Privacy Policy
Kubota Australia Pty Ltd, ACN 005 300 621, also trading as Kubota Australia Finance, (‘KAF’, ‘we’, ‘us’, ‘our’) is committed to protecting your privacy and the confidentiality of your personal and credit information (information). In handling your credit information, we are bound by, and comply with, the Privacy Act 1988, the Australian Privacy Principles (APPs) and the Credit Reporting Privacy Code (Code).
This privacy policy sets out how we collect and manage your information, how you can access that information if you wish and how you can complain if you are not satisfied with our policies and processes.
1. Collection and storage of personal information
We collect information from, and about, you to, as appropriate:
- respond to your enquiries about our finance products or insurances we can source for you
- to confirm your identity
- assess your credit application and provide you with the finance you require from us
- assess the application for finance made by a company of which you are, or were, a director
- assess your application to guarantee the repayment of finance we are considering providing
- provide customer support
- promote our finance products
- manage any complaints
- manage any business arrangements under which we provide or receive goods or services
We also use the information we collect to:
- manage your account
- develop new products, policies and procedures
- undertake market research
- obtain legal and compliance advice about our obligations
- meet our regulatory and legal obligations
The information we collect may include personal identification, contact details, financial information, lending and default history, banking details and transactions, personal and trade references and employment or business history, depending on the relationship you wish to have with us. If you choose not to provide this information, our ability to assist you may be restricted.
Wherever possible, we will collect your information directly from you, or from your broker, should you wish to apply for finance. We may obtain personal information about you from a third party, such as your accountant or banking institution, or a credit reporting body, for a particular purpose. Wherever possible we will tell you who we need to contact and why. However, if you are, or were, a director of a company applying to us for finance, we will collect information about you sourced from publicly available official corporate records and, if a current director, from a credit reporting body.We may also collect information from you if you choose to use our website to communicate with us. We will collect the information you provide, when you fill out a product or service application form or over the telephone or, through our interactive facilities, such as customer enquiry, customer rebate forms, or comment forms.In some circumstances, brokers, dealers, accountants, banking institutions, referees, external dispute resolution schemes, your agents and government bodies, and with your authorisation at the time, a banking transaction data service, may provide us with your information. The circumstances in which third parties provide us with information include purchase or service requirements, employment or finance applications, account management and complaints.We take steps to protect any information we collect so it will be safeguarded from misuse, loss, unauthorised access, use, disclosure or modification.
The law may require us to retain your personal information for a period of time after our business dealings have finished. It is securely stored and disposed of, or de-identified, when no longer required.
2. Website information collection
When you visit our website, our ISP host records a range of information, including your server address, domain name, the date and time of the visit and the pages viewed. This information may be collected by using cookies which is data sent to your web browser. This allows our site to interact more efficiently with your computer.If you disable the use of cookies, your use of our site may be affected. Information collected about your visit to our site is retained for statistical and website development reasons and is not in a form which would enable us to identify you.When visiting our site, you will not be required to provide us with any personal information unless you request information about our equipment or finance or respond to a promotion. If you do, we will ask you to provide contact details along with other information required to respond to your contact with us.We may also retain that information provided for product planning purposes. It may also be used for direct marketing purposes unless you tell us you do not wish to receive marketing material.
3. Use and disclosure
We use your information to provide you, or a company of which you are a director, with the finance required, consider your suitability to be a guarantor and perform other functions and activities associated with managing our relationship.
Those functions and activities can include our internal administration, credit assessment, account management, product or service development, compliance audits/reviews, marketing, complaints management, planning and research requirements as well as future offers of finance to you.
Where you, as an individual, apply for finance with us, or agree to act as a guarantor, you authorise how we may collect, use and disclose your personal and credit information in the Privacy Statement and Consent that we ask you to sign before we consider your application for credit or to be a guarantor. Where we collect or disclose information about you from or to another credit provider who is a member of the Australian Finance Industry Association (AFIA), we do so in accordance with AFIA’s National Credit Reference Scheme.
We will disclose your information to third parties only as the Privacy Act permits and where there is a valid reason to do so. All third parties must use your information only for the specific purpose for which we supply it.
Third parties may include:
- Employees, contractors, auditors and advisers
- Credit reporting bodies (CRB)
- Service providers (e.g. computer systems consultants, document custodians, mailing houses etc) to enable them to perform those services), including our service providers in Japan, USA, Germany, Thailand, Indonesia, South Korea, China where information is sent/stored
- Your agents, including your broker, where required
- Insurers, insurance brokers and insurance assessors
- Debt collection agencies
- Referees, where authorised
- Companies to which we are related
- Government authorities and law enforcement agencies, as required by law only.
We may also provide your information to, and receive your information from, Equifax Australia Information Services & Solutions Ltd, which is a credit reporting body (the CRB). We may:
- Disclose your information to the CRB for credit assessment or collections purposes
- Use information provided by the CRB for credit assessment or collections purposes, including:
- Your name, address and date of birth
- Current and previous credit account history
- Your personal or business credit score, depending on the nature of the credit application
- Default history
- Any court proceedings – summons, judgement and Bankruptcy actions
- Serious credit infringements history, covering fraudulently obtaining, or attempting to obtain finance or shown an intention to avoid repayment obligations
- Notify the CRB of any overdue payments, provided they are more than 60 days overdue, we have attempted to collect the payment and we have notified you of our intention to do so
- Notify the CRB of a serious credit infringement if we have reasonable grounds to believe you fraudulently obtained, or attempted to obtain, credit from us or that you have shown an intention to evade your obligations under the contract with us
- We will only do this if we have not been able to contact you over a 6 month period
- Ask the CRB to assess your eligibility to receive direct marketing material from us.
Any information shared with, or by, the CRB is held in electronic form, trackable through the CRB or our systems by time, date, account and user.
In addition, we may provide your identification details to both the CRB and RealAML Australia Pty Ltd trading as RealAML to:
- check those details with a document issuer or official record holder via third party systems to confirm your identity; and
- as circumstances require, confirm your identity and otherwise assist in our compliance with Australia’s Anti-Money Laundering and Counter-Terrorism Financing laws
Where information is provided to our service providers in Japan, USA, Germany, Thailand, Indonesia, South Korea, China and New Zealand, we require them to comply with our information management policies and procedures so your information has the same protections as if managed in Australia.
4. Information Access
You can access the personal and/or credit information we hold about you by contacting us in any of the ways shown in (6) below.
You can also access the information the CRB holds about you by contacting them for a copy of that information at:
Equifax Australia Information Services & Solutions Ltd
Online: www.equifax.com.au/understanding-your-credit-file
Postal: Address: PO Box 964, North Sydney NSW 2059
If any information is incorrect, out of date or incomplete, you have the right to have that information updated and corrected. If, for any valid reason, we refuse to correct your information, we will explain why.
5. Complaints and Concerns
Please contact us if you have any complaints or queries about how we manage your information or you no longer wish to receive marketing materials. You can contact us by mail, phone or email, as listed in (6) below.
If you lodge a complaint, our Internal Dispute Resolution Team will investigate your complaint. We will commence the investigation within 2 business days and provide you with a response within 14 business days. We will seek your agreement to a longer time if it is needed. We will keep you informed of the investigation process by phone or email at least once a week and provide you with a written response to your complaint within 30 days.
If you do not accept our response, you may take the complaint to our External Dispute Resolution Scheme. Australian Financial Complaints Authority, contact details are:
- Online: www.afca.org.au
- Email: info@afca.org.au
- Phone: 1800 931 678 (free call)
- Mail: Australian Financial Complaints Authority | GPO Box 3, Melbourne, VIC 3001
6. Obtaining our privacy policy
This privacy policy may change over time. You can obtain the current version from our website or by contacting us by any of the contact methods below.
- Email: privacy@kubota.com.au
- Address: Privacy Manager, Kubota Australia Pty Ltd25-29 Permas Way, Truganina, VIC 3029
- Phone: 1800 225 990
- Fax: 03 9394 4465
- Website: www.kubota.com.au
Anti-bribery Policy
Purpose
Kubota Australia Pty Ltd is committed to complying with the laws and regulations of the countries in which its businesses operate and acting in an ethical manner, consistent with the principles of honesty, integrity, fairness, and respect. Bribery and the related improper conduct referred to in this policy are serious criminal offences for both the company and any individuals involved. They are also inconsistent with Kubota Australia’s values. Laws prohibiting the types of improper payments covered by this policy apply in all the countries in which Kubota Australia has operations or engages in trading activities. Many laws, such as the Australian Criminal Code, the US Foreign Corrupt Practices Act and the UK Bribery Act, have application at home and abroad. The purpose of this policy is to:
(a) set out the responsibilities of directors, employees of Kubota Australia and its subsidiary companies, suppliers and agents acting on behalf of Kubota Australia in observing and upholding the prohibition on bribery and related improper conduct.
(b) provide information and guidance on how to recognise and deal with instances of bribery.
This policy applies to all directors, employees of Kubota Australia and its subsidiary companies, suppliers and agents acting on behalf of Kubota Australia.
Definition of Terms
“Bribe Offering” shall mean an act of offering, or proposing or promising to offer, money or another kind of benefit (“Bribes”) to a Public Official or a private individual citizen, in pursuit of unjust operational profits.
“Bribe Acceptance” shall mean an act of accepting, or a demand or promise to accept, a Bribe.
“Bribe Acceptance” shall mean an 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 the Kubota Australia and its subsidiaries could include.
A party insisting on receiving a commission or fee payment before committing to sign up to a contract with Kubota Australia and its subsidiaries.
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.
Above events are not intended to be exhaustive.
“Public Official” shall mean any of the following persons:
A public official of a government or a municipal government.
An official of an organisation de facto controlled by a government or a municipal government.
An official of an association established 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 to do government affairs..
Policy
Directors, employees of Kubota Australia and its subsidiary companies, suppliers and agents acting on behalf of Kubota Australia must:
(a) understand and comply with this policy
(b) 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
(c) not approve any offers, or make, accept, or request an irregular payment or other thing of value, to win business or influence a business decision in favour of the Kubota Australia and its subsidiaries
(d) comply with any reporting and approval processes for gifts, entertainment, or hospitality
(e) not offer or receive any gifts, entertainment, or hospitality to or from public officials outside policy
(f) obtain required approvals for donations and sponsorship
(g) maintain accurate records of dealings with third parties
(h) be vigilant and report any breaches of, or suspicious behaviour related to, this policy.
Directors and employees of Kubota Australia and its subsidiary companies:
Must not receive any gifts, entertainment, or hospitality from any party including suppliers and agents acting on behalf of Kubota Australia outside the KAU Conflict of Interest policy.
Maintain Accurate Records
(a) 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 payments.
(b) Internal control systems and procedures adopted to comply with this policy will be the subject of regular internal compliance reviews by the Compliance Officer to provide assurance that they are effective in mitigating the risk of non-compliance.
Reporting Breaches
Directors, employees of Kubota Australia and its subsidiary companies, suppliers and agents acting on behalf of Kubota Australia must report any breaches of, or suspicious conduct in relation to, this policy.
Reports should be made:
in accordance with the Kubota Australia’s whistleblower policy.
Consequences of a Breach
A breach of this policy by directors, employees of Kubota Australia and its subsidiary companies, suppliers and agents acting on behalf of Kubota Australia may be regarded as serious misconduct, leading to disciplinary action, which may include termination of employment or contractual agreements.
Breach of this policy may also expose an individual to criminal and civil liability and could result in imprisonment or in the imposition of a significant financial penalty.
Modern Slavery Policy
Purpose of policy
This policy affirms our commitment to contribute to ending all forms of modern slavery and outlines our approach to reducing the risk of modern slavery practices within our supply chains and operations. It is consistent with our Ethical Framework, that expects a culture of high ethical standards, including compliance with applicable laws, contractual and other obligations. As a result, this Modern Slavery Policy is part of the Ethical Framework. This Policy supports the Modern Slavery Act (Cth) 2018
Context
Modern slavery describes situations where coercion, threats or deception are used to exploit individuals and undermine or deprive them of their freedom. Kubota Australia (KAU) strives to use, insights gathered through its business activities to contribute to ending all forms of modern slavery by ensuring our own supply chains and operations don’t contribute to modern slavery practices, and to take appropriate action to respond to the humanitarian impacts of modern slavery
Scope of policy
This Policy applies to all employees, suppliers, and business partners of entities controlled by KAU, including Kubota Finance and Kubota New Zealand
Definitions
Modern Slavery Act 2018 (Cth) being the Commonwealth legislation (the Act) enacted by the Parliament of Australia on 29 November 2018 (and may be amended from time to time).
Modern slavery for the purposes of this policy is defined as including eight types of serious exploitation and outlined in Section 4[1]
Operations is defined as activity undertaken by KAU and any of its subsidiaries.
Partnership means all relationships between KAU and a Partner whereby KAU grants the Partner the possibility of using its name, emblem/logo or image in its communication and promotional materials, thereby potentially creating a public association of image between the Partner and KAU. This relationship includes arrangements of; sponsorships, cause-related marketing initiatives, and strategic alliances.
Risks of modern slavery practices means the potential for KAU to cause, contribute to, or be directly linked to modern slavery through its supply chains and operations.
Kubota Australia is the term used to refer to Kubota Australia Pty Ltd and its subsidiaries, not the broader Kubota Corporation.
Kubota People include any current:
Members of a Governance Body (members of the KAU board)
Employees.
Suppliers is defined as any organisation or person who provides us with goods or services, including their subcontractors, agents, related entities, and consultants.
Supply chains is defined as the products and services (including labour) that contribute to KAU’s own products and services. This includes products and services sourced in Australia or overseas and extends beyond direct suppliers
What is modern slavery
Modern slavery is defined by the Modern Slavery Act (Cth) 2018[2] to include eight types of serious exploitation and which can be understood as:
Trafficking in persons, which is the recruitment, harbouring and movement of a person for the purposes of exploitation through modern slavery. Exploitation also includes the prostitution of others or other forms of sexual exploitation, forced labour or services, slavery or practices like slavery, servitude or the removal of organs.
Slavery, which is where the offender exercises powers of ownership over the victim.
Servitude, which is where the victim’s personal freedom is significantly restricted, and they are not free to stop working or leave their place of work.
Forced labour, which is where the victim is either not free to stop working or not free to leave their place of work.
Forced marriage, which is where coercion, threats or deception are used to make a victim marry or where the victim does not understand or is incapable of understanding the nature and effect of the marriage ceremony.
Debt bondage, which is where the victim’s services are pledged as security for a debt and the debt is manifestly excessive or the victim’s services are not applied to liquidate the debt, or the length and nature of the services are not limited and defined.
The worst forms of child labour, which involves situations where children are: exploited through slavery or similar practices, including sexual exploitation; or engaged in hazardous work which may harm their health or safety, or used to produce or traffic drugs.
Deceptive recruiting for labour or services, which is where the victim is deceived about whether they will be exploited through a type of modern slavery[3]
KAU approach to limiting the risk of modern slavery practices
KAU will work proactively to reduce modern slavery within our supply chains and operations, and we expect all organisations we engage with to do the same.
Supply Chain
KAU Supplier Code of Conduct
We expect all existing and new Suppliers to comply with the principles set out in our Supplier Code of Conduct. Fundamental to the Supplier Code of Conduct is an expectation that all Suppliers operate in full compliance with the laws and regulations in the jurisdiction where the goods are sourced, procured or services are performed. Suppliers must use best endeavours to ensure that there is no modern slavery in their supply chains and operations. In the event Suppliers identify any occurrence of, or material risk of modern slavery in their supply chains or operations they are to take practical and effective steps to address that occurrence or risk. Suppliers must notify KAU as soon as practicable of any occurrence of, or material risk of modern slavery they have identified and notify relevant authorities where appropriate.
KAU’s contractual terms
Our contractual terms reflect Supplier obligations outlined in the Supplier Code of Conduct, including compliance with Australian modern slavery laws and those foreign modern slavery laws that apply in the locations in which they operate.
Supply chain mapping and risk assessment
We encourage our suppliers to complete a Corporate Social Responsibility questionnaire which contains questions relevant to modern slavery. Answers to this questionnaire will provide us with a greater understanding of the risk of modern slavery within a supplier’s supply chains or operations and enable us to work with a supplier to reduce the risks identified. We will actively and progressively improve our understanding and oversight of all tiers of our supply chains
Operations
Modern Slavery Policy
KAU maintains a Modern Slavery Policy (this Policy) outlining our approach to reducing the risk of modern slavery practices within our supply chains and operations. The Policy provides guidance on the steps KAU takes to work with suppliers to reduce risks and the range of supports available for when a KAU person becomes aware that someone is at risk of or affected by modern slavery practices.
Incorporating modern slavery into other policies
When existing policies undergo policy review or new polices are under development, policy owners are required to identify existing modern slavery commitments that can be enhanced, or where modern slavery protections can be incorporated.
Human Resources
We are committed to ensuring the health, safety and wellbeing of our workforce and we maintain a suite of policies that are informed by and compliant with Australian workplace occupational health and safety law.
Supplier Screening
The Supplier Code of Conduct requires KAU to complete a supplier screening tool before entering into a partnership with another organisation. Prospective suppliers automatically disqualify from public association with KAU if they are knowingly or deliberately engaged in activities running counter to:
The Movement’s objectives and Fundamental Principles
Principles of International Humanitarian Law
Internationally recognised standards of human rights, labour rights and protection of health
Communications, Engagement and Training
KAU team members will be provided communications and training opportunities to enhance their understanding of the causes and humanitarian impact of modern slavery, the Modern Slavery Policy and our approach to limiting the risk of modern slavery within our supply chains and operations. KAU team members with purchasing responsibilities are provided additional training on the KAU Supplier Code of Conduct, Corporate Social Responsibility tool and supporting suppliers to undertake due diligence. KAU team members who initiate and periodically review relationships with third parties are provided with training to apply due diligence processes.
Continuous improvement approach to reducing the risk of modern slavery
We are committed to applying a continuous improvement approach to how we reduce the risk of modern slavery practices within our supply chains and operations. We will seek feedback from KAU team members, Suppliers, and other parties regarding the success or otherwise of the actions we have taken to reduce the risk of modern slavery.
By 31 December each year we will publish a Modern Slavery Statement that outlines the steps we have taken over the reporting year to identify where our supply chains and operations may be contributing to modern slavery practices, and the actions we have taken to minimise these risks.
Reporting Concerns of modern slavery
Reporting unethical or unlawful conduct
A key part of supporting ethical standards is enabling KAU team members and suppliers to feel free and safe to speak up when there are reasonable grounds to suspect that KAU team members or any of KAU’s suppliers are not acting ethically or in accordance with laws and obligations. Concerns about compliance or ethical issues or illegal or unethical activities are to be reported according to our whistleblower policy
Responding to concerns of modern slavery practices
The Australian Federal Police is responsible for investigating suspected cases of modern slavery and can be contacted on 131 237 to discuss or report a suspected case. Contact can be made anonymously.
In an emergency and if someone is in immediate danger, please call Triple Zero (000) for police assistance
[1] Modern Slavery Act (Cth) 2018. Available from : https://www.legislation.gov.au/Details/C2018A00153
[2] Department of Home Affairs. Commonwealth Modern Slavery Act 2018: Guidance for reporting entities (2018). Available from https://modernslaveryregister.gov.au/resources/
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 authorised 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.
Kubota Australia’s Risks of Modern Slavery Practices
Supply Chain
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.
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 utilise employment agencies. All agencies utilised 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.
In line with our intentions discussed in the initial MS statement of KAU in 2021, these include
- 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 - 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.
- 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.
- 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 organisational 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