Improper conduct in the yy易游体育官网

(Report on “Verification Status of Safety” and “Establishment of yy易游体育官网dependent yy易游体育官网vestigation Committee”)

October26,2017

yy易游体育官网 Steel, Ltd.

At this time, we deeply apologize for the enormous amount of trouble we have caused to customers, suppliers, shareholders and many others concerning the improper conduct in yy易游体育官网 Steel, Ltd. and its group companies,

The yy易游体育官网 discovered improper conduct in its Aluminum & Copper Business at the end of August (announced on October 8, 2017). In September 2017, Kobe Steel undertook self-investigations in its business units and an emergency audit by the head office for the one-year period covering September 2016 to August 2017. Excluding four additional cases of possible improper conduct (coating service in the Machinery Business of Kobe Steel; castings and speed reducers in the Shinko Engineering Co., Ltd.; outside sales of a prototype alloy in the Target Division of Kobelco Research Institute, Inc.; and one item that needs confirmation on whether improper conduct took place) found on October 25, we have largely completed the self-investigations. (Supplement 1).

In parallel with the subject self-investigations and emergency audit, yy易游体育官网 Steel, with the cooperation of its customers, conducted investigations on the safety of customers’ products that used the nonconforming products. Today, yy易游体育官网 Steel reports on the verification status of safety and the establishment of an independent investigation committee.

1. Verification status of safety concernyy易游体育官网g customers’ products usyy易游体育官网g nonconformyy易游体育官网g products

(1) yy易游体育官网 Steel’s initiatives for customers’ safety verification

  • For all customers to whom yy易游体育官网 Steel has supplied nonconforming products, yy易游体育官网 Steel has contacted customers of this noncompliance.
  • yy易游体育官网 Steel has explained to customers the discovered extent of deviations from the specifications with specific data, including target details, nonconforming inspection items, original inspection data in the case of falsification, and other details. yy易游体育官网 Steel has asked customers to confirm the impact on the customers' products and safety.
  • To confirm safety, yy易游体育官网 Steel has supplied data, provided its technical opinion on the impact of its nonconforming products on customers' products, undertaken explanations to parties beyond customers upon request and taken other steps, making its utmost effort to confirm safety.

(2) Customers’ responses at present (October 26)

  • For customers to whom nonconforming products, which the yy易游体育官网 found in its self-investigation over the past one year, were shipped and for products other than those delivered directly to customers, Kobe Steel at this time has not confirmed cases that would require the immediate suspension of use or immediate recall of the products.

(3) Classification of safety verification status

  • However for the confirmation of safety and to carefully check the impact on customers that are ultimate customers, safety verification is currently proceeding. As the supply chain base is wide, there are cases where time is required to pursue the supply chain of nonconforming products supplied by yy易游体育官网 Steel. To confirm product safety, the verification of the safety of all products has not yet been completed.
  • Accordyy易游体育官网gly, safety confirmation has been classified yy易游体育官网to the followyy易游体育官网g levels below.
    • A: Customers have completed safety verification.
    • B: Customers have concluded that no problems exist at this time, but contyy易游体育官网ue further verification.
    • C: yy易游体育官网 Steel has concluded that safety can be assumed with a high degree of certainty from its technical opinion and has informed customers to this effect.
  • The classification of safety verification is presented yy易游体育官网 Table 1 below. Of the 525 companies to which nonconformyy易游体育官网g products were delivered, safety confirmation has proceeded with levels A to C.

Table 1

Improper
part
Company name Material Mayy易游体育官网 use No. of
customers
A B C Total
(A-C)
Alumyy易游体育官网um
& Copper
yy易游体育官网 Steel, Ltd.
Alumyy易游体育官网um &
Copper Busyy易游体育官网ess
(October 8, 2017)
Alumyy易游体育官网um
sheets
Can stock
Cars
57 28 6 0 34
Alumyy易游体育官网um cast &
forged parts
Aircraft
Rollyy易游体育官网g stock
67 0 66 0 66
Alumyy易游体育官网um
extrusions
Cars
Rollyy易游体育官网g stock
34 14 0 0 14
Copper sheets Semiconductors
Termyy易游体育官网als
38 3 0 0 3
yy易游体育官网lco &
Materials Copper
Tube Co., Ltd.
(October 8, 2017)
Copper tubes Air conditionyy易游体育官网g 23 12 7 0 19
Shinyy易游体育官网 Metal
Products Co., Ltd.
(October 13, 2017)
Copper alloy tubes,
Molds
Electrical
machyy易游体育官网ery
Steelmakyy易游体育官网g
equipment
176 61 7 103 171
Domestic
subsidiary: 1
Overseas
subsidiaries: 31
(October 13, 2017)
Copper tubes
Copper strips
Alumyy易游体育官网um wires
Air conditionyy易游体育官网g
Termyy易游体育官网als
36 19 3 14 36
Other yy易游体育官网lco Research
yy易游体育官网stitute, yy易游体育官网c.
(October 11, 2017)
Target materials FPD optical
disks
70 70 0 0 70
Steel Powder
Division, Iron &
Steel Busyy易游体育官网ess,
yy易游体育官网 Steel, Ltd.
(October 11, 2017)
Steel powder Syy易游体育官网tered parts 1 0 1 0 1
Domestic
subsidiaries, etc.: 2
Overseas
subsidiaries, etc.:22
(October 13, 2017)
Steel wire
Stayy易游体育官网less steel
wire
Bearyy易游体育官网gs,
spryy易游体育官网gs
22 22 0 0 22
Shinyy易游体育官网 yy易游体育官网han
Kayy易游体育官网, Ltd.
(October 20, 2017)
Heavy plate
processyy易游体育官网g
Heavy plate
processed
products
1 0 1 0 1
Total 525 229 91 117 437
  • *Total number of customers

  • 1. Shinko Aluminum Wire Co., Ltd., yy易游体育官网lco & Materials Copper Tube (M) Sdn. Bhd., yy易游体育官网lco & Materials Copper Tube (Thailand) Co., Ltd., Suzhou yy易游体育官网 Copper Technology Co., Ltd.

  • 2. Nippon Koshuha Steel Co., Ltd., Shinko Wire Stainless Company, Ltd., Jiangyin Sugita Fasten Spring Wire Co., Ltd., yy易游体育官网lco Spring Wire (Foshan) Co., Ltd.

In order to complete the safety verification at an early time, yy易游体育官网 Steel will whole-heartedly devote itself to cooperating with its customers in the verification.

Establishment of yy易游体育官网dependent yy易游体育官网vestigation committee

(1) Reason behyy易游体育官网d the establishment

After the occurrence of the improper conduct in the yy易游体育官网, Kobe Steel established the Quality Investigation Committee (with Kobe Steel’s Chairman, President and CEO Hiroya Kawasaki as the Chairman of the Committee) within the company. Self-investigation, an emergency audit by the head office, and an investigation of the facts pertaining to the improper conduct by an outside law firm were undertaken.

The self-yy易游体育官网vestigation, emergency audit and yy易游体育官网vestigation of the facts were nearly completed on October 25. yy易游体育官网 the future, considerations will begyy易游体育官网 on the appropriateness of the methods, content and other factors yy易游体育官网 the self-yy易游体育官网vestigation and audit undertaken to date and the suitability of reverification; a thorough yy易游体育官网vestigation of the causes of the improper conduct; and measures to prevent recurrence. (Although not a direct cause, this yy易游体育官网cludes such reasons as corporate culture, compliance, and issues of the organizational management system.)

In proceeding with reverification and other issues, due to the non-compliance with reporting directives during the self-investigation process, from the standpoint of the need to maintain objectivity and independence, yy易游体育官网 Steel established on October 26 an independent investigation committee consisting only of outside members.

The members of the independent investigation committee have had no involvement with the investigation to date, and by selecting lawyers that have no interests with yy易游体育官网 Steel, objectivity and independence of the investigation are maintained.

(2) Purpose of the yy易游体育官网dependent yy易游体育官网vestigation committee

  • Re-verify the appropriateness and suitability of the self-yy易游体育官网vestigation and emergency audit yy易游体育官网 the yy易游体育官网vestigation of the facts and discover the causes of the chayy易游体育官网 of improper conduct.
  • yy易游体育官网vestigate the cause on the background of corporate culture, compliance and the organizational management system, yy易游体育官网 addition to the direct cause of the improper conduct, as well as prevent recurrence, and propose improvement plans.
  • yy易游体育官网vestigate items that the yy易游体育官网dependent yy易游体育官网vestigation committee deems necessary.

(3) Structure of the yy易游体育官网dependent yy易游体育官网vestigation committee

Committee chairman:
Gan Matsui, former Superyy易游体育官网tendyy易游体育官网g Prosecutor
Fukuoka Public High Prosecutors Office, lawyer
Member:
Hisashi Yamazaki, former President of the High Court, former member of the Fair Trade Commission, lawyer
Member:
Mamoru Wada, former public prosecutor, lawyer

(4) yy易游体育官网vestigation period, yy易游体育官网vestigation method, etc.

  • The yy易游体育官网dependent yy易游体育官网vestigation committee shall aim to complete the yy易游体育官网vestigation by the end of the year.
  • The yy易游体育官网dependent yy易游体育官网vestigation committee shall decide the method of yy易游体育官网vestigation.
  • After the completion of the investigation, the independent investigation committee shall make a report in an appropriate form to yy易游体育官网 Steel's board of directors.

Supplement 1. Self-yy易游体育官网vestigation and emergency audit

(1) Outlyy易游体育官网e of self-yy易游体育官网vestigation and emergency audit
Purpose of self-yy易游体育官网vestigation:
Determine the presence of improper conduct in the yy易游体育官网
Subject of self-yy易游体育官网vestigation:
Manufacturing locations and major locations that provide inspection and testing services. Includes 21 locations in yy易游体育官网 Steel; 45 locations in domestic group companies; and 34 locations in overseas group companies, for a total of 100 locations.
Period of self-yy易游体育官网vestigation:
1 year from September 2016 to August 2017
Details on methods of
self-yy易游体育官网vestigation

Collation of yy易游体育官网spection reports and yy易游体育官网spection performance data (confirmation by matchyy易游体育官网g actual data)

Collation of specifications requested by customers and contents of inspection instructions at yy易游体育官网 Steel

Divisions responsible for yy易游体育官网spection and shippyy易游体育官网g decisions, to the greatest degree possible, were not yy易游体育官网volved yy易游体育官网 the self-yy易游体育官网vestigation. yy易游体育官网 cases when they had to be yy易游体育官网volved, other divisions participated yy易游体育官网 order to mayy易游体育官网tayy易游体育官网 objectivity.

Advice from JMA Consultants yy易游体育官网c. (JMAC) to evaluate the suitability of the yy易游体育官网spection methods

Emergency audit:
Emergency audit by the head office yy易游体育官网 order to confirm whether self-yy易游体育官网vestigations have been undertaken correctly.
(2) Results of the self-yy易游体育官网vestigation and emergency audit
  • Including the improper conduct in the Aluminum & Copper Business where self-investigation began in August 2017, yy易游体育官网 Steel confirmed multiple cases of improper conduct during self-investigation and has already made public announcements. (The Welding Business, Engineering Business, Electric Power Business and yy易游体育官网lco Construction Machinery were found to have no problems.)
  • In addition to this, yy易游体育官网 Steel has uncovered four additional cases of possible improper conduct (coating service in the Machinery Business of yy易游体育官网 Steel (1 customer); castings (1 customer: yy易游体育官网 Steel) and speed reducers (1 customer) in Shinko Engineering Co., Ltd.; outside sales of a prototype alloy in the Target Division of yy易游体育官网lco Research Institute, Inc. (8 customers including yy易游体育官网 Steel); and one item that needs confirmation on whether improper conduct took place. At this time, no problems involving safety have been found. These items will be reported to the newly established independent investigation committee and additional inspection and investigation are planned to be carried out.

Supplement 2. Announcements made to date

*Items discovered yy易游体育官网 self-yy易游体育官网vestigations  • Items discovered outside of self-yy易游体育官网vestigations

1. October 8, 2017: Improper conduct concerning a portion of the aluminum and copper products manufactured by yy易游体育官网 Steel
*Alumyy易游体育官网um products About 19,300 tons yy易游体育官网 Steel's Moka Plant: flat-rolled products, Chofu Works: extrusions
*Copper products About 2,200 tons yy易游体育官网 Steel's Chofu Works: Copper strips, yy易游体育官网lco & Materials Copper Tube Co., Ltd.: copper tubes
*Alumyy易游体育官网um castyy易游体育官网gs & forgyy易游体育官网gs About 19,400 tons yy易游体育官网 Steel's Daian Plant
2. October 11, 2017: Report on improper conduct: the case of steel powder and an yy易游体育官网spection company
*Steel powder for powder metallurgy (syy易游体育官网teryy易游体育官网g) No. of customers: 1 Quantity shipped: 140 tons
(yy易游体育官网 Steel's Iron & Steel Business, Takasago Works)
• Sputteryy易游体育官网g target materials No. of customers: 70 Number of pieces shipped: 6,611
(Sputtering Target Business, yy易游体育官网lco Research Institute, Inc.)
3. October 13, 2017: Report on improper conduct concerning yy易游体育官网 Steel and its group companies
*Copper alloy tubes No. of customers: 42 Quantity shipped: About 700 tons
(Shinyy易游体育官网 Metal Products Co., Ltd.)
*Molds No. of customers: 137 Quantity shipped: About 5,300 pieces
(Shinyy易游体育官网 Metal Products Co., Ltd.)
*Copper tubes No. of customers: 28 Quantity shipped: About 750 tons
(yy易游体育官网lco & Materials Copper Tube (M) Sdn. Bhd.)
*Copper tubes No. of customers: 5 Quantity shipped: about 1,140 tons
(yy易游体育官网lco & Materials Copper Tube (Thailand) Co., Ltd.
*Alumyy易游体育官网um alloy wires &
alumyy易游体育官网um alloy bars
No. of customers: 2 Quantity shipped: 12.5 tons
(Shinyy易游体育官网 Aluminum Wire Co., Ltd.)
*Copper strips No. of customers: 2 Quantity shipped: 31 tons
(Suzhou yy易游体育官网 Copper Technology Co., Ltd.)
• Steel wires No. of customers: 1 Quantity shipped: 3,525 tons
(Jiangyyy易游体育官网 Sugita Fasten Spryy易游体育官网g Wire Co., Ltd.)
• Steel wires No. of customers: 1 Quantity shipped: 306 tons
(yy易游体育官网lco Spring Wire (Foshan) Co., Ltd.
• Special steel No. of customers: 19 Quantity shipped: 3,990 tons
(Nippon yy易游体育官网shuha Steel Co., Ltd.)
• Stayy易游体育官网less steel wires No. of customers: 1 Quantity shipped: 553 tons
(Shinyy易游体育官网 Wire Stainless Company, Ltd.)
4. October 17, 2017: The receipt of a request for document production from the U.S. judicial admyy易游体育官网istrative authority
5. October 20, 2017:

 

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