Kawasaki Heavy Industries, Ltd.

Based on public information, there is evidence of the President’s commitment to Corporate Governance. However, the published commitment to the ethical / anti-corruption agenda is assessed to be weak.

Based on public information, there is no readily available evidence that the President demonstrates a strong personal external-facing commitment to the ethics and anti-corruption agenda of the company, for example through public speeches / interviews or involvement with industry anti-corruption initiatives.

Based on public information, there is no readily available evidence that the President demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is evidence of a list of basic principles of corporate ethics, and also a statement that these underpin corporate ethics as addressed in the Compliance Guidebook. However, these principles do not cover the range sought by the question other than (implicitly) honesty (‘we do not hide the truth’) and integrity (‘do the right thing’). Accountability is only mentioned with respect to financial reporting. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company is a member one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption.

Based on public information, there is evidence that the President is the head of the Corporate CSR Committee, which is a part of the Compliance Promotion Structure. However, few details are provided with regard to the full responsibilities held by this Committee. The company therefore scores 1.

Based on public information, there is evidence that the CSR structure involves the President as head of the Corporate CSR committee, with Business Division Directors with responsibility for the company CSR policies. However, the role and name of the person managing the Head Office CSR Planning group is unclear.

Based on public information, there is evidence that the President is the head of the Corporate CSR Committee, which has responsibility for compliance reporting and followup. Thus it has review functions at some level; whether these extend to review of the entire ethics and anti-corruption agenda is not known, neither is the frequency of such potential review.

Based on public information, there is no readily available evidence that a formal written plan guides the review of the ethics and anti-corruption agenda by the Board or senior management.

Based on public information, there is no readily available evidence that a formal process is in place to review policies and procedures in response to actual or alleged instances of corruption. TI notes that the company has published information on an alleged case of bid rigging, which was not further prosecuted, and the company clearly recognises the importance of further efforts to ensure compliance; however, there is no evidence on formal process in place.

Based on public information, there is evidence of a comprehensive risk management process across the company, with compliance risks identified. However, there is no readily available evidence of mitigation plans. The company therefore scores 1.

Based on public information, there is evidence of a comprehensive risk management process across the company. The risks identified include both continuous risks and those that would be more relevant at a decision-making stage. However, there is limited readily available evidence of the circumstances under which it is applied. The company therefore scores 1.

Based on public information, there is evidence that the Global Business Ethics Guideline suggests the company is aware of corruption risk relating to agents; however, there is no readily available evidence of due diligence procedures relating to their appointment or reappointment.

Based on public information, there is evidence that the Global Business Ethics Guideline suggests that the company is aware of corruption risk relating to agents, there is no readily available evidence of contractual arrangements put in place to address this risk.

Based on public information, there is evidence that the Global Business Ethics Guideline suggests that the company is aware of integrity issues relating to suppliers; however, there is no readily available evidence of contractual arrangements put in place to address corruption risk.

The company has informed TI that it does not engage in offset contracting.

The company has informed TI that it does not engage in offset contracting.

Based on public information, there is evidence that the company has an anti-corruption policy in place although there is limited readily available evidence on the prohibition of the various forms of corruption. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company’s anti-corruptuion policy is explicitly one of zero tolerance. Evidence suggests that an anti-corruption policy is provided as part of the Group Compliance Guidebook, but this is not publicly available.

Based on public information, there is evidence that an anti-corruption policy is provided as part of the Group Compliance Guidebook, but this is not fully publicly available, and thus cannot be properly evaluated. The company therefore scores 1. It is noted that anti-corruption is also promoted as part of the Global Business Ethics Guideline.

Based on public information, there is evidence that an anti-corruption policy is provided as part of the Group Compliance Guidebook, but this is not fully publicly available, and thus cannot be properly evaluated. The information that is provided is assessed to be understandable. The company therefore scores 1. It is noted that anti-corruption is also promoted as part of the Global Business Ethics Guideline.

Based on public information, there is evidence that the anti-corruption policy within the Group Compliance Guidebook is distributed to officers, employees, and temporary staff. It is not explicitly stated that the policy applies to every officer or employee, however.

Based on public information, there is evidence that an anti-corruption policy is provided as part of the Group Compliance Guidebook, but this is not publicly available. This may contain greater detail on conflict of interest situations. It is noted that avoidance of conflicts of interest is also promoted as part of the Global Business Ethics Guideline. There is insufficient detail on the policies applied to be able to award marks on this question.

Based on public information, there is evidence that in the Global Business Ethics Guideline reference is made to gifts not being given or received if they are ‘excessive’; however, there is no further detail on what this means in practice. The company therefore scores 1.

Based on public information, there is evidence that in the Global Business Ethics Guideline, reference is made to hospitality (entertainment) not being given or received if they are ‘excessive’; however, there is no further detail on what this means in practice. The company therefore scores 1.

Based on public information, there is evidence that an anti-corruption policy is provided as part of the Group Compliance Guidebook, but this is not publicly available, and thus cannot be properly evaluated, which is necessary for this question. It is noted that anti-corruption is also promoted as part of the Global Business Ethics Guideline.

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent. Evidence suggests the company carries out charitable activities.

Based on public information, there is evidence that an anti-corruption policy is provided as part of the Group Compliance Guidebook, but this is not publicly available. However, it is stated that the guidebook contains illustrative scenarios to explain the key points. Analysis of this material itself through open publication may enable a better score. The company therefore scores 1.

Based on public information, there is evidence of compliance training, but not of anti-corruption training specifically. The company therefore scores 1.

Based on public information, there is evidence that the company’s compliance training is available online and has been completed by 99% of eligible staff.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is evidence that employees can report suspected corrupt activity using an in-house reporting system. TI understands that reports made using this system are directed to an external lawyer for investigation. However, there is no evidence of other whistleblowing channels or the option for employees to report anonymously. The company therefore scores 1.

Based on public information, there is insufficient evidence to suggest employees across geographies have access to the external channel for reporting concerns.

Based on public information, there is evidence of the provision of an external lawyer to report to, and who reports back to the employee. TI assessed this to be an illustration of a supportive mechanism. Furthermore, there is evidence of allusion to ‘provisions to protect whistleblowers’ which undergo self-assessment, yet no further detail is provided. There is also some evidence of the data on reporting being collated and categorised. The company therefore scores 1.

Based on public information, there is evidence that employees can consult and seek advice from internal sources (their supervisor or relevant department), and an external lawyer.

Based on public information, there is no readily available evidence of an explicit commitment to non-retaliation; however, there is reference to ‘provisions to protect whistleblowers’ which are subject to self-assessment, but there is no further detail on this.