Read the Course Overview.
1. Five Principles of Compliance
1. Electronic Communication Tools and Trade Secrets and Proprietary Information and Disclosure
1. Antitrust Compliance and Fair Competition
1. Equal Opportunity Non-Discrimination
1. Internal Controls AND Financial Controls and Records
1. Promoting the Reporting of Misconduct
In this course, you will learn about topics that Komatsu considers to be the Rules of the business community, reinforced through our Worldwide Code of Business Conduct.
The cornerstone of Komatsu’s management philosophy is to commit ourselves to quality and reliability to maximize corporate value. We at Komatsu believe our “Corporate Value” is the total sum of trust given to us by society and all stakeholders.
While Komatsu is expected to achieve its own sound and sustainable growth as a global corporation, a growing number of stakeholders also expect Komatsu to give due consideration to the environmental and social impacts of its business activities, products and services, and to make positive contributions to the sustainable development of society. Komatsu believes that meeting these expectations is our social responsibility as a good corporate citizen, while we seek to find solutions for ESG (Environmental, Social and Governance) issues through our core business activities. In addition, a positive cycle of solving ESG issues and improving our earnings is expected to facilitate sustainable growth for Komatsu. Part 1 of “Komatsu’s Worldwide Code of Business Conduct” (the “Code”) provides principles and standards for responsible business conduct that Komatsu follows to fulfill its social responsibilities.
For Komatsu to continue to earn the trust of society, each and every employee of Komatsu is required to act in good faith, ethically and in compliance with laws, regulations and other rules generally recognized and respected by society (the “Rules”). Accompanied by examples, Part 2 of the Code contains select universally applicable rules which set the code of conduct that must be followed by all employees of Komatsu.
All employees of Komatsu are also expected to make decisions in accordance with the priority order of "Safety (and Health), Law (Compliance), Quality, Delivery, and Cost”, and to give the highest priority to Safety, Health and Compliance over all other principles. In addition, the “Five Principles of Compliance” demonstrate basic actions in order to comply with the Rules, and in particular, strictly prohibit covering up or disregarding any wrongdoings or mistakes in violation of the Rules.
More than 60,000 employees of Komatsu will take this training about our Worldwide Code. All employees of Komatsu should strive to create and maintain a safe and comfortable work environment so everyone can perform their jobs in good health and maintain the trust of society by complying with these Rules.
Thank you for participating in this overview of Komatsu’s Worldwide Code of Business Conduct.
After completing this topic, you should be able to
"Five Principles of Compliance” (the “Five Principles”) represent the basic actions of compliance that all Komatsu employees must observe. Komatsu employees must always keep the Five Principles in mind and perform their respective daily jobs accordingly.
1. To fulfill the trust of society, we must always follow the "Rules".
The company and its employees are expected to act faithfully and ethically in compliance with the law and the rules generally recognized and respected in society.
Failure to comply with the Rules (*) will result in a loss of the trust of society.
Instructions from superiors or requests from customers do not constitute any kind of excuse for a violation of the Rules.
(*) "Komatsu's Code of Conduct" defines the laws, regulations, standards, and social norms that companies and their employees are expected to comply with as "rules of the business community" or "the Rules."
2. Check or ask if you are uncertain about the “Rules.” Lack of awareness of the “Rules” is not an excuse for not following them.
There are many Rules that companies and employees must observe. Lack of awareness of the Rules is not an excuse for not following them. To not know the Rules is unacceptable. Accordingly, each employee must strive to be familiar with the Rules related to his/ her work, including any updates.
Especially with laws, regulations, and standards which may have serious adverse impacts if violated, it is imperative to check with internal and/or external experts to properly understand the contents (including any updates) so that such Rules are duly observed.
3. Never cover up or disregard any wrongdoing or mistake that violate the Rules. Report any issue immediately to the appropriate persons(s) or department(s).
In many corporate scandals that attract public criticism and are of social concern, it is the “covering up or disregarding” an issue or the lack of corporate governance that is considered problematic, which results in further damage to the reputation of the corporation.
It does require courage to report bad news such as wrongdoings or mistakes. However, the dishonest practice of covering up or disregarding these issues will not fix the problem, which will be discovered sooner or later. Never cover up or disregard any wrongdoings or mistakes.
4. Promptly correct any wrongdoings or mistakes and take effective measures to prevent recurrence.
When wrongdoings or mistakes are found, it is important to correct them promptly, prevent further violations and mitigate adverse impacts. Measures to prevent a recurrence must not be ad hoc; rather, you should go back to the source of the problem and introduce effective and permanent measures that address the root cause.
5. Never obstruct anyone from reporting or using the Compliance Hotline (whistle-blowing); never retaliate against the reporter/whistleblower for reporting a concern in good faith.
In order for a company to earn and maintain the trust of society, the company must promptly identify and remedy any deficiencies it may have. In addition to a supervisor reporting system and auditing system, a whistleblowing system constitutes part of such “self-purification function”.
To ensure that the above systems work in an effective manner, you should never prevent any person who would bring useful information to the company from reporting to the Compliance Hotline. The corporate self-purification function will never be firmly established when people believe “honesty does not pay.” You should likewise refrain from seeking out the identity of the whistleblower because that would put undue pressure on potential whistleblowers.
Komatsu has made a clear commitment that it will never take any unfavorable action against any person because of his/her whistleblowing.
After completing this topic, you should be able to
As an organization, we are dedicated to the highest standards of ethical conduct in all that we do. Our culture is defined by a commitment to honesty and integrity in all interactions. Remember, your actions reflect on the organization as a whole.
We expect our employees to take responsibility for conducting themselves in a way that is consistent with our values. These include our expectation that you'll follow the law at all times and act with honesty, fairness, and good judgment, and that you'll make decisions that reinforce our reputation for integrity.
We also expect that you'll treat others with respect and dignity; you'll be trustworthy; you'll be familiar with our policies and procedures, and ask questions if you need help; and finally, that you'll promptly report any suspected violation of our Code of Conduct.
In turn, we are committed to providing a work environment where you have the opportunity to thrive and achieve professional success.
After completing this topic, you should be able to
Offering or accepting gifts, gratuities, or entertainment can create a conflict of interest – or the appearance of one – between an employee's personal interests and his or her responsibilities to the company.
As a basic principle, employees are never to accept gifts, gratuities, or entertainment from anyone the employee believes to be attempting to influence the company's business decisions. This includes gifts or entertainment offered by suppliers or vendors, potential suppliers or vendors, government officials, or any other person seeking influence.
After completing this topic, you should be able to
Amy:
So, did you finally clean out that desk of yours?
Amy turns to Ashley, smiling.
Ashley:
Yeah...When you can't find a place to put your coffee, you know it's time to do some spring cleaning. I'm on my way to the trash can now.
Ashley holds a box full of papers and chuckles as she responds. She gestures with the box as she says "I'm on my way to the trash can now."
Amy:
Really...what have you got there?
Amy looks inquiringly at Ashley.
Ashley:
Oh, you know, the usual. Copies of contracts…proposals…some old price lists and e-mails. Good bye and good riddance!
Ashley looks at Amy as she explains. She smiles at the camera as she says "Good bye and good riddance."
Amy:
Hold on, you can't just throw those things into the trash! There could be confidential information in there.
Amy holds both hands up as if to say "stop." Her voice is alarmed.
Amy:
Not only that, we're required to keep certain types of documents on file for a specified amount of time, in case they're needed in the future. Have you even read our Record Retention Policy?
Amy addresses the camera, then turns to face Ashley as she says "Have you even read our Record Retention policy?"
Ashley:
Our what policy…?
Ashley addresses the camera, looking perplexed.
As an organization, we produce, receive, use, and process a substantial number of written communications – in both paper and electronic form – on a daily basis. These communications, which can include e-mails, text messages, instant messages, word processing documents, spreadsheets, PDFs, invoices, contracts, financial reports, and other materials, are subject to our Record Retention Policy.
The policy is designed with two major objectives in mind:
After completing this topic, you should be able to
As an employee, it is essential that you remain free from conflicts of interest that could influence your judgment or jeopardize your loyalty to the company. Even the appearance of a conflict can have negative consequences.
Your personal pursuits must never influence your decision-making on behalf of the company.
While we understand and respect that employees will maintain private lives outside of work, you must avoid situations that could result in a tension between your personal interests and those of the company.
There are a few things to avoid:
After completing this topic, you should be able to
Adam:
How many followers do you have?
Adam leans in to Ania in a conspiratorial way.
Ania:
Followers?
Ania looks at Adam with confusion.
Adam:
On Twitter.
Adam looks at the camera as though he can't believe she doesn't know.
Ania:
Oh. I don't know. Thirty, forty.
Ania looks at the camera, and shrugs her shoulders. She sounds casual as she states the numbers.
Adam:
Two hundred and eighty-seven.
Adam looks at the camera and is proud.
Ania:
Popular guy.
Ania looks at the camera and is sarcastic.
Adam:
It's all about good tweets. You wouldn't believe how many people want to know who our customers are.
Adam is speaking to the camera with a knowing tone. He gestures at himself with both hands as he says "who our customers are."
Ania:
You post tweets about our customers from your personal Twitter account?
Ania looks at Adam in shock and surprise.
Adam:
Yeah. You know...who's good to deal with. Who's a pain.
Adam looks at Ania and is unconcerned.
Adam:
And you should see what I get back. When you're networking with people in the industry, this kind of information is gold.
Adam turns to the camera, and is proud.
Ania:
And what happens if your comments reach our customers...and some of them discover that you think they're a "pain?"
Ania is speaking to Adam in a disapproving tone.
Adam:
Hey, this is me and my personal opinion. On my own time.
Adam looks at Ania and is defiant.
Ania:
What "this" is, is you sharing proprietary information about our company. It's completely inappropriate. Is this "networking," as you call it, worth risking your job?
Ania turns to the camera and then back to Adam as she says the last sentence.
The information that we, as a company, create, use, and store is among our most important and valuable assets. As an employee, you are responsible for protecting the company's confidential information you work with by ensuring it is not disclosed, either deliberately or accidentally.
A storage area contains files arranged on four categories: Employee information, Company information, Company Sales, and Future Plans.
The sharing of customer information on a social media site such as Twitter would definitely be considered deliberate disclosure of confidential company information.
In addition to information about customer details, confidential information can include any of the following: business strategies or plans, pricing information, company financial data, trade secrets, market research and analysis, as well as organizational structure, compensation information, and other personnel details.
After completing this topic, you should be able to
Most countries around the world have antitrust laws designed to promote competition and to prevent actions that interfere with the operation of the free market.
Generally, these laws prohibit agreements between two or more companies to restrict competition, as well as any abuse by a company of a dominant market position.
We are committed to doing business in a way that is consistent with these antitrust principles.
One of the most important things you can do to support that commitment is to use discretion in your conversations with competitors.
After completing this topic, you should be able to
We're committed to conducting our business with integrity. This means we are serious about our obligation to comply with the anti-bribery and anti-corruption laws that exist in all of our locations around the world. This applies not only to employees of the company, but also to the agents and partners who work on our behalf.
Many countries have enacted laws that prohibit the bribery of government officials and private individuals.
Serious consequences, including fines and imprisonment, can result from violation of these laws. Therefore, we do not allow the payment of bribes under any circumstances.
Never engage in bribery in any form. This includes offering, paying, requesting, or accepting bribes. There are several general guidelines to follow:
After completing this topic, you should be able to
As an employee of a global company, you should be aware of international trade laws. It's essential that you comply with these laws to protect our national security and to protect our own business interests. Compliance with export control laws impacts both the substance and the form of our business throughout the world. Trade regulations are complex and can change frequently. You must regularly check our trade compliance policies and standards. Engage our Trade Compliance Department when you have questions.
You may have anticipated that failing to comply with trade laws could result in significant criminal and civil penalties for the company and for an employee personally, as well as substantial disruption of business operations. For example, the government has authority under export control laws to suspend or revoke a company's trade privileges. A finding of noncompliance can also adversely impact business by damaging the company's reputation.
After completing this topic, you should be able to
Amy:
Found that new team member yet?
Amy turns to Ashley, who's holding a binder full of papers. Ashley shoots a smirk at Amy.
Amy:
Are those the resumes?
Amy points to the binder that Ashley is holding.
Ashley:
Yeah. And not one of them is any good.
Ashley smirks again, and raises an eyebrow. Amy leans in to at the resumes.
Amy:
What do you mean? They don't have the credentials?
Amy leans back a bit and addresses Ashley directly.
Ashley:
Oh, they're qualified, all right. Lots of degrees, lots of experience, but you know how it is with my team. We need people we can relate to.
Ashley sounds conspiratorial as she says, "but you know how it is with my team. We need people we can… relate to."
Amy:
I'm not sure I know what you mean.
Amy turns to the camera and sounds suspicious.
Ashley:
OK, there are five of us on the team, all women, all under thirty. If I hire him, he'll be the odd man out. Or...
Ashley points to the resume on top of the pile.
Ashley:
If I hire her – look at her work history. She's been around forever. The team's not going to want to work with someone old enough to be their mother.
Ashley flips the page to a second resume. She scoffs as she says "The team's not going to want to work with someone old enough to be their mother."
Amy:
Whoa! You can't choose who to hire based on characteristics like gender and age.
Amy sounds aghast and turns to the camera in amazement, then back to Ashley.
Ashley:
Why not?
Ashley expresses genuine surprise by this question.
Amy:
Why not? Well, not only does it mean you could miss considering some very high-quality candidates, but you're also violating our anti-discrimination policy. And you're probably breaking the law!
Amy sounds incredulous and exasperated. She looks to camera as she asks "Why not?" and then turns to address Ashley. She speaks emphatically. Ashley looks concerned.
We are committed to avoiding discrimination in our practices related to recruitment and hiring, compensation, benefits, training, promotion, and termination of employment. Our objective is not simply to follow anti-discrimination law. We wish to do more.
We recognize that discrimination is a barrier to attracting and hiring the most qualified, talented, and passionate individuals. And we know it can lead to dissatisfaction among employees once they are on board.
For these reasons, we consider it a priority to cultivate a culture of diversity and inclusion. We regard the unique experiences, perspectives, social backgrounds, knowledge, and capabilities our employees bring to the workplace to be a significant driver of our success as an organization. We operate by the philosophy that everyone can learn from others, and that a diverse work environment can be enriching and educational for all.
After completing this topic, you should be able to
We take pride in creating a respectful workplace that is characterized by professional, courteous interactions between employees and an environment that's free from harassment, bullying, and other forms of intimidation. It's everyone's responsibility to conduct him or herself in a way that reflects our values.
We suggest several guidelines to help promote our positive culture:
Remember that these expectations extend to online communications, as well as company events that take place away from the office.
A split screen showing an Instant message window with the suggestive message "Hey, you look HOT today". This image has a red circle with a line through it to show that it is prohibited. On the other side is an image of a company event with people milling about. A banner reads: "Welcome Employees."
If you experience or witness harassment or any form of uncivil behavior, speak up! We want to know about it so we can help remedy the problem.
And rest assured, we absolutely prohibit any retaliation for reporting the incident.
After completing this topic, you should be able to
Komatsu recognizes the importance of preserving the environment, conserving global resources and protecting human health. Each Komatsu Member shall strive to ensure that Komatsu conducts its business activities in an environmentally responsible manner by:
After completing this topic, you should be able to
Our company generates a vast number of financial and business records every day. These records include invoices, purchase orders, contracts, time sheets, expense reports, regulatory reports, and many others. It is essential that these records are accurate and that reports are in compliance with the financial reporting regulations in all the locations where we conduct business.
Accurate financial records are important for our own internal decision-making, as well as for various external stakeholders. These stakeholders include government and tax authorities, credit rating agencies, audit firms, and financial institutions.
After completing this topic, you should be able to
Amy:
Everything OK?
Amy sounds concerned as she addresses Ashley, who is standing with her arms crossed looking upset.
Ashley:
Not really…
Ashley glances at Amy, still looking upset.
Amy:
What's up?
Amy speaks in a gentle, inquiring tone.
Ashley:
Well…You know Louis? In IT?
Ashley hesitates at first, then uncrosses her arms as she starts to explain.
Amy:
Yeah…
Amy nods in recognition.
Ashley:
I heard him on the phone this morning ordering a part for his motorcycle…and paying for it with the company credit card.
Ashley looks uncomfortable. She addresses the camera, wincing as she says "and paying for it with the company credit card."
Amy:
That doesn't sound like Louis. Are you sure?
Amy looks surprised and sounds skeptical.
Ashley:
Yeah, I heard the whole thing. Not that I was eavesdropping…he was using the cube next to mine.
Ashley looks unhappy. She sounds defensive as she quickly says "Not that I was eavesdropping...." She folds her arms again.
Amy:
Well, if you really heard that, then you need to report it.
Amy turns toward the camera, then back to Ashley, sounding certain.
Ashley:
But shouldn't I say something to him first? I mean, everybody loves Louis. You have a problem, he makes sure it gets fixed. And who would I tell anyway?
Ashley looks unsure. She stares into the distance as she talks about Louis. She shrugs and sounds dejected as she says "And who would I tell anyway?"
Amy:
Have you checked the code of conduct? There are a lot of options. The ethics hotline number…or you could just tell your manager, or another manager. Or you can notify HR…
Amy addresses Ashley when she asks "have you checked the code of conduct?" She then turns to the camera to explain the different ways of reporting.
Ashley:
Just forget it. Louis has been here forever. He's one of the guys…if I tell on him, I'm worried his friends in management will make my life miserable.
Ashley sounds dismissive at first. She uses a mocking tone when she says "He's one of the guys." She casts her eyes downward and sounds utterly defeated as she says "miserable."
Amy:
You're wrong about that. Our code is very clear that there won't be any retaliation for reporting misconduct. In fact, the company wants employees to report anything they see so that they can deal with it.
Amy sounds firm but friendly. She's addresses the camera as she discusses what the code covers. She turns back to Ashley as she finishes.
Amy:
Here...let's take a look at the code together.
Amy reaches for her tablet and Ashley leans in to look at the screen with her.
As part of our organization's commitment to a lawful and ethical culture, we believe that everyone should feel comfortable raising concerns or reporting misconduct that they observe in the workplace. Reports of misconduct can help bring issues to the attention of management and enable the organization to respond swiftly.
As an organization, we do not tolerate retaliation of any kind. This means that any employee who makes a genuine report or disclosure of information related to misconduct will be protected from negative consequences related to the report or disclosure.
After completing this topic, you should be able to
Course Acknowledgment
You have not completed this course until you have read and acknowledge receipt of the policy found on your Learning Plan.
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