Business Conduct


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Equal Employment Opportunity

The policy of the Company has been, and will continue to be, equal employment opportunity for all. The Company expects all individuals employed by the Company to be committed to this policy as well.

While not intending to create any contractual rights on the part of the employees or applicants, to ensure implementation of this policy, we assure that:

  • Employees are treated, during employment, without regard to race, color, religion, sex, age, national origin, disability, or Vietnam veteran or special disabled veteran status. The Company will not discriminate against employees based on any of these factors and shall take affirmative action to ensure that employees are treated without regard to any of these factors.
  • All personnel actions such as recruiting, hiring, training, promoting, compensation, benefits, transfers, layoffs, returns from layoff, Company-sponsored training, educational assistance, and social and recreational programs are administered without regard to race, color, religion, sex, age, national origin, disability or veteran status.
  • All employment decisions will be based so as to further the principle of employment opportunity. Management shall base employment decisions only on valid job requirements. To ensure that promotion decisions are in accord with the principles of equal employment opportunity, the Company will impose only valid requirements for promotional opportunities.
  • The Company will reasonably accommodate the physical and mental limitations of employees, unless such accommodation would impose an undue hardship. Employees with a disability who believe they need an accommodation to perform the essential functions of their jobs should contact an HR representative, who, along with the employee’s supervisor/manager, will meet with the requesting employee to discuss and identify the precise limitations resulting from the disability and any potential accommodations that might be made to help overcome the limitations.
  • The Company will encourage and support the employment and promotion of persons who are disabled veterans, recently separated veterans (within three years of discharge or release from from active duty), other protected veterans (veterans who served during a war or in a campaign or expedition for which a campaign badge has been authorized), and Armed Forces service medal veterans (veterans who, while on active duty, participated in a U.S. military operation for which an Armed Forces service medal was awarded).

If the Company finds anyone to be acting in violation of this policy, appropriate disciplinary measures will be taken.

Code of Conduct

Midlantic Machinery Employee Code of Conduct (Rules of the Road)

The Company is committed to the maintenance of its integrity, business ethics and reputation and will conduct its business legally and fairly. It is the policy of the Company to require employees to conduct their personal and business affairs in a manner consistent with acceptable business practices and with a high degree of personal integrity at all times. The Komatsu America Corp. Employee Code of Conduct (Code of Conduct), which is provided to each employee, sets out the standards to be followed while employed by the Company. Establishment of these standards of conduct does not alter the employment-at-will relationship. As a condition of employment, employees will be required to periodically sign a statement of compliance stating that they have read and understand the Code of Conduct.

Non-Discrimination/Harassment

The Company and its directors, officers and employees shall comply with all laws and regulations that prohibit unlawful discrimination, harassment, or an intimidating or hostile work environment. The Company is also committed to maintaining a zero-tolerance policy of all such activities by or against other employees, customers, vendors or visitors. This behavior applies to all employees, male or female, and to all phases of the employment relationship, and conduct inside or outside the workplace. Any claims of discrimination or harassment will be investigated promptly, and violations of the policy will be considered gross misconduct and grounds for disciplinary action, up to and including termination of employment. Retaliation against employees for raising claims of discrimination or harassment will not be tolerated. Supervisors/managers have a responsibility to maintain a workplace free of discrimination and harassment and to notify HR if they become aware of inappropriate conduct or receive a complaint.

Harassment and discrimination include verbal, non-verbal and electronic communications and can include, but are not limited to:

  • Unwelcome conduct that is based upon a characteristic protected by law, including gender, color, race, ancestry, religion, national origin, age, physical or mental disability, veteran or marital status, sexual orientation or any other protected group status;
  • Conduct that degrades or shows hostility or aversion toward another employee because of his/her protected status or that of relatives, friends or associates;
  • Name calling, letters, jokes, emails, cartoons, graffiti, pictures, posters/postings, gestures, ethnic slurs, racial epithets and other conduct which is aimed at a particular employee or group of employees;
  • Unwanted sexually directed behavior, including but not limited to, unwelcome sexual advances, requests for sexual favors, and other verbal, visual or physical conduct based on gender, any or all of which constitute sexual harassment; or
  • Foul or obscene language or gestures, displays of foul or obscene printed or visual material, and unwanted physical contact.

Conduct constitutes sexual harassment by law specifically when:

  • Submission to such conduct is made either explicitly or implicitly a term or condition of an employee’s employment;
  • Submission to or rejection of such conduct by an employee is used as the basis for employment decisions affecting such employee; or
  • Such conduct has the purpose or effect of unreasonable interference with an employee’s work performance, or creating an intimidating, hostile or offensive working environment.

Open Door Policy

The Company believes in providing fair, equitable, and timely resolution of work-related issues and concerns as they arise. It is the Company’s policy to promote open and casual communication between employees and management. It is also the Company’s goal to provide open channels of communication to allow employees the opportunity to express their feelings concerning working conditions, problems, or questions relating to employment.

All employees are strongly encouraged to talk with their immediate supervisors/managers whenever issues arise. The immediate management has primary responsibility for responding to issues and attempting to settle situations appropriately. If they are unable to resolve issues satisfactorily, employees are encouraged to talk to the next higher level of management. If issues cannot be resolved within their departments, employees are encouraged to seek help from the HR department who will then work with employees and any other appropriate parties to resolve issues.