JAPANESE

Compliance

Frameworks for Promoting Compliance

To make certain that the entire Komatsu Group complies with the rules of the business community, Komatsu has appointed an executive officer in charge of compliance and established the Compliance Department to handle this issue exclusively. The Compliance Committee, chaired by the President and CEO, reviews the Group's action policies and important issues, while regularly reporting the state of compliancerelated activities to the Board of Directors.

Strengthening Compliance

Komatsu's Code of Worldwide Business Conduct

The company has formulated Komatsu's Code of Worldwide Business Conduct (established in 1998 and revised six times to date) as a compilation of best business practices to be observed by officers and employees of Komatsu Group companies both in and outside Japan. The code addresses such topics as fair business practices, non-discriminatory personnel systems, endeavors for the global environment, appropriate information management, and internal control structure. The text of the code has been released to the public in its entirety.

Towards Thorough Compliance

For continual awareness among employees about compliance, the Group is working to raise their consciousness of best business practices by displaying in every Komatsu Group business unit posters listing The Five Principles of Compliance, a condensed version of Komatsu's Code of Worldwide Business Conduct. Beyond this, the Group strives to provide effective awareness-raising through the use of e-Learning as well as well-developed compliance-related education and training that is tailored to employees' ranks and the types of operations they are engaged in. Furthermore, during internal audits of Komatsu business units and Group companies, the Komatsu Group not only conducts financial audits but also monitors their compliance with business rules and safety and environmental practices, enabling early detection of risks and improvement.

Internal Reporting System

Komatsu established the Business Rule Consultation Office in1998 through which employees from any Group company can consult with the company about issues pertaining to best business practices or report questionable actions. By clearly stating in Komatsu's Code of Worldwide Business Conduct and Group companies' workplace rules that employees using the internal reporting system will not be penalized, the Group fosters active consultations and reporting.