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Corporate Governance

Modern Slavery Statement

This statement covers the activity of Kubota Engine America Corporation (“KEA” or the “Company”), for the year ending December 31, 2023.

KEA was incorporated as of September 2, 1997, under the laws of the State of Illinois. The Company is a wholly owned subsidiary of Kubota North America Corporation (KNA), which is wholly owned by Kubota Corporation (KBT), a Japanese corporation and the principal manufacturer of the Company’s products. The company purchases the majority of its products from KBT on a contract basis.

KEA is working to ensure that it does not commit or assist violations of human rights in either its own company business or through its supply chains and explain its activities for the abolition of modern slavery below.

STRUCTURE

KEA is located at 505 Schelter Road, Lincolnshire, IL  60069.  The Company engages in the import, sale, distribution, and servicing of industrial diesel engines and gasoline engines and other related parts and accessories.   With more than 20 years since KEA was formed, the KEA employee base has grown to over 115 employees.  KEA relies on an extensive engine and generator distribution network, along with over 1,200 dealers in North America, South America, and the Caribbean to support our customers.

SUPPLY CHAIN

KEA maintains a diverse network of suppliers from around the world.  Our main source of supply for engines, generators and parts is our parent company based in Japan.  This covers about 90% of our supply chain.  The remainder of our supply chain is comprised of manufacturers of parts and various other services that contribute to supporting our operations.  In order to meet the demand for KEA engines and parts, we annually procure goods and services worth more than $849 million from our suppliers.   As of the year ending on December 31, 2023, we had a supply chain comprising approximately 38 active suppliers for the year.  KEA places significant importance on collaborating with suppliers that uphold Kubota values and adhere to principles relating to modern slavery and human rights, as described below

POLICIES AND DUE DILIGENCE

KBT has a number of policies that apply to KEA, including the “Kubota Group Human Rights Policy”, the “Kubota Group Charter for Action”, the “Kubota Group Code of Conduct” as well as the “Kubota Group CSR Procurement Guidelines”.

  • Kubota Group’s Human Rights Policy outlines KEA’s commitment to respect internationally recognized human rights in line with the International Bill of Human Rights and the ILO Declaration of Fundamental Principles and Right at Work, including the prohibition of child labor and forced labor. This policy is accessible here:  Respecting Human Rights | relationships with Society | Kubota Global Site
  • Both Kubota Group’s Group Charter for Action and Code of Conduct underscores KEA’s commitment to conducting its corporate activities with high moral standards and respecting human rights. This policy is accessible here:  Kubota Group Charter for Action & Code of Conduct | Relationships with Employees | Kubota Global Site
  • Kubota Group’s CSR Procurement Guidelines apply to all Kubota Group’s business partners, including KEA’s business partners. These Guidelines request the KEA’s business partners not only comply with laws and corporate ethics, but also that they base their activities on the Universal Declaration of Human Rights.  This includes the prohibition on the use of forced labor and child labor by KEA business partners.  These Guidelines are available here:  Procurement Policy | relationships with Society | Kubota Global Site

The parts of its business and supply chains that carry a risk of forced labor or child labor being used and the steps it has taken to assess and manage that risk

KEA recognizes the potential forced labor risks associated with its business operations and supply chains, both domestically in the United States as well as internationally.  KEA is committed to understanding and addressing risks of forced labor and child labor in its supply chains and plans to implement measures to begin more accurately assessing these risks.

The Kubota Group, including its manufacturing companies, assessed the potential human rights risks in its business activities and across supply chains, including assessing risks of forced labor and child labor.  Only certain Kubota Group companies participated.  However, KEA sources many of its products from KBT and other Kubota Group companies and so the risks identified by KBT and other Kubota Group companies also apply to KEA.

The human rights risk assessment process is available online at https://www.kubota.com/sustainability/society/rights/index.html

KEA’s approach to tackle Modern Slavery practices

KEA has taken steps to strengthen its governance and controls to assess and respond to risks of Modern Slavery in its operations and Supply Chain relationships.  KEA recognizes the potential modern slavery risks associated with its business operations and supply chains, both domestically in the U.S. as well as internationally.

Through the Kubota Charter for Action and Code of Conduct policies we address having an environment that is free of any forced labor conditions and adherence to child labor laws.  This Code of Conduct is included as part of our Employee Handbook which all staff are required to acknowledge.   Our business policies include a Whistleblower Policy, Equal Employment Opportunity, Harassment prevention policies and more.

The KEA workforce resides within the United States and includes expats from Japan working here on appropriate VISA’s.   When sourcing staff to join our organization we use reputable agencies in addition to postings on our own company website, state government websites, and other key employment websites.  All new members joining the company follow standardized background checks and screening procedures.  Consequently, KEA believes that it possesses robust systems and controls to effectively manage any potential risks of modern slavery arising from our employment practices.

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

KEA currently monitors compliance with our organizational policies and procedures through:

  • Contractual warranties from suppliers regarding compliance with all applicable laws and regulations
  • Internal Audit and risk assurance reviews
  • Review of complaints raised through our open door policy
  • Review of concerns raised through whistleblower program
  • Centralized review of new supply contracts
  • Annual review of existing supply contracts

During the reporting period there were no reports or complaints received by KEA in relation to Modern Slavery.

This statement is made after due consultations with key stakeholders in KEA 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.  KEA will continue to monitor and report on the effectiveness of this Modern Slavery Statement to the Board of Directors of KEA.

The KEA Modern Slavery Statement 2023 was approved by its Board of Directors on May 24, 2024.

In accordance with the requirements of the Act, and in particular section 11 thereof, I attest that I have reviewed the information contained in the report for the entity listed above.  Based on my knowledge, and having exercised reasonable diligence, I attest that the information in the report is true, accurate and complete in all material respects for the purposes of the Act, for the reporting year listed above.