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Business and human rights

Business and Human Rights

Business and human rights

We respect the human rights related to our business activities in accordance with international human rights principles, including the United Nations’ Guiding Principles on Business and Human Rights. We also prevent and mitigate the occurrence of negative human rights impacts and establish following processes for corrective action when it becomes clear that we have caused or been involved in such impacts.

【Komatsu Group Human Rights Management System】

Implementation of human rights due diligence

Assessment of human rights risks: Keeping identification repeatedly of potential risks based on the requirements of national laws and international human rights laws and regulations.

  • Main human rights issues covered in risk assessment: Prohibition of child labor, forced labor, and overwork; freedom of association; collective bargaining rights; prohibition of discrimination and harassment; minimum wage; occupational safety and health, etc.
  • Key stakeholders in risk assessment: Komatsu Group companies, suppliers, distributors, business partners, local communities, etc.

Integration into internal divisions and procedures, and appropriate measures: Adoption of improvement activities based on risk assessment evaluation results (appropriate actions to prevent or reduce identified risks and integration of these actions into internal divisions and procedures).

Follow-up survey (Monitoring): Monitoring of the status and effectiveness of risk prevention/mitigation measures and the prevention of the recurrence of incidents.

Information disclosure: Disclosure of information on web pages and in reports to provide an overview of risk assessment efforts and the actions taken to address identified risks.

1. Formulation of human rights policy

In September 2019, Komatsu established our Human Rights Policy (revised in September 2023) and declared that we endeavor to conduct our business respecting human rights in compliance with the United Nations Guiding Principles on Business and Human Rights, and to apply respect for human rights in accordance with international standards throughout our global organization. Based on this policy, Komatsu develops and implements measures to prevent and mitigate negative impacts on the Group and our business partners' human rights, including suppliers, sales and service distributors, and further improves its processes to correct potential negative impacts on human rights.
This human rights policy has been incorporated into the Komatsu’s Worldwide Code of Business Conduct (revised in 2024) and is thoroughly communicated by all Komatsu Group employees worldwide.

In September 2023, the Human rights policy was revised following discussions by the Sustainability Promotion Committee and final approval by the President. The revised policy incorporates Komatsu's "Purpose" and "Sustainability policy," clearly articulating the company's stance by stipulating the prohibition of forced labor and child labor and respecting freedom of association and right to collective bargaining. The revised version has been translated into 13 languages and disseminated to Komatsu Group companies and partner companies (suppliers) and sales agents.

2. Promotion structure

Since human rights management activities are closely related to the operations of each department, including human resources, procurement, occupational safety, and marketing, the Sustainability Promotion Division serves as the secretariat and promotes human rights management in cooperation with each department.
Human rights policies, measures, and activities are discussed and decided by the Sustainability Promotion Committee, and the discussions are reported to the Board of Directors at least once a year.

3. Human rights due diligence

We conduct ongoing due diligence to identify, prevent, and mitigate any human rights abuses and explain how we address human rights issues in our business activities.

【Summary of human rights due diligence conducted to date】

2014 With the support of BSR (Business for Social Responsibility), an external expert, we conducted a risk assessment of human rights issues for our global construction, mining, and forestry equipment business.
2017 Conducted the second human rights risk assessment with the cooperation of BSR. In conducting the assessment, we referred to the Universal Declaration of Human Rights and the UN Guiding Principles on Business and Human Rights.
2020 With the support of an external expert, CSR Europe, a Belgian business network, we conducted a systematic global human rights risk assessment of our downstream business (sales of equipment and spare parts) in construction, mining, and forestry equipment business. Based on the characteristics of our business, we assessed and prioritized risks from multiple perspectives, including discrimination based on race, ethnicity, and country of origin, and forced labor, freedom of association, and fair labor conditions to identify and prioritised potential issues for each business sector and region.
2021 Prioritized how Komatsu’s human rights issues should be addressed and decided to conduct a survey of suppliers and Komatsu Group companies, as well as an on-site impact assessment in downstream businesses.
2022 - Conducted a human rights web survey of the Komatsu Group companies and major suppliers with support from external consultants.
- Conducted an on-site impact assessment of downstream businesses in South Africa with the support of CSR Europe.
2023 - Revised the "Human rights policy."
- Conducted "Business and human rights basic education" for all Group employees and "Procurement officer training" for purchasing personnel.
- Held "opinion exchange meetings" with headquarters marketing personnel in each region.
- Visited suppliers in Japan to exchange views on their efforts and the draft of the new human rights guidelines being prepared.

We will strengthen the identification of human rights risks and issues by conducting constant risk assessments throughout our business.

a. Internal and supply chain human rights due diligence

(1) Human rights risk assessment and impact assessment

Assessment of Komatsu Group and the supply chain

From FY2020 to FY2021, we have conductedan Self-Assessment Questionnaire (SAQ) on CSR activities, including human rights, among 156 Midori-kai supplier companies in order to further promote CSR in our supply chain and reconfirm that all parties remain fully aware of the guidelines. We confirmed their recognition of the CSR procurement guidelines and the status of their CSR activities, and followed up on the survey results on an individual basis.

  • Midori-kai: A supplier organization that is considered particularly important to our business and has been established in Japan, the U.S., Europe, China, and Thailand. The amount procured from Midori-kai accounts for approximately 70% of the total.

In FY2022, we conducted a web-based human rights survey of all Group companies and Midori-kai supplier companies in Japan and overseas. To ensure objectivity in this survey, we received support from an external consultant to create questions and analyze the results based on the UN Guiding Principles on Business and Human Rights and other international rules.
Although no serious human rights violations were found, some challenges such as insufficient awareness of the human rights policies and grievance mechanisms were identified. To mitigate these risks, a feedback report was distributed to all respondents and the results were shared.

DATA Human rights assessment results for group companies and suppliers

  1. All consolidated companies are aggregated to 84 for the survey, depending on the country/region and the business.
  2. As the European Union is planning to enact human rights due diligence legislation, the survey was not conducted this year so that it could be conducted in accordance with the legislation in the future.

Supplier visits and meetings

To understand the actual issues identified in the 2022 human rights web survey (targeting Komatsu Group and partner companies (suppliers)), we visited five partner companies (suppliers) in Japan in March 2024 and exchanged views with their representatives and staff. Currently, Komatsu is working on establishing human rights requirements. We aim to set more specific and effective requirements based on the feedback received during these visits, which will serve as the future due diligence evaluation criteria.

Screening

In our global operations, we have established a screening system to check and regulate transactions with partners designated specified in our sanction lists and other documents. We are ensuring compliance with international laws and regulations (such as embargoes).

Response to conflict minerals

In line with our corporate social responsibilities, Komatsu is continuing its efforts to avoid using conflict materials produced in the Democratic Republic of Congo (DRC) or its neighbors, as these pose a human risk when mined. We have informed our business partners of this policy through the Komatsu Green Procurement Guidelines. Working hand-in-hand with suppliers, we conducted a country-of-origin survey to determine the location of origin of our materials. Komatsu continuously investigates the subject minerals using the RMAP* and other processes. As the number of minerals of concern is increasing, we are taking action while monitoring the laws and regulations of each country.

  • RMAP (Responsible Minerals Assurance Process): A process proposed by the Responsible Minerals Initiative (RMI), an international organization.

Response to UK modern slavery act

In response to the "Modern Slavery Act 2015" being enacted by the UK in October 2015, Komatsu UK Ltd. revised its “Slavery and Human Trafficking Statement for the Financial Year 2015.” disclosed on the web site. Recognizing the possibility of the risk of human rights violations occurring in Komatsu's business operations and its supply chains, this statement reports how such an issue will be properly managed.

(2) Integration into internal departments and procedures and appropriate measures

As part of our response to risks, we conducted basic education on business and human rights for all employees and procurement staff in FY2023. We plan to maintain and expand this education in the future.

(3) Follow-up surveys

We repeatedly conduct risk assessments and continuously follow up on identified risks. We also plan to follow up on issues identified in the surveys conducted in FY2022.

(4) Disclosure of information

In the "Komatsu’s Worldwide Code of Business Conduct," we declare that we shall proactively disclose information, except in cases involving confidentiality or trade secrets. We will also make efforts to disclose relevant information on human rights issues to improve transparency and fairness.

b. Human rights due diligence in downstream business

We continue our efforts to establish a "responsible sales" approach, considering human rights in our downstream business, i.e., sales and service of products and spare parts.

[Activities in 2022] On-site impact assessment in South Africa

Based on the results of the risk assessments conducted up to the previous year, we have been conducting on-site impact assessments of our business operations on human rights since 2022.

In September 2022, we conducted an on-site impact assessment in South Africa with the support of CSR Europe. The assessment was conducted in cooperation with Komatsu Ltd. and Komatsu South Africa (Pty) Ltd., which oversees sales and services in South Africa. Based on desk research conducted in advance, the on-site impact assessment was carried out to hold dialogues with stakeholders involved in our business in South Africa. No major human rights risks were identified, and intensive discussions on human rights were held, enabling us and our customers to share awareness and deepen the understanding of issues and values.

DATA Downstream impact assessment results

4.Correction and grievance mechanisms

Komatsu has established a "Global Compliance Hotline" at its head office, which can be used to report any violation of human rights issues, and has made this hotline known to all Komatsu Group employees. The hotline also accepts reports of violations or suspected violations of human rights policies and laws, as well as reports of non-compliance or suspected non-compliance in procurement activities, to whom anyone can contact anonymously if he or she becomes aware of facts that may indicate a violation or suspected violation. The "Five Principles of Compliance," which all Komatsu Group companies and their employees must follow, making it clear that employees who use the system for appropriate reporting will not be treated unfairly in any way as a result of their action.
In addition, Komatsu has joined the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER) to receive and respond to wide range of enquiries, mainly from outside the company, on human rights issues throughout the value chain.

5. Internal training

In FY2023, We conducted "Business and human rights basic education" for all Group employees and "Procurement officer training" for purchasing personnel. The materials were translated into 13 languages and distributed to each Komatsu Group company. Additionally, we held "opinion exchange meetings" with Komatsu headquarters marketing personnel five times in each region, where we introduced our previous efforts and gathered opinions on approaches toward responsible sales. We will continue to provide human rights education and strive to enhance human rights awareness throughout the entire Komatsu Group.

Revitalization of local communities (social contribution activities)

We believe that revitalizing the local economy will also help solving potential human rights issues. Through human resource development utilizing our core skills, we continue to focus on education at training centers around the world, and support regional vocational training schools through our social contribution programs in ways such as providing curriculums and training tools. This will also support the safe deployment of the machines and reduces further the risks for accidents and misuse.

Examples of specific human rights due diligence activities

Since 2019, we have conducted due diligence on Myanmar with the support of external experts, to identify the issues and discuss how we approach those issues. As a result, we made a decision in 2019 to terminate sales of mining equipment to the jade mining market in Myanmar. We also terminated the operations of "Komatsu Manufacturing Myanmar", our subsidiary engaging in mining equipment maintenance. We have since been in the process of liquidating the company. We will continue to work further with our distributors and external experts in Myanmar to take effective measures to strengthen respect for human rights in our operations.

komatsu csr, env, corporate communication, Procurement Division