DCI Company Scorecard: Komatsu Ltd.

Leadership and Organisational ControlA

1.1
Tone from the Top
1.2
Anti-Corruption Policy
1.3
Board Oversight
1.4
Programme Management

Internal ControlsE

2.1
Risk Assessments
2.2
Internal Audit
2.3
Investigations Procedure
2.4
Quality of Investigations
2.5
Self-Reporting Material Findings
2.6
High-Level Data on Employees

Support to EmployeesE

3.1
Anti-Corruption Training
3.2
Tailored Anti-Corruption Training
3.3
Measuring Effectiveness
3.4
Employee Incentives
3.5
Commitment to Support Employees
3.6
Non-Retaliation Policy
3.7
Whistleblowing Channels

Conflict of InterestE

4.1
Conflict of Interest Policy
4.2
Conflict of Interest Procedures
4.3
Public Sector Appointments
4.4
Contracted Politicians

Customer EngagementF

5.1.1
Political Contributions Policy
5.1.2
Political Contributions Transparency
5.1.3
Charitable Donations and Sponsorships
5.2.1
Responsible Lobbying Policy
5.2.2
Lobbying Aims and Topics
5.2.3
Lobbying Expenditure
5.3.1
Gifts and Hospitality

Supply Chain ManagementE

6.1
Procurement Department Involvement
6.2
Supplier Due Diligence
6.3
Anti-Corruption Standards for Suppliers
6.4
Anti-Corruption Standards for Supply Chain
6.5
High-Level Data on Suppliers

Agents, Intermediaries and Joint VenturesF

7.1.1
Policy on Agents
7.1.2
Due Diligence on Agents
7.1.3
Ulimate Beneficial Ownership of Agents
7.1.4
Anti-Corruption Standards for Agents
7.1.5
Agent Incentives
7.1.6
Publishing Details of Agents
7.1.7
High-Level Data on Agents
7.2.1
Due Diligence on Joint Ventures
7.2.2
Anti-Corruption Standards in JVs
7.2.3
Preventing Corruption in Joint Ventures

OffsetsF

8.1
Offsets Policy
8.2
Due Diligence on Offsets
8.3
Publishing Details of Offset Brokers
8.4
Publishing Details of Indirect Offsets

High Risk MarketsC

9.1
Market Risk Assessment
9.2
Subsidiaries and Holdings Transparency
9.3
Beneficial Ownership Transparency
9.4
Transparency of Major Customers

State-Owned Enterprisesna

10.1
SOE Transparency of Shareholder Voting Rights
10.2
SOE Commercial and Public Policy Objectives
10.3
SOE Board Composition
10.4
SOE Audit Committee Composition
10.5
SOE Asset Transactions Transparency

Points: 2/2

Points: 1/2

Points: 0/2

Points: NA