Protected Disclosure / Whistleblower Protection

Purpose

This Policy supports compliance with the Protected Disclosures Act 2000 (New Zealand).  It aims to create a safe way to report wrongdoing, to protect whistleblowers, and, those that are the subjects of yet to be investigated and substantiated concerns from adverse action, discrimination and victimisation.  The Policy provides a framework to deal with and remedy reported matters.

Scope/ Eligibility

This Policy extends to serious wrongdoing that occurs before or after the commencement of this Policy.

A team member, including employee, former employee, contractor, secondee or volunteer may make a disclosure under this policy.

Policy

What to report

Should you have reasonable grounds or belief to suspect that misconduct has occurred, or that an improper state of affairs or circumstances exist within Kubota New Zealand you may choose to make a report.  The subject of any report may include current or former team members (including employees and contractors), officers or Board members of Kubota New Zealand.  Please refer to the Kubota Australia policy in relation to the making of a Whistleblower complaint regarding Kubota Australia.

Misconduct may include, but is not limited to:

  • Breach of specific legislation
  • Dishonest, corrupt or illegal activities
  • Serious breach of Policies and Procedures, including serious risks to health and safety or environment
  • Fraud, theft, money laundering or misappropriation
  • Offering or accepting a bribe
  • Damage/ sabotage
  • Instruction to cover up or attempt to cover up serious wrongdoing/ actual or potential offences

Personal work related grievances covered by the Employment Relations Act are excluded from his Policy and should be dealt with under other policies and New Zealand employment law.

Protected Disclosure/ Report

A “Protected Disclosure” is a report made in accordance with the Protected Disclosures Act and this Policy.

Nothing in this Policy is intended to abrogate or diminish any additional or alternative protections which may be available at law. To be protected under this Policy, a discloser/ whistleblower must:

  • be acting with reasonable belief that the information in the allegation is true or likely to be true
  • make the disclosure in accordance with this Policy; and
  • not have engaged yourself in illegal or serious misconduct in relation to the conduct you are reporting.  However, you may still wish to report this in the knowledge that it is not a protected disclosure.

Advice prior to lodgement

Before making a report it is recommended that you contact the Office of the Ombudsman, New Zealand for advice and guidance.

Who to report to

Depending on a range of circumstances, you may choose to make a report internally to Kubota New Zealand or externally.  See the Procedures section regarding who to report to, in what format and the information to include in your report.

Alternatively, you may determine that it is reasonable and necessary for you to make your report directly to relevant authorities or external entities.  The Office of the Ombudsman has a listing of all relevant authorities and can provide advice regarding appropriate lodgement of disclosures.

Protections

Investigation and findings

Kubota shall apply principles of procedural fairness and natural justice to the conduct of any investigation and resultant findings arising under this Policy.

Duty not to disclose identity

A team member to whom a report has been made, must not disclose either a discloser/ whistleblower’s identity, or any information likely to lead to the identification of the discloser/ whistleblower. The only exceptions are where:

  • the identity of the discloser/ whistleblower is disclosed with the consent, is provided as required by law to regulatory or law enforcement bodies if required, or is given to a lawyer in order to obtain legal advice or representation; and
  • information likely to lead to the identification of the discloser/ whistleblower (but not the discloser/ whistleblower’s identity) is disclosed because it is reasonably necessary for the purpose of investigating the matter, and the person takes all reasonable steps to reduce the risk that the discloser/whistleblower will be identified.

Protection from discrimination and victimisation

The whistleblower/s, nor the person/s who are the subject of a yet to be investigated and substantiated concern must not be treated adversely nor discriminated against in any aspect of employment, and must not be victimised. Refer to relevant legislation such as the Human Rights Act 1993 (New Zealand) for further information.

Should any action be taken against an employee who is a discloser/ whistleblower they may take action as prescribed at law such as raising a personal grievance or instituting action under the Human Rights Act 1993 (New Zealand).

Limitation of Policy

Kubota have no ability to offer discloser/s, whistleblower/s immunity against criminal or civil legal action that may be taken against them. 

Procedures

Who to report to

Depending on a range of circumstances, you may choose to make a report internally to Kubota.  You may make a report to:

  • The nominated Whistleblower Protection Officer, currently the Compliance Officer.
  • A General Manager on the understanding that they will need to refer this to our nominated Whistleblower Protection Officer. 
  • An officer of Kubota New Zealand (such as a Board member).
  • The General Manager of Finance and Administration, should the subject of complaint be the Compliance Officer.
  • Care of kau_g.whistleblower@Kubota.com which is received by our nominated Whistleblower Protection Officer in respect to Australia and New Zealand.
  • Anonymously to: Kubota Australia Pty Ltd, Whistleblower Protection Officer, 25-29 Permas Way, Truganina, VIC, 3029.

Where the subject of the report is the Whistleblower Protection Officer, the report should be made to the General Manager, Finance and Administration (who will assume, or delegate to an external professional, all case management duties of the Whistleblower Protection Officer).  Should the General Manager, Finance and Administration also be implicated, the report should be made to Kubota New Zealand’s Managing Director (who will assume, or delegate to an external professional, all case management duties of the Whistleblower Protection Officer and General Manager Finance and Administration).  Where the Managing Director is implicated, the report may be directed to the Kubota Australia Board or Kubota Corporation if more appropriate to do so.

Alternatively, you may determine that it is reasonable and necessary for you to make your report directly to relevant authorities or external entities.  Contact the relevant authority/s or entity/s for detailed information or refer to Protected Disclosure information contained on their website/s.

Content of report

Your report may be made verbally or in writing.  It is strongly preferred that you make a report in writing to ensure clear communication and to enable the best possible management of the matter.

Information you should pass on in your report should include:

  • date of report
  • identity of reporter (if disclosed/ known)
  • substance of report
  • any dates or details of when, where or how the reportable conduct occurred
  • the identity or level of seniority of the person/s who are the subject of the report
  • the perceived level of risk or gravity of the reportable conduct
  • any other pertinent matters or evidence.

Receipt of reports

If you receive a Whistleblower report, you must ensure it is conveyed to the Whistleblower Protection Officer expediently. It is recommended that you pass on the report within 24 hours, or sooner where it would be assumed the matter would be urgent or involves a potential emergency. 

Once you have passed on the report, you should take no further action.  You will generally not be kept updated as to the status of the report.  You must not discuss the report further and must maintain confidentiality at all times.

Investigation Process

Where a Whistleblower Report is made internally, or Kubota become aware of the substance of a report that is made externally, the Whistleblower Protection Officer will ensure that an investigation is undertaken in a timely manner.  Where there is sufficient information to do so, an investigation will be undertaken to the full extent possible based on the information contained in the allegation or level of awareness of the substance of any concern/s.  

The Whistleblower Protection Officer (or alternate as outlined above if the Whistleblower Protection Officer or their Manager are implicated) will:

  • Undertake a preliminary review of the matter.
  • Determine if there is sufficient information to conduct an investigation.
  • Determine if an external professional organisation should be engaged to case manage and/or conduct the investigation and/or provide findings and recommendations as to appropriate action.
  • Create a plan for the investigation, inclusive of any witnesses to be contacted, information to be sourced, professional advice (eg. legal, taxation, etc) to be sought and indicative timeframes.
  • Conduct the investigation, or, oversee that it is conducted.
  • Ensure the findings of the investigation are clearly documented.
  • Review and provide recommendations, or ensure any external organisation provides recommendations, to the Managing Director (via the General Manager Finance and Administration if appropriate) based on the specific individuals involved or systemic matters and risks.

Findings and actions

The Managing Director shall make any final decision and determine any actions based on the findings and recommendations.  The Managing Director is not required to adopt recommendations and shall determine any actions.  The Managing Director is responsible for ensuring (via delegation or directly) that actions are implemented.

Where the subject of the report is the Managing Director, the Kubota New Zealand Board then Kubota Australia Board would assume this responsibility, or Kubota Corporation if this is more appropriate.

Contact with Discloser/ Whistleblower

Should Kubota determine that it is appropriate to do so in light of confidentiality, privacy and legal constraints, and the discloser/ whistleblower indicates they would like to be kept updated, the discloser/ whistleblower may be kept up to date in regards to key milestones within the investigation process.  Where Kubota determine that a referral to an appropriate authority or external entity is necessary, it may not be possible to provide updates.


Supplier Code of Conduct

This code of conduct applies to all businesses that provide products or services for Kubota New Zealand Limited (Kubota) and its joint ventures, divisions, or affiliates. Kubota requires suppliers and their employees to commit to this code of conduct as a condition of doing business

Kubota suppliers must comply with the laws, rules, regulations, and Kubota policies of the countries and locations in which they operate. They are expected to be familiar with the business practices of their suppliers and subcontractors, and ensure they operate according to this code of conduct. Kubota may discontinue its relationship with suppliers who fail to comply with this code.

People Responsibilities

Labour and human rights

Suppliers are expected to provide a fair and ethical workplace, maintaining high standards of human rights, with appropriate labour and human rights policies and practices in place.

At Kubota, we pride ourselves on providing an equal employment and gender equality workplace and expect our suppliers not to discriminate against any employee based on age, disability, ethnicity, gender, marital status, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by law, in hiring and other employment practices. Suppliers are expected to proactively support gender equality initiatives. Kubota strives to promote and influence improvements in gender equality across its Supply Chain through procurement policies and practices.

Suppliers are expected not to bully or threaten employees or subject them to unlawful or inhumane treatment. This includes, but is not limited to, abuse and harassment which can be verbal, physical, sexual, or psychological. Consistent with Modern Slavery Policy of Kubota Australia, suppliers are expected to proactively identify, address and where required by legislation, report on risks of modern slavery practices in their business operations and supply chains. You can read more in our Modern Slavery Statement.

Suppliers should take reasonable endeavours to ensure that any third-party labour agency it may use to fulfil services to Kubota, is compliant with the Modern Slavery Policy of Kubota Australia Pty Ltd and any Labour Hire laws within the relevant jurisdiction/s including payments, recruitment related fees, practices and expenditure in recruiting foreign contract workers.

Suppliers are expected to freely allow employees to associate with others, form and join (or refrain from joining) industrial organisations or associations of their choice and bargain collectively, or engage in any lawful industrial activity without interference, discrimination, harassment, victimisation or adverse action.

Suppliers must abide by The Privacy Act 2020, which regulates the treatment of personal information about individuals. This includes the collection, storage, and disclosure of personal information about individuals.

Health and Safety

Suppliers are expected to provide a healthy and safe work environment, with comprehensive health and safety management practices in place.

Suppliers with employees who need to enter Kubota premises must ensure those employees meet any applicable requirements and be able to provide verified evidence.

Suppliers must comply with Health and Safety at Work Act 2015 and all other applicable laws relating to workplace health and safety and provide their employees with job-related training and consult with employees in relation to the provision of information and training.

Environmental Responsibilities

Suppliers are expected to conduct their operations in a way that minimizes the impact on natural resources and protects the environment, customers, and employees. They must ensure their operations comply with all applicable laws related to air emissions, water discharges, toxic substances, and hazardous waste disposal. Throughout the world, laws and regulations prohibit or restrict certain substances and/or require manufacturers and suppliers to provide information about restricted substances in their products. Suppliers must, therefore, comply with the Kubota Group’s environmental charter and when requested by Kubota, provide regulatory compliance declarations for identified products.

Ethical Expectations

Ethics, Gifts and Gratuities

Suppliers must not offer gifts to Kubota employees. This includes gifts of nominal value. Although giving gifts is acceptable in some cultures, Kubota requests that suppliers respect its policy of not accepting gifts.

Improper Payments

Bribes, ‘kickbacks’, and similar facilitation payments are strictly prohibited. This ban applies even when local laws may permit such activity. Employees, suppliers, and agents acting on behalf of Kubota are strictly prohibited from accepting or giving such considerations under any circumstances. Suppliers must, therefore, comply with Kubota New Zealand’s Anti-bribery and Corruption Policy and Procedures.

Confidential Information

Proper management of confidential information is critical to the success of both Kubota and suppliers. Suppliers must protect all Kubota information, electronic data, and intellectual property or Kubota technologies with appropriate safeguards.

Any collection, transfer, archiving or deletion of confidential information must be executed in a way that secures and protects the intellectual property rights of Kubota and its suppliers as well as ensure all privacy obligations are complied with (as relevant).

Suppliers may receive Kubota confidential information only as authorised by a Confidentiality or Non-Disclosure Agreement and must comply with their obligations to not disclose the confidential information, to not use the information except as permitted by the agreement, and to protect the information from misuse or unauthorised disclosure.

Our suppliers can expect Kubota to similarly safeguard their confidential information when authorisation is provided to Kubota. Suppliers may not use the Kubota trademark, images, or other materials to which Kubota owns the copyright, unless explicitly authorised in writing.

Supplier Management

System/s of management

Suppliers are expected to have management system/s that ensure they comply with applicable laws, regulations, and Kubota policies, conform to this Supplier Code of Conduct, and identify and reduce operational risks related to this Code. The system should also promote continuous improvement and compliance with changing laws and regulations.

Supply Chain Transparency

Supply chain transparency is required to confirm compliance to this Code. Internal or external audit shall be utilised to monitor this. This may include, but not be limited to; Kubota’s Compliance Officer request for documentation/ evidence, on-site audit, corrective action planning and verification of the implementation of corrective action.

Communication

Suppliers are expected to assist Kubota in enforcing this Supplier Code of Conduct by communicating its principles to their supervisors, employees, and suppliers.

Corrective Action

Non-compliance

Kubota will address confirmed Supplier Code of Conduct non-compliance. Actions may include, but not be limited to, any of following:

  • Require a supplier to implement changes to policy, procedure or related conduct and confirm/ evidence effective implementation in writing and/or via on-site inspection by Kubota or its representatives
  • Require specific action to be taken by a supplier, evidenced by a specified date
  • Vary the terms of, or terminate a contract, which may include summary termination
  • Referral to appropriate authorities.

Non-Compliance Reporting

Violations of the Kubota Supplier Code of Conduct can be reported confidentially via any of the following ways:

  • By email to kau_g.whistleblower@Kubota.com.au for receipt by Kubota’s Compliance Officer in respect to Australia and New Zealand.
  • To a General Manager or officer of Kubota (such as a Board member) by email or telephone at +61 9394 4400, on the understanding that these will need to be referred to the Compliance Officer
  • Anonymously to: Kubota Australia Pty Ltd, Compliance Officer, 25-29 Permas Way, Truganina, VIC, 3029 Australia

More Information or Questions

Any supplier may direct questions or comments about this Code to their Supply Management representative or Kubota’s Compliance Officer.


Anti-bribery and Corruption

Purpose

This policy sets out the responsibilities of directors, employees of Kubota New Zealand Limited (Kubota), and its suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota in observing and upholding the prohibition on bribery, corruption and related improper conduct.

The document provides information and guidance on how to recognise and deal with instances of bribery or corruption.

Kubota is committed to complying with the laws and regulations of the countries in which its business operates. Bribery, corruption and the related improper conduct referred to in this policy are serious criminal offences for both the company and any individuals involved. This conduct is inconsistent with Kubota values.

Scope

This policy applies to all directors, employees of Kubota, suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota.

Definitions

Bribe is an offer, promise or giving of anything of value to improperly influence a person’s actions or decisions to gain or retain a business benefit. Bribery and corruption can take many forms including, the provision or acceptance of cash payments, facilitation payments, kickbacks, political contributions, charitable contributions, social benefits, gifts, travel, hospitality and rebates or reimbursements.

Bribe Acceptance is the act of accepting, or a demand or promise to accept, a bribe.

Some indications of bribery that may arise during working for or providing services to Kubota could include, but are not limited to:

  • A party insisting on receiving a commission or fee payment before committing to sign up to a contract
  • A party requesting payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made
  • A party requesting that payment is made to a country or geographic location different from where the party resides or conducts business
  • A party requesting an unexpected additional fee or commission to facilitate a service
  • A party demanding lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services
  • A party requesting that a payment is made to overlook potential legal violations
  • A party insisting on the use of side letters or refusing to put terms agreed in writing.

Public Official may include, but not be limited to, any of the following:

  • a public official of a government or a municipal government
  • an official of an association established by a government or a municipal government
  • an official of an organization de facto controlled by a government or a municipal government
  • an officer or staff of a public international organisation
  • an officer or staff of a political party
  • a candidate for public office
  • a person acting in place of the persons described above

Corruption is the misuse of entrusted power or office, for private gain.

Policy

Directives

Directors, employees of Kubota, suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota must:

  • Understand and comply with this policy in all regards
  • Not give, offer, accept, or request bribes, facilitation payments, secret commissions or other prohibited payments or engage in money laundering or cause any of them to be given, offered, accepted, or requested
  • Not approve any offers, or make, accept, or request an irregular payment or other value, to win business or influence a business decision in favour of Kubota
  • Comply with any reporting and approval processes in relation to Benefits, including gifts, entertainment, or hospitality
  • Not offer or receive any benefit such as gifts, entertainment, or hospitality to or from public officials outside policy and approval processes
  • Obtain required approval/s for donations and sponsorships
  • Maintain accurate records of dealings with third parties
  • Be vigilant and report any actual or suspected breaches of, or suspicious behaviour related to bribery, corruption or associated conduct.

Directors and employees of Kubota:

  • Must not receive any gifts, entertainment, or hospitality from any party including suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota outside the KNZ Conflict-of-Interest policy.

Due diligence and contract management

Kubota team members, including directors and employees, when contracting with a third party, must undertake and ensure completion of relevant and appropriate due diligence in advance of the making of a contract. Due diligence must be conducted in accordance with Guidelines determined by each department and/or any guidelines provided by Kubota, as amended from time to time. Contracts may only be executed by those with the authority and power to do so in alignment with Kubota’s Delegation and Authority Schedule, as amended from time to time.

Record keeping

All accounts, invoices and other documents and records relating to dealings with third parties (including due diligence reports), must be prepared and maintained with strict accuracy and completeness. No accounts may be kept “off the books” to facilitate or conceal improper conduct, including improper payment.

Internal control systems and procedures adopted to comply with this policy will be the subject of regular internal compliance reviews by the Compliance Officer, and potentially external audit, to provide assurance that they are effective in mitigating risk and non-compliance.

Reporting breaches

Actual or suspected breaches of this policy must be reported in accordance with the Procedure below.

Consequences of breach

A breach of this Policy may be regarded as serious misconduct in employment, leading to disciplinary action, which may include immediate termination of employment and referral to appropriate authorities and/or other legal action. Other parties committing a breach may be subject to termination of contractual agreements without notice, and/or referral to authorities and/or other legal action, as appropriate.

Procedures

Reporting actual or suspected breaches

Reports should be made:

  • By email to kau_g.whistleblower@kubota.com for receipt by Kubota’s Compliance Officer in respect to Australia and New Zealand
  • To a General Manager or officer of Kubota (such as a Board member) by email or telephone at +61 9394 4400, on the understanding that these will need to be referred to the Compliance Officer
  • Anonymously to: Kubota Australia Pty Ltd, Compliance Officer, 25-29 Permas Way, Truganina, VIC, 3029 Australia.

Modern Slavery Statement 2021

This statement, pursuant to the Australian Modern Slavery Act 2018 (“the Act”) (Cth), sets out the actions taken by Kubota Australia Pty Limited ACN 005 300 621 and its controlled entities (together referred to as “Kubota Australia”, “KAU”) to address modern slavery in our business and supply chain over the Calendar year ended 31 December 2021. This statement also includes the planned actions to mitigate the modern slavery risk in future.

About Kubota Australia

KAU is Australia’s leading supplier of agriculture, construction, and power equipment, operating in Australia for over 40 years. It is part of the global Kubota Group of companies (KBT).

Since its foundation in 1890, KBT has delivered a variety of products that contribute to people’s lives and society, including iron water pipes for the development of modern waterworks, and agricultural machinery to increase food production and save labour. KBT believes that its mission is to comprehensively solve the problems of food, water and the environment through its superior products, technologies, and services, thereby continuing to support the future of the earth and humanity.

Brand Statement

For Earth, For Life

The Kubota Group promises to continue supporting the prosperous life of humans while protecting the environment of this beautiful earth.

Mission

Food, water, and the environment are indispensable for human beings. The Kubota Group continues to support the future of the earth and humanity by contributing products that help the abundant and stable production of food, help supply and restore reliable water, and help create a comfortable living environment through its superior products, technologies, and services.

Vision

To be a company that can make the greatest contribution to society by earning the trust of the greatest number of customers.

Kubota Australia’s Structure, operations, and supply chains

Structure

KAU is a company incorporated in Australia and our registered office is located at 25-29 Permas Way
Truganina VIC 3029.

KAU is a subsidiary of Kubota Corporation, headquartered in Japan. Under the trading name of Kubota
Australia Finance (KAF), KAU offers equipment finance. Kubota New Zealand Limited (KNZ) is domiciled in New Zealand. It is a wholly owned subsidiary of Kubota Australia. Under the trading name of Kubota New Zealand Finance (KNZF), KNZ offers equipment finance.

Operations

KAU conducts a diversified range of business activity which include agriculture, construction, and power equipment. KAF offers designated services to its corporate and retail customers by providing finance for new, demo and used Kubota machinery and equipment, including tractors, excavators, mowers, utility machinery/equipment, generators, and Krone equipment. KAF also offers finance for used equipment and machinery of competitor brands which are sold by Kubota Australia’s authorized dealers. KNZ, conducts a diversified range of business activity which include agriculture, construction, and power equipment in New Zealand. KNF offers designated services to its corporate customers by providing finance for new, demo and used Kubota machinery and equipment.

As of 31st December 2021, KAU employed 161 team members in Australia and 8 team members based in New Zealand. All team members are paid in accordance with local Australian and New Zealand requirements.

Supply Chain

KAU engages in various dealings with international related parties. Material dealings during the year included, purchasing goods from related and unrelated parties of KAU located in Australia, New Zealand, Norway, Netherlands, Indonesia, Japan, South Korea, Thailand, United States of America, Germany, France, and Italy. For the year ending 31 December 2021 KAU had a supply chain made up of approximately 2,100 suppliers.

KAU seeks to engage with suppliers that act consistently with Kubota values in relation to modern slavery and human rights. Our supplier code of conduct which is provided to every supplier we intend to do business with, outlines our expectations on supplier activity.

In 2021 KAU conducted our initial modern slavery risk assessment of its Tier 1 supply chain. We engaged a specialist consulting firm who conducted a risk assessment on our current supply chain using risk assessment software along with their specialist industry knowledge. In assessing the risk, following factors were considered:

  • Geographic location of the Supplier
  • Annual value of the purchase with each supplier
  • Type of products or services procured


This risk assessment highlighted KAU’s highest Modern slavery risk within Tier 1 suppliers is with offshore suppliers. This assessment has allowed us to prioritise due diligence process according to the risk of modern slavery for suppliers. The risk assessment also identified following industry categories in our direct supply chain, where modern slavery risks are high:

  • Agricultural & Farm Machinery
  • Industrial Machinery

This graph shows the breakdown of KAU’s suppliers considering the industry risk, location and total spend.

Operations

All employees of KAU (permanent and maximum term) reside and work in Australia and New Zealand as citizens or residents with a very small proportion of expatriates holding work visas. All employees are engaged via a legally reviewed Employment Agreement.

Work at times is performed by Australian employees, via infrequent short-term travel, in respect to KNZ operations only.

KAU do not currently, nor have we during 2021 employed any casual employees.

KAU generally do not utilize employment agencies. All agencies utilized must be contracted via a Services Agreement which includes a requirement to be registered under any relevant Labour Hire laws and provide evidence of such to KAU.

All employees and workers placed by agencies are subject to probity processes based on the inherent requirements of their position, identity check, legal right to work check and criminal records history check at a minimum. All are assessed against the inherent requirements of the position they will fulfill based on a Position Description in line with process dictated by our Recruitment and Selection Policy.

KAU considers that our systems and controls are satisfactory to manage potential risks of Modern Slavery occurring through our employment practices.

Kubota Australia’s approach to tackle Modern Slavery practices

KAU has taken steps to strengthen its governance and controls to assess and respond to risk of Modern slavery in its operations and Supply Chain relationships. KAU has conducted a comprehensive review around current sourcing, selecting, contracting and on boarding of suppliers to further build awareness to Modern Slavery Risk identification.

  1. KAU has developed specific policies to mitigate Modern Slavery risks in its operations and supply chains. These policies have been reviewed and approved by Senior management and are made available to KAU employees, contractors, and business partners.

    These policies are:

    Modern Slavery Policy
    Supplier Code of Conduct Policy
    Whistleblower Policy
  2. When onboarding new suppliers, applying a Modern Slavery risk assessment criterion, and adopting a risk-based approach. KAU’s compliance team manage the operational aspects of identifying Modern Slavery risks when engaging with new suppliers. Our process considers the potential risks of engaging with a supplier and include both a compliance review and a review of the Suppliers Modern Slavery policies and statements where they are available.
  3. Existing first tier suppliers are evaluated on a periodic basis to ascertain the levels of Modern Slavery risks. The assessment considers factors such as low skill labour by suppliers, goods manufactured in high-risk countries and services provided by suppliers using non-transparent contracting arrangements. KAU’s compliance team manage the operational aspects of identifying Modern Slavery risks when extending relationship with existing suppliers.
  4. All KAU and KNZ team members have been provisioned e-learning training to raise awareness of Modern Slavery. This includes Modern Slavery risks, practices, and requirements under the Modern Slavery Act. Training is provisioned upon commencement with the business and annually to all employees. From 2022 training completions are reported periodically to assist Managers to ensure compliance, although each Manager has full visibility at all times of employee training records, and this must be discussed quarterly as part of our Performance Management policy.

    All team members must notify our Compliance team immediately if they become aware of a potential act or an increased risk of Modern Slavery within business operations, supply chain or commercial partnerships.

Assessing and Reporting on effectiveness of actions taken by Kubota Australia

KAU has already commenced and intends to continue further developing frameworks and processes to appropriately review the effectiveness of KAU’s actions to assess and address modern slavery risks in KAU’s operations and supply chains.

KAU currently monitor compliance with our organizational policies and procedures through:

  • Internal audit and risk assurance reviews
  • Review of complaints raised under dispute resolution process
  • Review of concerns raised through whistleblower program
  • Centralised review of new supply contracts
  • Annual review of existing supply contracts

During the reporting period:

  • There were no reports or complaints received by KAU in relation to Modern Slavery
  • KAU completed and submitted number of reports to Law enforcement bodies and none of the matters were concerned on Modern Slavery risks.

KAU continuously review how we can effectively monitor modern slavery risks further under our 2021-2022 compliance program.

Consulting with entities that Kubota Australia own and Control

This Modern Slavery Statement covers all controlled entities of KAU. Each controlled entity relies on KAU for the resources they require for their operations. KAU provides and procure all goods, services, and personnel requirements. Therefore, all controlled entities work under the management of KAU.

This statement is made after due consultations with key stakeholders in KAU and its controlled entities, including the relevant Business Unit Leaders and their team members. Stakeholders have been provided with the opportunity in our business forums to share their insight on the processes implemented to manage Modern Slavery risks during the reporting year. KAU will continue to monitor and report on the effectiveness of this Modern Slavery Statement to the Board of Directors of KAU.

The Kubota Australia’s Modern Slavery Statement 2021 was approved by its Board of Directors on 21 January 2022.

Tetsu Kojima
Managing Director
Kubota Australia Pty Ltd