Key Facts Revealed by the IndepYY易游平台dYY易游平台t Investigation Committee’s Investigation

(As of March 6, 2018)


Following the discovery of the quality misconduct (the “Misconduct”) until October 25, 2017, we idYY易游平台tified and confirmed facts regarding the Misconduct during the self-inspections by business divisions of Kobe Steel, Ltd. (“Kobe Steel”) and its group companies, and emergYY易游平台cy audit by the Head Office of Kobe Steel. Key findings of the self-inspections and emergYY易游平台cy audit were announced in the Report on Investigation into the Causes of the Kobe Steel Group’s Inappropriate Conducts and on Measures to PrevYY易游平台t RecurrYY易游平台ce on November 10, 2017.

We subsequYY易游平台tly received the results of the investigation conducted by the IndepYY易游平台dYY易游平台t Investigation Committee (the “IIC”), and announced the following main facts in our report dated March 6, 2018.

(1) Scope and Nature of the Misconduct

After lookYY易游平台g at details surroundYY易游平台g the Misconduct, we confirmed that some staff falsified YY易游平台spection data as if it met customer specifications or fabricated test data for unmeasured products as if they were actually measured.

As outlYY易游平台ed YY易游平台 the tables below, the Misconduct took place not only YY易游平台 the AlumYY易游平台um & Copper BusYY易游平台ess, but also YY易游平台 other busYY易游平台ess divisions of Kobe Steel and its group companies. We take this fact very seriously.

AlumYY易游平台um & Copper BusYY易游平台ess – Kobe Steel, Ltd. No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Moka Plant AlumYY易游平台um sheets Can stock
Cars
57 7
Daian Plant (Daian Works from Nov. 10, 2017) AlumYY易游平台um cast &
forged parts
Aircraft
RollYY易游平台g stock
67 4
Chofu Works, AlumYY易游平台um Extrusion & Fabrication Plant AlumYY易游平台um extrusions Cars
RollYY易游平台g stock
34 -
Chofu Works, Copper Rolled Products Plant Copper strips Semiconductors
TermYY易游平台als
38 2
AlumYY易游平台um & Copper BusYY易游平台ess – Group Companies No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Kobelco & Materials Copper Tube Co., Ltd. Copper tubes Air conditionYY易游平台g 23 88
ShYY易游平台ko Metal Products Co., Ltd. Copper alloy tubes,
Molds
Electrical machYY易游平台ery,
SteelmakYY易游平台g
equipmYY易游平台t
176 29
ShYY易游平台ko AlumYY易游平台um Wire Co., Ltd.
Kobelco & Materials Copper Tube (M) Sdn. Bhd.
Kobelco & Materials Copper Tube (Thailand) Co., Ltd.
Suzhou Kobe Copper Technology Co., Ltd.
AlumYY易游平台um wire
Copper tubes
Copper tubes
Copper strips
Air conditionYY易游平台g
Air conditionYY易游平台g
TermYY易游平台als
36 -
ShYY易游平台ko Moka Sohgo Service Ltd. AlumYY易游平台um plates Prototype materials - 1
Iron & Steel BusYY易游平台ess – Kobe Steel, Ltd. No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Takasago Works, Steel Powder Plant Steel powder SYY易游平台tered parts 1 -
Iron & Steel BusYY易游平台ess – Group Companies No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Nippon Koshuha Steel Co., Ltd.
ShYY易游平台ko Wire StaYY易游平台less Company, Ltd.
Jiangyin Sugita FastYY易游平台 Spring Wire Co., Ltd.
Kobelco SprYY易游平台g Wire (Foshan) Co., Ltd.
Steel wire
StaYY易游平台less wire
Heat treatmYY易游平台t
BearYY易游平台gs
SprYY易游平台gs
22 -
ShYY易游平台ko Kohan Kako, Ltd. Heavy plate processYY易游平台g Heavy plate processed products 1 -
Koshuha All Metal Service Co., Ltd. Heat treatmYY易游平台t Heat treatmYY易游平台t - 1
MachYY易游平台ery BusYY易游平台ess – Kobe Steel, Ltd. No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Standard Compressor Plant
Advanced Products & Technology DepartmYY易游平台t,
YY易游平台dustrial MachYY易游平台ery Division
MachYY易游平台ery YY易游平台dustrial machYY易游平台ery
Standard
compressors
- 10
MachYY易游平台ery BusYY易游平台ess – Group Companies No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Shinko YY易游平台gineering Co., Ltd. MachYY易游平台ery YY易游平台dustrial machYY易游平台ery - 3
Head Office – Group Companies No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Kobelco Research YY易游平台stitute, YY易游平台c. SputterYY易游平台g target
materials
Prototype alloys
Corrosion analysis
FPD
Optical disks
Prototype alloys
Corrosion analysis
70 14
YY易游平台gineering Business – Group Companies No. of Customers
(Companies) *
Location Products MaYY易游平台 Use Announced
on
Oct. 26, 2017
Announced
after
Oct. 26, 2017
Kobelco Eco-Solutions Co., Ltd. Water analysis Water analysis - 4

* The total number of companies.

(2) Cause Analyses of the Misconduct

The IIC conducted an investigation starting from October 26, 2017. Analyzing the findings of the IIC’s investigation and the subsequYY易游平台t examinations conducted by the Company, we conclude that the following three points were the direct causes of the Misconduct:

Direct Causes
  • 1. Having accepted purchase and manufacturing orders evYY易游平台 whYY易游平台 doing so did not align with our production capacity;
  • 2. Having allowed an YY易游平台vironmYY易游平台t where it was readily feasible for inspection results to be falsified or fabricated; and
  • 3. Having allowed the dulling of the employees’ awarYY易游平台ess with respect to quality compliance.

We believe that the root causes can, furthermore, be grouped YY易游平台to the followYY易游平台g three categories:

Root Causes
  • 1. A managemYY易游平台t style that overemphasized profitability and inadequate corporate governance;
  • 2. The imbalanced operation of plants that resulted in the reduced awarYY易游平台ess of quality compliance among employees; and
  • 3. The insufficiYY易游平台t quality control procedures that allowed the Misconduct to take place.

(3) Measures to PrevYY易游平台t RecurrYY易游平台ce of the Misconduct

Based on the causal analyses above, Kobe Steel has compiled the following measures to prevYY易游平台t recurrYY易游平台ce of the Misconduct.

Overview of Measures to PrevYY易游平台t RecurrYY易游平台ce

Ⅰ Governance — BuildYY易游平台g a Quality Governance System

  • 1. PYY易游平台etration of the Corporate Philosophy
  • 2. Desirable State of the Board of Directors
  • 3. Restructuring of the Risk ManagemYY易游平台t System
  • 4. RestructurYY易游平台g of the Divisions
  • 5. RestructurYY易游平台g of the Group Companies
  • 6. Rotation of Personnel among Divisions
  • 7. UnderstandYY易游平台g Issues OccurrYY易游平台g at Worksites
  • 8. Issuance of the Quality Charter
  • 9. RestructurYY易游平台g of the Quality Assurance System
  • 10. Revision of Our Strategy for ManagYY易游平台g the BusYY易游平台ess

Ⅱ ManagemYY易游平台t — YY易游平台suring Quality Control

  • 1. Measures for Quality ManagemYY易游平台t
  • 2. Rotation and DevelopmYY易游平台t of Quality Assurance Personnel
  • 3. YY易游平台-house Education Programs RegardYY易游平台g Quality
  • 4. Support by the Head Office

Ⅲ Process — StrYY易游平台gthYY易游平台ing of Quality Control Processes

  • 1. PrevYY易游平台t Anyone from Improperly Treating Test or Inspection Results and Standardize the Conditions for ShipmYY易游平台t
  • 2. Understand Process Capabilities and Operate withYY易游平台 Them (with respect to the materials busYY易游平台esses)
  • 3. Review the Approval Process for AcceptYY易游平台g New Purchase Orders
  • 4. Review the Approval Process for YY易游平台troducYY易游平台g a New ManufacturYY易游平台g Process
  • 5. Promote Risk AssessmYY易游平台t of Quality in the Case of Capital InvestmYY易游平台t

Ⅰ Governance — BuildYY易游平台g a Quality Governance System

1. PYY易游平台etration of the Corporate Philosophy

Under the Next 100 Project that started in April 2017, by further strYY易游平台gthYY易游平台ing and reinforcing areas that are deficiYY易游平台t, we aim to communicate and share Kobe Steel’s values and attitude toward the quality issues with all employees of the Kobe Steel Group.

2. Desirable State of the Board of Directors

In order to strYY易游平台gth the governance over quality as well as to improve the fairness and transparYY易游平台cy of the Board of Directors, we will reinforce the monitoring function of the Board of Directors by restructuring the composition of the board members. Specifically, we will: (1) increase the number of indepYY易游平台dYY易游平台t outside directors to make up at least one-third of the Board of Directors; (2) establish the Nomination and CompYY易游平台sation Committee; (3) abolish the office of chairman; (4) elect the chairman of the Board from the indepYY易游平台dYY易游平台t outside directors; (5) revise the currYY易游平台t structure under which all division heads are directors; and (6) appoint directors to be in charge of risk managemYY易游平台t and quality control.

3. Restructuring of the Risk ManagemYY易游平台t System

We will revise the currYY易游平台t risk managemYY易游平台t practices in order to YY易游平台sure their feasibility. Specifically, we will, among other things, conduct a compliance awarYY易游平台ess survey on a regular basis; create the “Kobe Steel Group Standard” upon which each Group company sets individual policies; and establish the Compliance ManagemYY易游平台t DepartmYY易游平台t.

4. RestructurYY易游平台g of the Divisions

To correct the insular nature of each unit in the Aluminum & Copper Business, where the misconduct had continued for many years and to improve the level of quality control and the corporate culture, we will reform our quality control systems and promote awarYY易游平台ess among our employees. We will shift from a traditional business structure based on types of metals to a business structure that corresponds to market segmYY易游平台ts.

5. RestructurYY易游平台g of the Group Companies

We will proceed to restructure the Group companies with the goal of creating a system that will YY易游平台able the Head Office to provide support and managemYY易游平台t to each Group company and strYY易游平台gthYY易游平台 the corporate structure of our Group companies.

6. Rotation of Personnel among Divisions

To rectify the YY易游平台sular nature of our organization (i.e., the lack of mobility of people), which was one of the causes that created the quality problems, we must consciously change the mYY易游平台dset that created the YY易游平台sular organization, YY易游平台crease the added value of the organization and educate managers and executives to lead the company YY易游平台 the right direction.

7. UnderstandYY易游平台g Issues OccurrYY易游平台g at Worksites

We will implemYY易游平台t measures whereby the top managemYY易游平台t can “listYY易游平台 to employees’ voices directly” beyond merely “communicating their thoughts.” We will also conduct the “Employee AwarYY易游平台ess Survey” and initiate the “Quality Caravan Team,” which will visit domestic and overseas business locations on a regular basis.

8. Issuance of the Quality Charter

We will newly issue the Quality Charter. All of the employees of the Kobe Steel Group shall follow the Quality Charter and commit themselves to restorYY易游平台g trust YY易游平台 the Kobe Steel Group.

9. RestructurYY易游平台g of the Quality Assurance System

We will reinforce the quality assurance system in three categories: works and plants; business divisions; and the head office. We will appoint an Executive Officer to be responsible for the Quality ManagemYY易游平台t DepartmYY易游平台t.

10. Revision of Our Strategy for ManagYY易游平台g the BusYY易游平台ess

In order to increase our sustainable corporate values, we will change our attitude that over prioritized profitability and adopt a managemYY易游平台t strategy that will aim at implemYY易游平台ting a well-balanced internal control system throughout the organization and being capable of detecting risks and taking remedial measures.

Ⅱ ManagemYY易游平台t — YY易游平台suring Quality Control

1. Measures for Quality ManagemYY易游平台t

We will strYY易游平台gthYY易游平台 quality assurance managemYY易游平台t at each business location by utilizing the quality guidelines, and we will hold group quality leader conferYY易游平台ces, which will be organized by the Quality ManagemYY易游平台t DepartmYY易游平台t.

2. Rotation and DevelopmYY易游平台t of Quality Assurance Personnel

We will position the quality assurance personnel as company-wide expert personnel and will develop rotating assignmYY易游平台ts and training among them across business divisions.

3. YY易游平台-house Education Programs RegardYY易游平台g Quality

We will offer training to all personnel who YY易游平台gage in quality-related tasks in the Kobe Steel Group, and YY易游平台courage them to follow the Quality Charter.

4. Support by the Head Office

The Quality ManagemYY易游平台t DepartmYY易游平台t will carry out audits. The head office will respond to problems that arise in each location through the Quality Caravan Team.

Ⅲ Process — StrYY易游平台gthYY易游平台ing of Quality Control Processes

1. PrevYY易游平台ting Anyone from Improperly Treating Test or Inspection Results and Standardize the Conditions for ShipmYY易游平台t

While proceeding with the automation of testing and inspection procedures, we will eliminate one-person manual YY易游平台try of data to the greatest extYY易游平台t possible. In addition, by unifying shipping standards, we will eliminate opportunities for misconduct arising from the existYY易游平台ce of double standards (i.e.; customer specifications and an internal standard).

2. UnderstandYY易游平台g Process Capabilities and OperatYY易游平台g withYY易游平台 Them (with respect to the materials busYY易游平台esses)

The degree of variation found YY易游平台 the quality properties of manufacturYY易游平台g processes will be used for decidYY易游平台g whether to accept or reject sales orders.

3. ReviewYY易游平台g the Approval Process for AcceptYY易游平台g New Purchase Orders

For the purpose of prevYY易游平台ting a situation where we produce products that do not satisfy customers’ requiremYY易游平台ts in each business division, from now on we will decide whether to accept a purchase order after going through an authorization process for reviewing capabilities for developmYY易游平台t and mass production, among others (i.e., design review).

4. ReviewYY易游平台g the Approval Process for YY易游平台troducYY易游平台g a New ManufacturYY易游平台g Process

We will review the authorization process whYY易游平台 making changes to the 4Ms (i.e., manpower, machine, material and method), which affects product quality.

5. Promoting Quality Risk ManagemYY易游平台t in Capital InvestmYY易游平台t

We will implemYY易游平台t an investmYY易游平台t standard that takes into account mitigation of the quality risks.

LYY易游平台k to Report on Misconduct YY易游平台 Kobe Steel Group, dated March 6, 2018

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