Voluntary Tax Transparency Code Report

Introduction

Kubota Australia Pty Ltd (Kubota Australia) is Australia’s leading supplier of agriculture, construction and power equipment, operating in Australia for over 45 years. It is part of the global Kubota Group of companies.

Since its foundation in 1890, the Kubota Group 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. Today, the world faces many challenges in the areas of food, water and the environment, which are indispensable for human beings. The Kubota Group 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.

This report provides an overview of Kubota Australia’s tax strategy, governance and tax contributions made to Australian State and Commonwealth governments. The information provided in this Report is released on a voluntary basis in accordance with the recommendations and guidelines contained in the Board of Taxation’s Voluntary Tax Transparency Code (the Code).

Kubota Australia has chosen to voluntarily disclose this information, which is consistent with the Australian Government’s efforts to promote tax transparency. Kubota Australia has made this commitment to transparency because it believes it is important that companies help build trust in society by being transparent about how and where they pay taxes.

Shubhodita Pandey

Assistant General Manager Finance

Kubota Australia Pty Ltd

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Part A Disclosures

The Part A Disclosures required of Kubota Australia by the Code are:

• a reconciliation of the accounting profit to income tax expense;
• a reconciliation from income tax expense to current year income tax payable; and
• Kubota Australia and Kubota Group’s effective tax rates.

Kubota Australia published its tax disclosures in Note 13 of its 2022 and 2023 Financial Reports. The tax reconciliations in Note 13 form the basis of Kubota Australia’s Part A disclosures for the Code (particularly reflected in response to question 1 below).

1. Reconciliation of accounting profit to income tax expense

2. 2. Reconciliation from income tax expense to current year income tax payable

   Reconciliation from income tax expense to current year income tax payable	31 Dec 2023 AUD $000	31 Dec 2022 AUD $000
   Income tax expense	12,720	12,966
   Movements in temporary differences	2,263	978
   Adjustment for permanent differences	Nil	nil
   Adjustment for Transfer Pricing Advanced Pricing Arrangement	Nil	nil
   Adjustment to prior year under/ overs for provisions	35	255
   Income tax paid	15,018	14,199

   Income tax expense is different to income tax payable, as income tax expense (an accounting concept) reflects amounts of accounting income which are assessable for tax / amounts of accounting expenditure which are deductible for tax, irrespective of when that assessment or deduction arises. Income tax payable reflects amounts which are assessable or deductible in the current year, which does not always align with the timing for these amounts being recognised in the income statement.

3. Accounting effective company tax rates for Kubota Australia and Kubota Group

The above effective tax rates (ETRs) have been calculated as income tax expense divided by accounting profit for the Australian Kubota accounting consolidated group and the global Kubota accounting consolidated group.

The 2023 and 2022 Australian ETRs are 29.68% and 29.35% respectively. This reflects the impact of permanent adjustments in respect of non-deductible entertainment and subscriptions which decrease the ETR below the headline Australian income tax rate of 30%.

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PART B Disclosures

Part B of the Code prescribes minimum disclosure standards in relation to Kubota Australia’s:

• tax policy, strategy and governance;
• total tax contributions;
• international related party dealings.

4. Approach to tax strategy and governance

Kubota Australia is committed to achieving the highest standards in the areas of corporate governance and business conduct and its tax responsibilities are in line with this commitment. Kubota Australia has established a group Tax Governance Framework governing its tax strategy, which was reviewed and approved by the Board in 2017. The Board meeting in November 2023 reviewed and approved the updated version for 2023. It strongly believes in tax governance and has taken various actions to ensure that it follows best practice both on governance and transactional data.

Actions taken by Kubota Australia on “best practice” tax governance

• A Tax Governance Framework document has been prepared and endorsed by the Board and is operational across Kubota Australia. The responsibilities imposed under the framework are carried out by experienced professionals who also draw on the use of external advisors.
• Kubota Australia has implemented appropriate internal controls at a Board and managerial level in relation to the identification and management of tax risk, and a framework for escalation of tax matters from business units to the Kubota Australia Board as necessary.
• Kubota Australia has engaged external advisors to undertake separate corporate income tax, GST and Fringe Benefits Tax operational assessments. The results of these assessments indicated that Kubota Australia operates within a robust, clearly defined control environment.
• Kubota Australia dedicates appropriate resources to managing its tax obligations and has always been able to meet ATO compliance obligations and requests within the timeframes granted. The ATO has previously rated Kubota Australia as a low risk taxpayer under its risk-categorisation framework.

5. Total tax contribution summary

The table below provides an overview of all the Australian Federal and State taxes paid and collected by Kubota Australia Pty Ltd in the 31 December 2023 income year (with comparatives to the 31 December 2022 and 31 December 2021 years).

6. Information about international related party dealings

Kubota Australia Pty Ltd engages in various dealings with international related parties. Kubota Australia discloses these dealings at Note 28 of its Financial Report. Material dealings during the year included:

• Purchases of goods from related parties located in Japan, Korea, Thailand, United States of America, Germany, France, Norway and Spain.
• Payment of a fee for management services received from a related party in Japan.
• Kubota Australia established a New Zealand subsidiary in 2019. Kubota Australia raised a fee for Management services in support of New Zealand operations.

Kubota Australia Pty Ltd and its related parties regularly review their transfer pricing policies to ensure their international related party dealings are conducted in accordance with the arm’s length principle.

7. ATO public tax transparency disclosures

Australia’s public tax transparency laws require the ATO to publish specific tax return information of public companies and foreign-owned companies with total income of $100 million or more, and Australian-owned private companies with total income of $200 million or more.

The ATO published data for the 2022-23 income year in September 2024. This would have included the following information in relation to Kubota Australia Pty Ltd based on its lodged income tax return for the year ended 31 December 2023:

KUBOTA AUSTRALIA

PRIVACY and CREDIT REPORTING POLICY

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ANTI-BRIBERY AND CORRUPTION

KAU

Purpose

Kubota Australia Pty Ltd (Kubota) 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’s values. Laws prohibiting the types of improper payments covered by this policy apply in all the countries in which Kubota 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 and its subsidiary companies, suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota in observing and upholding the prohibition on bribery and related improper conduct.

(b) provide information and guidance on how to recognize and deal with instances of bribery.

This policy applies to all directors, employees of Kubota and its subsidiary companies, suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota.

Definitions

“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.

Some indications of Bribery that may arise during working for or providing services to Kubota 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 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 association established by a government or a municipal government

an official of an organization de facto controlled by a government or a municipal government

an officer or staff of a public international organization

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 and its subsidiary companies, suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota 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 favor of Kubota 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 and its subsidiary companies:

Must adhere to parameters, benefit limits and other requirements of Kubota's Conflict of Interest Policy and Procedure in respect to the proposed or actual receipt of any gifts, entertainment or hospitality from any party, including suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director, secretary or employee of that corporation) that has, or proposes to, enter into a Dealership Agreement.

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

Due diligence and contract management

Kubota team members, including directors and employees, when contracting with a third party, must undertake and ensure completion of relevant and appropriate due diligence in advance of the making of a contract.  Due diligence must be conducted in accordance with Guidelines determined by each department and/or any guidelines provided by Kubota, as amended from time to time.  Contracts may only be executed by those with the authority and power to do so in alignment with Kubota’s Delegation and Authority Schedule, as amended from time to time.

Reporting Breaches

Directors, employees of Kubota and its subsidiary companies, suppliers and agents acting on behalf of Kubota as well as any person or corporation (including a director or secretary of that corporation) that has entered into a Dealership Agreement with Kubota 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[1]

Consequences of a Breach

A breach of this policy by directors, employees of Kubota and its subsidiary companies, suppliers and agents acting on behalf of Kubota 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

[1] https://kubota.com.au/our-company/the-story/

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WHISTLEBLOWER PROTECTION POLICY AND PROCEDURE

Purpose

This Policy supports compliance with the Treasury Laws Amendment (Enhancing Whistleblower Protections) Bill 2019 (Cth). It aims to create a safe way to report wrongdoing, to protect whistleblowers, and those that are the subjects of yet to be investigated and substantiated concerns from adverse action, discrimination and victimisation. The Policy provides a framework to deal with and remedy reported matters.

This policy, along with any revisions made over time, is accessible to officers and employees in the ‘Policies, Procedure and Guidance’ folder on the shared drive and SharePoint intranet. It is also made available to other stakeholders through our websites. Introductory training on whistleblowing is provided to all new staff at Kubota Australia from the date of policy adoption.

Scope/ Eligibility

This Policy extends to serious wrongdoing that occurs before or after the commencement of this Policy.

A team member, former team member and their relatives, dependents, spouse or associates and suppliers may be a whistleblower.

Policy

What to report

Should you have reasonable grounds or belief to suspect that misconduct has occurred, or that an improper state of affairs or circumstances exist within Kubota Australia you may choose to make a report. The subject of any report may include current or former team members (including employees and contractors), officers or Board members of Kubota Australia.

Misconduct may include, but is not limited to:

• Breach of specific legislation
• Dishonest, corrupt or illegal activities
• Serious breach of Policies and Procedures, including serious risks to health and safety
• Fraud, theft, money laundering or misappropriation
• Offering or accepting a bribe
• Damage/ sabotage
• Conduct that is likely to contribute to, or likely to be considered as, a form of Modern Slavery
• Harassment, discrimination, bullying or victimisation
• Instruction to cover up or attempt to cover up serious wrongdoing

Personal work-related grievances are excluded from the protections of the whistleblowing regime and this Policy, except in specific circumstances. This includes when the disclosure has 'significant implications' for a Regulated Entity or another Regulated Entity, and such implications do not relate to the whistleblower themselves.

Protected Disclosure/ Report

A “Protected Disclosure” is a report made in accordance with this Policy. Nothing in this Policy is intended to abrogate or diminish any additional or alternative protections which may be available at law. To be protected under this Policy, a whistleblower must:

• be acting with reasonable belief that the information in the allegation is true or likely to be true
• make the disclosure in accordance with this Policy; and
• not have engaged yourself in illegal or serious misconduct in relation to the conduct you are reporting.

Who to report to

Depending on a range of circumstances, you may choose to make a report internally to Kubota Australia or to Kubota Group Global Whistleblowing Hotline. See the Procedures section regarding who to report to, in what format and the information to include in your report.

Alternatively, you may determine that it is reasonable and necessary for you to make your report directly to relevant authorities or external entities, such as:

• Kubota Australia's auditor
• ASIC
• APRA
• ATO
• Relevant Ombudsman
• Police
• Journalist (so long as other steps have been taken first and there is a public interest or public emergency)
• Parliamentarian (so long as other steps have been taken first and there is a public interest or public emergency)

Protections Investigation and findings

Kubota Australia shall apply principles of procedural fairness and natural justice to the conduct of any investigation and resultant findings arising under this Policy.

Duty not to disclose identity

A team member to whom a report has been made, must not disclose either a whistleblower's identity, or any information likely to lead to the identification of the whistleblower. The only exceptions are where:

• the identity of the whistleblower is disclosed with the consent of the whistleblower, is provided to ASIC, APRA or the AFP, or is given to a lawyer in order to obtain legal advice or representation; and
• information likely to lead to the identification of the whistleblower (but not the whistleblower's identity) is disclosed because it is reasonably necessary for the purpose of investigating the matter, and the person takes all reasonable steps to reduce the risk that the whistleblower will be identified.

Protection from discrimination and victimisation

The whistleblower/s, nor the person/s who are the subject of a yet to be investigated and substantiated concern must not be treated adversely or discriminated against in any aspect of

employment and must not be victimised. Refer to the Harassment, Discrimination and Bullying Policy and relevant legislation for further information.

Limitation of Policy

Kubota Australia have no ability to offer whistleblower/s immunity against criminal or civil legal action that may be taken against them.

Procedures

Who to report to

Depending on a range of circumstances, you may choose to make a report internally to Kubota Australia or to Kubota Group Global Whistleblowing Hotline. You may make a report to:

• The nominated Whistleblower Protection Officer, currently the Head of Compliance and Internal Control.
• A General Manager on the understanding that they will need to refer this to our nominated Whistleblower Protection Officer.
• An officer of Kubota Australia (such as a Board member).
• The Assistant Managing Director should the subject of complaint be the Head of Compliance and Internal Control.
• Care of whistleblower@kubota.com which is received by our nominated Whistleblower Protection Officer.
• Anonymously to: Kubota Australia Pty Ltd, Whistleblower Protection Officer, 25-29 Permas Way, Truganina, VIC, 3029.
• Kubota Group Global Whistleblowing Hotline:

1. https://kethicspoint.com for PC
2. https://kubotaglobalmobile.ethicspoint.com for smart devices

Where the subject of the report is the Whistleblower Protection Officer, the report should be made to the Assistant Managing Director (who will assume, or delegate to an external professional, all case management duties of the Whistleblower Protection Officer). Should the Assistant Managing Director also be implicated, the report should be made to Kubota Australia's Managing Director (who will assume, or delegate to an external professional, all case management duties of the Whistleblower Protection Officer and Assistant Managing Director). Where the Managing Director is implicated, the report may be directed to the Kubota Australia Board or Kubota Group Global Whistleblowing Hotline.

Alternatively, you may determine that it is reasonable and necessary for you to make your report directly to relevant authorities or external entities. Contact the relevant authority/s or entity/s for detailed information or refer to Whistleblowers information contained on their website/s.

Content of report

Your report may be made verbally or in writing. It is strongly preferred that you make a report in writing to ensure clear communication and to enable the best possible management of the matter.

Information you should pass on in your report should include:

• date of report
• identity of reporter (if disclosed/ known)
• substance of report
• any dates or details of when, where or how the reportable conduct occurred
• the identity or level of seniority of the person/s who are the subject of the report the perceived level of risk or gravity of the reportable conduct
• any other pertinent matters or

Receipt of reports

If you receive a Whistleblower report, you must ensure it is conveyed to the Whistleblower Protection Officer expediently. It is recommended that you pass on the report within 24 hours, or sooner where it would be assumed the matter would be urgent or involves a potential emergency.

Once you have passed on the report, you should take no further action. You will generally not be kept updated as to the status of the report. You must not discuss the report further and must maintain confidentiality at all times.

Investigation Process

Where a Whistleblower Report is made internally, or Kubota Australia become aware of the substance of a report that is made externally, the Whistleblower Protection Officer will ensure that an investigation is undertaken in a timely manner. Where there is sufficient information to do so, an investigation will be undertaken to the full extent possible based on the information contained in the allegation or level of awareness of the substance of any concern/s.

The Whistleblower Protection Officer (or alternate as outlined above if the Whistleblower Protection Officer or their Manager are implicated) will:

• Undertake a preliminary review of the
• Determine if there is sufficient information to conduct an
• Determine if an external professional organisation should be engaged to case manage and/or conduct the investigation and/or provide findings and recommendations as to appropriate action.
• Create a plan for the investigation, inclusive of any witnesses to be contacted, information to be sourced, professional advice (e.g. legal, taxation, etc) to be sought and indicative
• Conduct the investigation or oversee that it is
• Ensure the findings of the investigation are clearly
• Review and provide recommendations, or ensure any external organisation provides recommendations, to the Managing Director/ Assistant Managing Directors based on the specific individuals involved or systemic matters and risks.
• Recommendations can include any course of action from disciplinary action to referral to appropriate authorities.
• Where appropriate and relevant, enter risks into the Kubota Australia's Risk Management framework for management.
• Maintain, or direct the maintenance of, all appropriate

Findings and actions

The Managing Director shall make any final decision and determine any actions based on the findings and recommendations. The Managing Director is not required to adopt recommendations and shall determine any actions. The Managing Director is responsible for ensuring (via delegation or directly) that actions are implemented.

Where the subject of the report is the Managing Director, the Kubota Australia Board or Kubota Corporation would assume this responsibility.

Contact with Whistleblower

Should Kubota Australia determine that it is appropriate to do so in light of confidentiality, privacy and legal constraints, and the whistleblower indicates they would like to be kept updated, the whistleblower may be kept up to date in regard to key milestones within the investigation process. Where Kubota Australia determine that a referral to an appropriate authority or external entity is necessary, it may not be possible to provide updates.

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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 organization 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, harboring 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 organizations 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 endeavors 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 organization. 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 recognized 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 minimize 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] Modern Slavery Act (Cth) 2018. Available from : https://www.legislation.gov.au/Details/C2018A00153

[3] Department of Home Affairs. Commonwealth Modern Slavery Act 2018: Guidance for reporting entities (2018). Available from https://www.homeaffairs.gov.au/criminal-justice/files/modern-slavery-reportingentities.pdf

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Supplier Code of Conduct

I.                Kubota Group 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.]

II.   Purpose of Kubota Group Supplier Code of Conduct

The purpose of this Supplier Code of Conduct is to promote management that increases the value of the entire company through cooperation between the Kubota Group and its suppliers by indicating the items that the Kubota Group requires suppliers to address and compliance with them.

III.   Scope of Application

This Code of Conduct applies to all suppliers who provide products and services to Kubota Group. If the supplier uses its associated business partners in connection with a transaction with the Kubota Group, we expect the supplier to make a similar requirement to the associated business partners.

IV.  Implementation of the Supplier Code of Conduct

The Kubota Group may require suppliers to explain or provide information through questionnaires, etc. about their compliance with the Supplier Code of Conduct. If a supplier or its associated business partners are found not to comply with the Supplier Code of Conduct, the supplier is required to promptly report to our Supplier hotline. At our Supplier hotline, we accept opinions and comments of all employees of our suppliers, including management, regular and temporary employees, part-timers and casual workers. For information on Kubota Group Supplier hotline, please refer to https://www.kubota.com/sustainability/society/procure/index.html

For Kubota Australia Supplier hotline, please refer to below contact details:

By email to kau_g.whistleblower@KubotaAustralia.com.au for receipt by Kubota’s Compliance department in respect to Australia and New Zealand.

Telephone: 1300 582 582

Anonymously to: Head of Compliance and Internal Control, 25 - 29 Permas Way Truganina VIC 3029

Australia

If a supplier or its associated business partners are found to have violated this Supplier Code of Conduct or violated human rights, the Kubota Group may require the supplier to take appropriate measures to prevent or minimize the scope of the violation, to verify the measures, and to provide corrective measures and remediation to the victims of the situation arising from the violation. For suppliers who fail to respond to our requirements, and Kubota Group believes that this will have a significant impact on Kubota's business, Kubota Group may review the business relationship with the supplier.

V.  Kubota Group Supplier Code of Conduct

1. Legal Compliance and Business Ethics

All suppliers shall comply with the laws and regulations of the countries and regions in which they operate and conduct business in accordance with international rules.

• Fair Competition

All suppliers shall respect “fair and free competition”, comply with the provisions of Anti-Trust Laws, Australian Competition and Consumer Act 20101 and other related laws and regulations, and not engage in unfair transaction practices.

• Improper Payment

Suppliers must comply with the Kubota Australia’s Anti-bribery and Corruption policy2. No suppliers shall make bribes, kickbacks or other illicit payments to political organizations, government officials, employees of the Company or other third parties in order to obtain an unfair advantage. Kubota Group suppliers and their employees, agents and representatives shall comply with Kubota Group's “Request for Understanding and Cooperation in Anti-Bribery Activities” and shall not accept, solicit, offer or pay bribes or provide anything of value, directly or indirectly, to Kubota Group employees or third parties.

For further details, please refer to "Request for Understanding and Cooperation in Anti-Bribery Activities"

at https://www.kubota.com/sustainability/society/procure/data/requests_20210218_english.pdf.

• Intellectual Property

All suppliers shall respect the intellectual property rights of others, including patent rights, utility model rights, design rights, trademark rights, copyrights, and know-how, and shall not use such rights improperly.

• Confidential Information

All suppliers shall protect all confidential information of the Kubota Group, such as sales, technical, management and personal information (all business information not disclosed outside the Company), and shall permit access to such information in a legitimate manner if such access is permitted under applicable law.

1 https://www.legislation.gov.au/C2004A00109/latest/downloads

2 https://kubota.com.au/company/corporate-governance

• Electronic Information

All suppliers shall ensure thorough information security and appropriately manage electronic information to prevent leakage, theft or alteration of electronic information. For further details, please refer to "Information Security Measures Standards for Business Partners at https://www.kubota.com/sustainability/society/procure/index.html.

• Appropriate and Timely Disclosure of Corporate Information

All suppliers shall disclose appropriate corporate information on their management and business activities in accordance with relevant laws and regulations at an appropriate time and in an appropriate manner upon our request.

• Ensuring Proper Quality

All suppliers shall not only comply with laws, regulations, codes and standards, but also ensure that the responsible department is responsible for ensuring safety and excellent quality in each operational process, from development to production, sales and service. In the event that a possible safety problem is identified, our relevant department is to be informed promptly and accurately, and suppliers will work to resolve the problem and prevent its spread.

• Elimination of Relationships with Antisocial Groups

All suppliers shall take a resolute stance against antisocial groups that threaten the order and safety of civil society and cooperate with the police and other relevant organizations to ensure thorough elimination of any relationships of such groups. No suppliers shall accept unreasonable demands from antisocial groups under any circumstances.

• Stable Supply of Products and Services

All suppliers shall develop the necessary systems to ensure a stable supply of products and services by formulating a business continuity plan (BCP) in preparation of disasters or unforeseen events that may hinder the stable supply of products and services.

2.   Labour and Human Rights

In accordance with the Universal Declaration of Human Rights, we require all suppliers to respect the dignity and rights of all people, refrain from human rights violations, respect privacy and protect personal information.

(*In order to respect and ensure human rights and freedoms, the Universal Declaration of Human Rights is a declaration of "a common standard of achievement for all peoples and all nations" and was adopted by the United Nations General Assembly in 1948.)

• Child Labour

No suppliers shall employ persons under 15 years of age or under the age of completion of compulsory education, whichever is higher, in their business activities and supply chains.

• Forced Labour and Responsible Employment

No suppliers shall engage in bonded labour, indentured servitude, forced labour, slave labour, labour by sentenced persons, labour resembling slavery, or labour through trafficking in persons. Forced labour includes violation of the rights of vulnerable groups, deception, restriction of movement, isolation, physical or sexual violence, threats and intimidation, withholding of identity documents, withholding of wages, debt bondage, inadequate work and living conditions, and forced or excessive overtime. All suppliers shall ensure that foreign workers do not pay recruitment and placement fees (in excess of the legal amount) in their placement and, suppliers or their recruitment agencies shall not deprive workers of their identity documents. Consistent with The Modern Slavery Act 20183, suppliers are expected to proactively identify, address and where required by legislation, report on risks of modern slavery practices in their business operations and supply chains. For further details, please refer to Kubota

Australia Modern Slavery Policy4.

• Wages and Working Hours

All suppliers must ensure that all employees receive at least the legally prescribed minimum wage and benefits. If possible, provide a living wage. All suppliers must, at the very least, comply with the laws, standards and practices applicable in the country in which they operate in terms of working conditions and hours. All relevant Suppliers involved in the labour hire sector must hold a licence under this scheme before Kubota Australia can engage their services. Please refer to the Victorian Labour Hire Authority5 , for more information.

3 https://www.legislation.gov.au/Details/C2018A00153

4https://kubota.com.au/company/corporate-governance 5 https://labourhireauthority.vic.gov.au/

• Occupational Health and Safety

All suppliers shall provide workers with a safe and healthy working environment and shall appropriately manage the health and safety of workers. They shall also provide the necessary training on occupational health and safety in a language that workers understand.

• Harassment

No suppliers shall tolerate any form of harassment, including sexual harassment and power harassment,

or any other violation of human rights, such as bullying.

• Discrimination

No suppliers shall discriminate against workers on the basis of race, sex, colour, nationality, religion, age, pregnancy, marital status, social or ethnic origin, sexual orientation, political beliefs, disability, union membership, or any other grounds. Consistent with the Workplace Gender Equality Act 20126, suppliers are expected to proactively support gender equality initiatives. Kubota Australia strives to promote and influence improvements in gender equality across its Supply Chain through procurement policies and practices. Kubota Australia also encourages Suppliers to explore opportunities to engage Aboriginal and Torres Strait Islander businesses in their supply chain.

• Right to Organise and Collective Bargaining

All suppliers shall allow workers to freely join and bargain collectively in accordance with local laws without interference, discrimination, retaliation or harassment. In addition, where the right to join or form a trade union is not fully protected by law, suppliers must facilitate and not impede parallel and alternative means of independent and free association and negotiation.

• Marginalised Populations/Groups

All suppliers shall respect the land and natural resources on which people of marginalised

populations/groups live without depleting or depriving them.

3.   Global and Local/Regional Environment

We require all suppliers to understand the basic ideas set forth in the "Kubota Group Green Procurement Guidelines" and comply with the standards required of suppliers, and the environmental considerations required for goods procured from suppliers. For further details, please refer to the "Kubota Group Green Procurement Guidelines" at https://www.kubota.com/sustainability/environment/procure/index.html.

6 https://www.legislation.gov.au/Details/C2018A00153https://kubota.com.au/company/corporate- governancehttps://labourhireauthority.vic.gov.au/

4.   Others

In Europe and the United States, laws and regulations requiring specific products, parts, and raw materials to undergo environmental and human rights due diligence are being developed. In order to comply with this requirement, Kubota may require suppliers that handle specific products, parts, or raw materials to confirm the usage status, provide information on the supply chain, purchase from specific suppliers, and conduct environmental and human rights due diligence. We also ask all suppliers to establish a mechanism for handling employee complaints.

• Human Rights Policy

All suppliers shall strive to develop human rights policies in accordance with the UN Guiding Principles on

Business and Human Rights.

• Due Diligence on Products, Parts and Raw Materials and Compliance with Environmental Laws and Regulations

All suppliers are directly or indirectly responsible for the import and export of products (including their raw materials and parts) delivered to Kubota Group and must be aware of and comply with the laws and international rules applicable to international trade. This includes obtaining (or assisting in obtaining) the necessary licenses, approvals, certificates or other permits and making accurate customs declarations. It also includes cooperation in conducting due diligence and providing accurate information on the place of origin necessary for the Kubota Group to comply with regulations (examples include, but are not limited to, the Dodd-Frank Act on Conflict Minerals, the EU Battery Regulation, and the EU Deforestation Regulation) that require due diligence on raw materials and parts suspected of involvement in child labour, forced labour or environmental destruction. In the area of environmental legislation, this includes investigating and responding to environmental hazardous substance surveys, CBAM (European Carbon Border Adjustment Mechanism), etc.

• Grievance Mechanisms

All suppliers shall endeavour to establish a grievance mechanism that enables workers, both named and anonymous, to raise complaints and concerns to management and employee representatives without retaliation from the company, and to provide effective solutions to such complaints and concerns.

END