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The Kobelco Construction Machinery’s Code of Conduct represents its Group’s corporate compliance philosophy and guideline by integrating the Company’s “Corporate Code of Ethics” and “Corporate Code of Behavior” in itself.
1. Objectives and Applicability of the Code
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This Code of Conduct will establish rules of appropriate action in accordance with the action policies of “Simplicity,” “Speed” and “Openness” when conducting corporate activities based on Kobelco Construction Machinery Management Philosophy. All officers and employees of Kobelco Construction Machinery, its affiliates and subsidiaries will be required to observe this Code in performing all daily corporate activities. This Code must be observed in the pursuit of each current corporate activity area but the Code does not necessarily cover all applicable behaviors. As for acts which are not prescribed in this Code, it is expected that employees shall review the management philosophy, action policies and fundamental principles, which are the foundation of our corporate activities, to formulate the appropriate action based on the code policies. This Code of Conduct shall be revised periodically to appropriately reflect changes in social conditions, legal amendments and/or other reason to warrant revision.
2. Fundamental Principles
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[1] |
In every corporate activity, all relevant laws and Company regulations including this Code of Conduct shall be observed, and there shall be no deviation from the corporate ethics and social morals. (Foreign Exchange and Foreign Trade Act, Securities and Exchange Act, Act for the Regulation of Political Funds, Public Office Election Act, all rules and regulations to prohibit bribery and corruption, rules and regulations related to environmental conservation, etc. ) |
[2] |
In every aspect of corporate activity, human rights shall be respected, and discrimination based on race, gender, occupation, age, nationality, social status, religion, physical disability, language, place of origin, or other socially unacceptable practices shall be prohibited. |
[3] |
In every corporate activity, fair trade practices shall be observed with each of our stakeholders. (Observance of the Prohibition of Private Monopolization and Maintenance of Fair Trade Act, and the Act against Delay in Payment of Subcontract Proceeds, Etc. toward Subcontractors) |
[4] |
All business practices shall always be based on high ethical standards, and antisocial behavior shall never be condoned, nor any practices that will damage the honor and credit of the Company. |
[5] |
The Company shall always strive to supply the safest products with attention to the conservation of the global environment, and will provide services and information in a timely manner that satisfy customers and meet their demands. |
3. Justice and Fairness in Corporate Activities
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[1] |
Relationships with Customers and Business Partners including Dealers and Designated Service Shops
In sales activities, arbitrary manipulation of markets through bid rigging, cartels and other illegal acts will never be tolerated. The Company will never conduct any illegal transactions under the laws including the Commercial Code, the Anti-Monopoly Act, etc. by forcing specified business partners to accept prices and/or designate quantities, nor implement false transactions.
Business shall be conducted with partners fairly and ethically on an equal basis, and will not discriminate against partners nor unfairly restrict their business activities.
The Company shall not engage in any malfeasances that may damage the Company through illegal transactions caused by collusion and bid rigging, nor violate rules.
The Company will properly control gift-giving, entertainment of customers and business partners for the objective of sales promotion in frequency and amounts with respect to accepted social practices and international standards.
The Company shall strictly prohibit sales activities using false information and/or exaggerated advertisements that will harm our reputation with customers.
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[2] |
Relationships with Our Suppliers
The Company will negotiate properly to determine suppliers and prices fairly while giving equal opportunities to all partners in the procurement of materials and services.
In pursuit of procurement operations, the Company shall not require partners to offer benefits and/or favors by taking advantage of its position nor engage in any questionable business practices.
For entertaining partners and/or giving and receiving gifts, the Company shall practice caution in insuring that it does not deviate from sound common sense. |
[3] |
Relationships with Shareholders
The Company shall work to maximize profits for our shareholders from the perspective of stable and long-term management. Based on the relevant laws, the Company shall willingly disclose information in a timely manner on our business activities and corporate information for just and fair business practices.
The Company shall never engage in insider-trading, neither using information of the Company and its affiliates nor information of business partners obtained through operations and transactions. |
[4] |
Political and Administrative Relationships
Observing the Act for the Regulation of Political Funds and the Public Offices Election Act, the Company will never illegally offer endowments and political donations. In accordance to relevant laws, we will appropriately conduct transactions with public offices and local governments by eliminating collusion and improper personal relationships. |
[5] |
Social Relationships
Recognizing their role as a corporate spokesperson, each employee shall make every effort to accurately convey the policies of the Company’s management in order to earn the public’s trust. The Company shall sincerely welcome opinions and requests from the community and reflect them in our business activities.
The Company shall never establish any relationships with antisocial organizations including racketeers and/or gangsters.
For development and manufacture of products, the Company shall be attentive to environmental conservation by focusing on the conservation of resources, energy saving, enhancing recyclability, and reducing waste and harmful substances while observing relevant laws and regulations
To enhance and maintain good relationships with local communities, the Company will proactively participate in community activities and offer support to them. |
[6] |
Overseas Business Activities
Following international rules in the Company’s overseas business activities, the Company will promote localization of management as much as possible while respecting that country’s society, culture and customs. |
4. |
Corporate Activities Promptly Responding to Customers and Current Social Needs |
[1] |
Development and Manufacture of Products
Developing creative products with a focus on emerging customer and social needs as well as potential future generation needs, the Company will provide products, services and information toward the betterment of daily lives and communities in a timely manner.
With rational production approaches focusing on safety, conservation of resources, energy savings and environmental considerations, we will manufacture quality products under the perfect quality control system to provide them at proper prices with stability in mind. |
[2] |
Customer Support
The Company shall establish a 24-hour customer support system for prompt and steady operation for customer support activities with an emphasis on three elements: speedy response, smooth parts supply, and communication with customers.
In the event of product malfunction or safety considerations, the Company shall promptly take appropriate action to reduce the damage and/or risk through cooperation with all individuals involved whether in or out of the Company. The Company will take the necessary steps to prevent recurrence of the problem. |
5. Disclosure and Information Systems
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[1] |
The Company shall manage systems and organizations to prevent confidential information leaks with regard to every business activity. The Company shall also legally collect information from competitors and other companies. |
[2] |
The Company shall disclose development and research achievements as intellectual property in accordance with international rules. The Company shall promote the utilization of these achievements for technological development and popularization. In addition, the Company shall respect the intellectual property rights of other companies. |
[3] |
The Company shall disclose information in a timely manner to our stakeholders in accordance with relevant laws. The Company shall properly handle information obtained from other persons. |
[4] |
The Company shall build efficient internal and external information systems through the full utilization of advanced information network systems. The Company shall also make every effort to prevent misuse of these systems for theft and/or falsification of data, as well as the use of the internet and mobile terminals for private gain and interest. |
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Creation of a Free and Magnanimous Company Atmosphere that Is Open yet Maintaining Discipline |
[1] |
Employees shall act rationality and display common sense as businesspersons, understanding that each individual is responsible for their role, which is responsible for development of the Company and the happiness of the individuals. |
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The Company shall promptly and proactively convey all management information required for fulfillment of employees’ duties to enhance awareness of each individual’s participation in management. Management shall make every effort to directly hear the opinions and views for reflection. |
[3] |
Respecting individual’s rights, personalities and characteristics, the Company shall work to eliminate discrimination against gender, age, post, careers, nationality, physical disability, language, religion and place of birth in personnel affairs, working condition, our words and deeds. |
[4] |
The Company shall create a corporate atmosphere where the spirit to challenge is encouraged without the fear of failure, and will establish a personnel system to fairly assess the capabilities and achievements of each employee. |
[5] |
The Company shall endeavor to create a comfortable and safe work environment, in which employees feel comfort and affluence, while working to improve work conditions. |
[6] |
In the Company’s daily activities, employees shall learn good manners as businesspeople (neat appearance, proper greetings, appropriate response to callers, human relations at the worksite, creating proper business documents, appropriate behavior outside the Company, social customs, etc.) in the effort to create good human relations for the smooth fulfillment of operations. |
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