Slavery and Human Trafficking Statement for the Financial Year 2018

Published on 22/08/2019


This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”), and sets out the steps which Komatsu UK Limited (KUK) has undertaken during the previous financial year to ensure that slavery and human trafficking (“human rights abuse”) is not operating within either its own business or its supply chains, and the further steps which are to be taken going forward.  

Organisation's Structure

KUK is part of the global Komatsu Group, whose head office in Tokyo, Japan.  KUK manufactures medium-sized hydraulic excavators, sold mainly to the European market.   The Company’s financial year runs from 1st April to 31st March.

Our Supply Chains

We operate with a global supply base that provide KUK with parts, services and equipment from a direct supply chain of around 75 companies.  Our Supply chains can be extensive and can often involve a number of levels between raw materials entering the manufacturing process, through to delivery and use of the finished component by KUK.  

We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. 

KUK strives to ensure that it does not contribute towards human rights abuse through its supply chains.  The Company has a commitment to engage only those suppliers that uphold the same principles as KUK, and where necessary, implement corrective measures.  Where a supplier should fail to take steps to cease or prevent human rights abuse, Komatsu reserves the right to terminate our business relationship without any notice period.  

Activities to enhance our compliance with the Act commenced in 2016 and have continued through 2017 and 2018.  To date the following steps have been taken:

  • An annual risk assessment of our supply chain based on geography, products supplied and ownership, has been carried out, the outcome of which was deemed to be satisfactory.
  • We have received written confirmation from all of our suppliers affirming their compliance with the act. 
  • A member of the Purchasing Team, who has undertaken qualifications accredited by the Chartered Institute of Purchasing and Supply, has carried out further internal training on Modern Slavery for the relevant staff. 
  • As part of our regular supplier visit programme, staff have conducted open eye audits of Tier 1 supplier factories to monitor compliance with KUK expectations and legal requirements, and no issues have been identified.
  • All on-site contractors have submitted statements to confirm that they operate in compliance with the Modern Slavery Act, and where they have in place their own Modern Slavery Statement, a copy has been provided.

The KOMATSU Way and Komatsu’s Worldwide Code of Conduct

Komatsu defines its corporate value as “the sum total of the trust given to us by all our stakeholders and society”.   The KOMATSU Way is the Company’s “Mindset, belief, values, and code of conduct in writing that the Komatsu group employees should follow” and explains what is required from employees in order that the Company can achieve its corporate value. The KOMATSU Way requires compliance with the laws and rules of the business community, and to expand upon this, Komatsu has in place a Worldwide Code of Business Conduct (the Code) which all employees must follow.  In relation to Employment, the Code states that Komatsu Group companies shall not tolerate child labour or forced labour.  Where any deviation to the Code is found to be in existence, a proper investigation is required, and remedial action must be taken.  

There are contact persons in the organisation to whom whistle-blowers can report breaches of the Code, including information about possible human rights violations and infringements of labour standards.  No instances of child labour or forced labour have been reported or alleged in 2018.

Further Steps

In the 2019 financial year, focus on suppliers in relation to the legislation will continue.  In particular the following steps will be undertaken:

  • Annual risk assessments of our supply chain including any new partners and service providers.
  • Ongoing open eye audits of Tier 1 suppliers to monitor compliance with KUK expectations and legal requirements.
  • The Supplier Handbook, which is provided to all direct suppliers, will be updated in 2019 to include reference to modern slavery and human trafficking, and explain our expectations from suppliers.
  • An investigation will be undertaken into the use of suitable e-learning packages covering the Modern Slavery Act, to utilise for the future training of relevant employees.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Komatsu UK Limited’s slavery and human trafficking statement for the financial year ending 31st March 2019. 

Paul Blanchard 
Managing Director

22nd August 2019

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