to human rights, can file a report anonymously. They can contact the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) at https://jacer-bhr.org/application/index.html. Komatsu prohibits retaliation against whistleblowers and, if it becomes clear that Komatsu has caused or contributed to negative human rights impacts, will work to provide appropriate correction and remedy.

Established: September 2019
Revised: September 2023
and September 2026