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Compliance

Fundamental Compliance Promotion Policy

To realize K-ESG management, we share a common set of values codified in our Corporate Principles and Charter for Action & Code of Conduct, and our fundamental policy is that we faithfully adhere to laws and internal rules, but also to ethical and moral standards. Compliance forms the foundation for a company to achieve continuous growth, and so to promote it, we have come up with a three-pronged approach: fostering awareness, gaining knowledge, and constructing systems. In line with this approach, we are ensuring thorough compliance through such measures as training and education, rules, and an internal control system.
Moreover, to warrant the trust and confidence placed in us by customers and other stakeholders, and to give back to society, it is important that we perform our work honestly and sincerely, without lies or falsehoods. On this point, we are striving to transform some words that Kubota’s founder valued—“One must hold integrity and morality in high esteem”—into our corporate culture. It goes without saying that we must adhere to laws and regulations, but integrity and morality are equally vital in this age of compliance, and we believe them to be the basis of our corporate activities.

Basic approach

No sales or profits are worth pursuing at the expense of the Kubota Group’s corporate dignity and trust.

  • Promotion Framework

Kubota Group Charter for Action & Code of Conduct

All the employees working for the Kubota Group, including those overseas, are required at the time of joining the Group to submit a written “Confirmation Statement” that they will comply with the Kubota Group Charter for Action & Code of Conduct, and the corporate principles, the Kubota Global Identity.
Furthermore, various tools for education and awareness-raising are prepared with the aim of fostering a mindset based on compliance and the corporate principles. For more information, please refer to the following link and the Kubota Group Integrated Report / ESG Report.

Internal Control System

Prevention of Illegal Payments

The Kubota Group is engaged in efforts to prevent any corrupt practices. It has placed particular focus on preventing bribery among risk management activities on the preventing of illegal payment, and will work to achieve SDGs Target 16.5: Substantially reduce corruption and bribery in all their forms.
Amid increasing international moves to anti-bribery, we marked December 9 – designated by the United Nations as International Anti-Corruption Day – by broadcasting a President’s Message to all Kubota Group officers and employees every year. In the message, our top management made a clear commitment by declaring that ‘KUBOTA Group never allows business based on unfair practices such as bribery.’
As part of efforts to prevent corruption, the Kubota Group is working to establish and enforce rules for pre-consultation on opportunities suspected of involving bribery, including small bribes. Also, to ensure effectiveness, we are strengthening and enforcing education and awareness activities for officers and employees, especially those stationed at overseas locations. Specifically, as part of our anti-bribery education for officers and employees, we run training based on concrete case studies involving the bribery of foreign public officials, along with workshops and e-learning sessions both in Japan and overseas. To deepen understanding of the laws, incidents, and enforcement status in each country, we extensively incorporate explanations by lawyers. By doubling down on pre-consultation rules and conducting regular and continuous training, we aim to cultivate an awareness of bribery prevention and ensure the circulation of the latest information.
Furthermore, we have prepared a handbook*, and we issue newsletters throughout the year, among various measures to introduce various information such as laws, regulations, and case studies related to bribery prevention, embezzlement, and facilitation payments, etc., to the entire Group in and effort to prevent bribery and ensure widespread awareness.
In addition, as an initiative directed outside the company, a ‘Request to Suppliers’ was posted on the Kubota website in the name of the General Manager of the Corporate Compliance and Risk Management Headquarters. The text outlined to suppliers the Kubota Group’s approach to bribery prevention and asked for their understanding and cooperation in bribery prevention activities.
From the end of 2023, we have rolled out operation of a global hotline for overseas bases. In this way, we are working to enhance our internal reporting system with the aim of facilitating early detection and prevention of bribery and other improper activity.
To verify these risk management activities, the Kubota Group has established the Committee on Prevention of Illegal Payments. In FY2024, document surveys were conducted at 13 companies in Japan and 34 overseas bases to investigate whether preventive frameworks were in place and sufficiently functioning, as well as whether there were any illegal payments.
The policies for these risk management activities and the results are periodically reported to the Board of Directors through the Kubota Group Risk Management Committee. Based on the feedback provided, the content of risk management activities is reviewed to improve the overall level.

  • We have put together a Kubota Group Handbook for Anti-Bribery which is being issued across the entire Group. The Handbook is issued in a global version with universal content available in Japanese, English, French, Chinese, and Thai.
The Kubota Group Anti-Bribery Policy (excerpt)

As specified in the Kubota Group Charter for Action, we commit ourselves to “conducting corporate activities based on compliance with legal regulations and ethical principles.” As such, Kubota Group never allows business based on unfair practices such as bribery. The Group also strictly prohibits all of its companies, officers and employees from being involved in bribery.

President, Kubota

Information Security

Tax Management

Personal Information Protection

As cyberattacks yearly grow more sophisticated and more complex, Kubota is aware that the appropriate protection and management of the personal information of its customers and other stakeholders is an important social responsibility. In addition, we are working to appropriately manage personal information not only under Japanese law, but also overseas laws and regulations.

System

Under our internal rule “Personal Information Protection Rules” regarding the protection of personal information, a responsible person is appointed at each business division, department, and Group company to promote appropriate handling of personal information. We have also established a structure that will enable us to respond rapidly to an incident such as a data leak. To minimize the risk of data leaks originating from contractors, we established and enforced “the Guidelines for entrusting personal data” in 2024, and since then, we have endeavored to bolster our management of contractors.

Education and Awareness-Raising

We regularly conduct education and awareness-raising activities for departments and Group companies that handle personal information in our efforts to increase and strengthen employee awareness. From 2023, we have conducted e-learning together with the IT department, combining an information security perspective to provide education for employees of departments and Group companies.

Audits

We regularly conduct audits (such as on-site and document audits) of departments and Group companies handling personal information to understand the status of risk management related to personal information.

Ensuring the Reliability of Financial Reporting

To ensure the reliability of financial reporting for the Kubota Group overall, including overseas subsidiaries, we have established and operate an internal control system. Moreover, to confirm its effectiveness, the Corporate Auditing Department and the auditing divisions of subsidiaries conduct regular internal audits. Based on the results of these audits, we have built a system for evaluating the effectiveness of internal controls on a consolidated basis in conformance with the internal control and reporting system (J-SOX), etc., pertaining to financial reporting as stipulated by the Financial Instruments and Exchange Act.

Compliance with the Anti-Monopoly Act/Competition Laws

We realize that full implementation of compliance is key to establishing Kubota as a Global Major Brand. The Kubota Group therefore engages in the risk management activities set out below to ensure prevention of any infringement of Japan’s Anti-Monopoly Act and the competition laws of overseas countries as well as the Subcontract Act.

System

The Company’s internal rules relating to Japan’s Anti-Monopoly Act, competition laws and the Subcontract Act are the Rules on Competition Laws Compliance and the Rules on Subcontract Act Compliance. Under these rules, we have established the Competition Laws Compliance Committee and the Subcontract Law Subcommittee, each with members elected from Kubota and Kubota Group companies’ relevant departments. These committees promote measures to prevent violations of their respective laws and regulations.

Education and Awareness-Raising

In 2023, the Guidelines for Global Competition Law were formulated as basic rules for the Kubota Group with regard to the Anti-Monopoly Act and competition laws, and the Company implements education and awareness-raising regarding the guidelines. Moreover, annual training sessions about the Subcontract Act are held each year for divisions engaged in subcontracting business. In addition, training is conducted as needed for business divisions and Group companies on the Anti-Monopoly Act, competition laws, and Subcontract Act. In 2024, we conducted training on competition laws and the aforementioned guidelines at workshops for employees widely dispatched to overseas locations.

Audits

Kubota continuously conducts audits under both the Anti-Monopoly Act and Subcontract Act, including on-site inspection, targeting its business divisions and Group companies in Japan. For overseas Group companies that conduct sales outside the Group as well, Kubota gauges the status of risk management in relation to each country’s competition laws through document surveys, email, and communication through online meetings and other venues.

Maintaining and Expanding the Consultation System

The Company has stipulated the reports and consultations to be undertaken based on the Rules on Competition Laws Compliance and the Rules on Subcontract Act Compliance, should it be judged that a Kubota Group officer or employee has violated, or is in suspicion of having violated the relevant laws and regulations, or in any other case where it is necessary, and maintains a consultation system for both emergencies and normal times.