ABOUT KUBOTA AND OUR APPROACH TO INTERNATIONAL SANCTIONS, ANTI-BOYCOTT AND ANTI-CORRUPTION
Kubota Holdings Europe B.V., a company registered under the laws of the Netherlands, having its registered address at Hoofdweg 1264, 2153 LR, Nieuw-Vennep, The Netherlands (hereinafter referred to as “Kubota Holdings Europe”) and its affiliates[1] (hereinafter referred to as “Kubota Companies”, together, with Kubota Holdings Europe, referred to as “Kubota”, “We”, “Our” or “Us”) using and making the Website available their end-customers and their dealers, understand transparency and respect the foundational aspects of longstanding relationships and, therefore, We take every reasonable effort to protect the information you provide to Us.
Kubota Holdings Europe is a company belonging to Kubota Corporation, a company registered under the laws of Japan, having its registered address at 2-47, Shikitsuhigashi 1-chome, Naniwa-ku, Osaka 556-8601, Japan (hereinafter referred to as “Kubota Corporation”).
Kubota Holdings Europe owns the brands “Kubota”, “Kverneland”, “Vicon”, “FEDE” and “ROC”. The brands “Kubota”, “Vicon”, “FEDE”, “ROC” and “Kverneland” are together referred to as the “Brands”.
Kubota is committed to comply with the various economic and trade sanctions, anti-boycott and anti-corruption laws in all jurisdictions in which it operates, physically or via the Brands websites of Kubota where you can view information about products and services of the Brands that are sold by dealers to end-customers (hereinafter referred to as the “Website”).
This international sanctions, anti-boycott and anti-corruption policy is drawn up in English and is, at the discretion of Kubota, translated in several languages for your convenience. In case of inconsistencies, discrepancies or difficulty of application or interpretation between the English version and the translated versions, the English version shall prevail.
APPLICABILITY
This international sanctions, anti-boycott and anti-corruption policy applies to:
- all of your employees, officers, directors, and contracted personnel, and to such other persons that you will designate from time to time; and,
- all natural and legal persons (and their respective employees, officers and directors) that perform services for or on behalf of you, including without limitation, supply chain business partners, suppliers, consultants, contractors, distributors, and agents (including without limitation, sales agents/representatives).
As a condition of using the Website and/or doing business with Kubota, you accept this international sanctions, anti-boycott and anti-corruption policy to be fully applicable, directly or indirectly, to you and to above-mentioned persons.
INTERNATIONAL SANCTIONS AND ANTI-BOYCOTT
You represent and warrant to Kubota that neither you nor any person or entity that you own or control is a designated target of any trade, and/or economic and/or financial sanction or sanctions (including without limitation any relevant law, regulation, order, ordinance, resolution, decree, restrictive measure or other requirement having the force of law), adopted by the United States of America, European Union (or its respective member states), the United Kingdom, Norway, Japan, United Nations, or any other relevant jurisdiction, or the country of the Party of the country of origin of the products and/or services related to the Brands and/or the Website (collectively referred to as “Sanctions”). You agree and undertake to Kubota that you and your agents, contractors, and representatives will fully comply with the requirements of all applicable Sanctions in the use of this Website, as well as the requirements of all other applicable laws and regulations about export or import control that relate to dual use item control (collectively referred to as “EARs”).
You agree and undertake to Kubota and Kubota Corporation that the products and/or services related to the Brands and/or the Website will not be:
(i) resold to;
(ii) re-exported to;
(iii) disposed of by; or
(iv) transported on a vessel, or by a carrier, owned, flagged, chartered, managed or controlled by, directly or indirectly to,
any country, person or entity, or for the purpose of any commercial activity, which would cause Kubota or Kubota Corporation or a person subject to the European Union (or its respective member states), the United Kingdom, Norway, the United States of America, Japan or any other relevant jurisdiction, to be in violation of applicable Sanctions and/or EARs, including but not limited to the Russian Federation or for use in the Russian Federation any products and/or services related to the Brands and/or the Website, supplied under or in connection with the Website that fall under the scope of Article 12g of Council Regulation (EU) No 833/2014.
If Kubota requires, you shall provide Kubota with appropriate documentation for the purposes of verifying the final destination of the products and/or services related to the Brands and/or the Website. Kubota has the right to reject any restricted destination, vessel, transit route, person or entity that would cause the use of the Website to violate any applicable Sanctions and/or EARsor which would cause Kubota, Kubota Corporation or their agents, contractors, or representatives or a person subject to the European Union (or its respective member states), the United Kingdom, Norway, the United States of America, Japan or any other relevant jurisdiction, to be in violation of or be penalized by any applicable Sanctions and/or EARs.
You commit to undertake your best efforts to ensure that the purpose of the above paragraph is not frustrated by any third parties further down the commercial chain, including by possible resellers.
You commit to set up and maintain an adequate monitoring mechanism to detect conduct by any third parties further down the commercial chain, including by possible resellers, that would frustrate the purpose of the above paragraph.
You warrant and represent that you will not re-export the products and/or services related to the Brands and/or the Website supplied by Kubota to a country, person, entity or body subject to Sanctions and/or EARs if such re-export would violate applicable Sanctions or EARs. You further warrant that if the products and/or services related to the Brands and/or the Website supplied are integrated into another product (referred to as the “Downstream Products”) destined to a country to which the supplied products and/or services related to the Brands and/or the Website cannot be exported under the Sanctions and/or EARs, the supplied products and/or services related to the Brands and/or the Website cannot be easily removed from the Downstream Product. In case you, by your activity, directly or indirectly causes Kubota or Kubota Corporation to breach Sanctions and/or EARs, you shall be indefinitely liable and shall indemnify Kubota and Kubota Corporation against all costs and penalties Kubota or Kubota Corporation may incur as a result of your breach of Sanctions and/or EARs imputable to Kubota or Kubota Corporation.
You further represent and warrant that you will not make payment for the products and/or services related to the Brands and/or the Website through or via such country, bank, or other entity or body or facility, as would cause Kubota or Kubota Corporation or a person subject to European Union, United Kingdom, Norwegian, United States of America, Japan or any other relevant jurisdiction, directly or indirectly, to be in violation of or be penalized by any applicable Sanctions and/or EARs.
Should payment for the products and/or services related to the Brands and/or the Website be impeded, blocked, delayed, or prevented, for longer than three business days, by reason of Sanctions and/or EARs or their alleged applicability, you shall make payment by alternative lawful means that do not, directly or indirectly, violate any Sanctions and/or EARs (insofar as they apply or are applied or implemented by banks, governments, or other lawfully-constituted authority whatsoever), unless any such payment problems are a result of Kubota’s or Kubota Corporation’s violation of the Sanctions and/or EARs.
The parties will not cooperate with, agree to, or comply with any terms or requests, including documentary requests, which violate or are otherwise prohibited or penalized under the anti-boycott laws or regulations of the European Union (or its respective member states), the United Kingdom, Norway, the United States of America, Japan or any other relevant jurisdiction.
ANTI-CORRUPTION
You agree to cooperate with Kubota’s reasonable requests for information and/or documentary evidence to support and/or verify compliance with this clause.
You agree and undertake to Kubota that, in connection with the use of the Website, you will fully comply with all applicable laws, regulations, orders, ordinances, resolutions, decrees, or restrictive measures and/or other requirements having the force of law of the United States of America, European Union (or its respective member states), the United Kingdom, Norway, Japan, United Nations, or the country of origin of the products and/or services related to the Brands and/or the Website relating to anti-bribery and anti-money laundering (hereinafter referred to as the “Applicable Legislation”). In particular, you represent, warrant and undertake to Kubota that you shall not, directly or indirectly,
- pay, offer, give or promise to pay or authorize the payment of, any monies or other things of value to, or confer a financial advantage on:
- a government official or an officer or employee of a government or any department, agency or instrumentality of any government;
- an officer or employee of a public international organisation;
- any person acting in an official capacity for or on behalf of any government or department, agency, or instrumentality of such government or of any public international organisation;
- any political party or official thereof, or any candidate for political office;
- any other person, individual or entity at the suggestion, request or direction or for the benefit of any of the above-described persons and entities; or
- engage in other acts or transactions
in each case if this is in violation of or inconsistent with the Applicable Legislation, including, without limitation, the U.S. Foreign Corrupt Practices Act and applicable country legislation implementing (in whole or in part) the OECD convention on combating bribery of foreign public officials in international business transactions.
INDEMNIFICATION
Any violation or doubt of violation of the of the provisions of the above-mentioned clauses related to Sanctions, EARs, anti-boycott or anti-corruption by you shall constitute a material breach of an essential element of the use of the Website, and Kubota shall be entitled to seek appropriate remedies, including, but not limited to:
(i) termination without notice of the use of the Website;
(ii) indemnification of the value of the damages created by the said violation or doubt of violation, without time limitation, as per the below paragraphs.
Notwithstanding anything to the contrary, the same termination conditions shall also apply, if at any time Kubota, acting in good faith, has reason to believe that:
(i) you have used or are in the process of using any part of the compensation payable, or expenses reimbursable, as part of this commercial relationship, for a bribe, kickback or other corrupt payment, in violation of applicable anti-corruption laws, including, without limitation, the U.S. Foreign Corrupt Practices Act, and/or other applicable anti-corruption law applicable in country of the respective Kubota’s company’s seat;
(ii) you are breaching or have breached any Sanctions, EARs, anti-boycott or anti-corruption regulations;
(ii) the representations and warranties in the foregoing sections are false or have been breached; or
(iv) the commercial relationship between the parties, including but not limited to any relationships created through written or unwritten contracts, or the performance of any of its terms violates or contravenes any applicable law.
In case of violation or doubt of violation of the provisions of the above-mentioned clauses related to Sanctions, EARs, anti-boycott or anti-corruption by you, you agree to indemnify and hold harmless Kubota, Kubota Corporation, its officers and employees upon first request of Kubota from and against all direct claims and suits by third parties for damages, injuries to persons (including death), property damages, losses, and expenses including court costs and reasonable attorney’s fees, arising out of, or resulting from, the violation of the above-mentioned clauses related to Sanctions, EARs, anti-boycott or anti-corruption by you, under the use of the Website, including all such causes of action based in whole or in part, upon allegations of negligent or intentional acts on the part of you, its officers, employees, agents, subcontractors, licensees, or invitees.
In relation to any indemnity given in the use of the Website related to, Sanctions, EARs, anti-boycott and anti-corruption, the party receiving the benefit of the indemnity (hereinafter referred to as the “Indemnity Beneficiary”) shall:
- notify the other party (hereinafter referred to as the “Indemnifier”) promptly if it receives any notice, demand, letter or other document concerning any claim for which it appears that the Indemnity Beneficiary is, or may become entitled to indemnification under this international sanctions, anti-boycott and anti-corruption policy;
- not make any admissions nor attempt to settle or compromise any such claim or action without the Indemnifier’s written consent (such consent not to be unreasonably withheld or delayed);
- give the Indemnifier the sole conduct of the defense to any such claim or action;
- use its best endeavors to mitigate any costs, losses, charges, damages, expenses, claims and demands whatsoever covered by the indemnity; and
- act in accordance with the reasonable instructions of the Indemnifier and give the Indemnifier such assistance as the Indemnifier shall reasonably require in relation to any such claim or action.
HOW TO CONTACT US
If you have any questions or comments about this international sanctions, anti-boycott and anti-corruption policy, Kubota practices or if you would like to report an incident or violation based on this policy, please contact Us by email at khe_g.privacy@kubota.com or by post to the attention of:
Kubota Holdings Europe B.V.
Compliance Department
Data Privacy Counsel
Hoofdweg 1264
2153 LR Nieuw-Vennep
The Netherlands
All rights reserved – Kubota Holdings Europe B.V.
Last update: January 1st, 2026
Appendix 1: List of Kubota Companies
| Kubota Europe SAS – 19-25 Rue Jules Vercruysse, 95100 Argenteuil, France |
| Kubota Europe SAS Italian branch – SP Nuova Rivoltana 2/A 29, 20054 Segrate, Italy |
| Kubota Europe SAS Netherlands branch – Rietveldstraat 22, 8013RW Zwolle, The Netherlands |
| Kubota Research and Development Europe SAS – 80 Rue du Bois Tillet, 60800 Crépy-en-Valois, France |
| Kubota Farm Machinery Europe SAS – Route de Socx, 59380 Bierne, France |
| Kubota (Deutschland) GmbH – Senefelder Strasse 3-5, 63110 Rodgau/Nieder-Roden, Germany |
| Kubota (Deutschland) GmbH Sp. z o.o. Oddział w Polsce – Baletowa 82, 02-867 Warszawa, Poland |
| Kubota Baumaschinen GmbH – Steinhauser Strasse 100, 66482 Zweibrücken, Germany |
| Kubota Baumaschinen GmbH Netherlands branch – Via Raeka 16, 6003NK Weert, The Netherlands |
| Kubota Brabender Technologie GmbH – Kulturstrasse 49, 47055 Duisburg, Germany |
| Kubota Brabender Technologie Inc. – Kestrel Road 6500, L5T 1Z6 Mississauga, Ontario, Canada |
| Kubota Brabender Technologie (Beijing) Co Ltd – 3rd F,B Section, No 3 Workshop, 2nd Project of Guanglian Industrial
Park, No 2 Kechuang East 5th Rd, 101111 Beijing, China |
| Kubota (U.K.) Ltd – Dormer Road, OX9 3UN, Thame, Oxfordshire, United Kingdom |
| Kubota Gianni Ferrari Srl – Via Vespucci 53, 42046 Reggiolo, Italy |
| Pulverizadores Fede SLU – Polígono industrial Castilla, vial 3, parcela 61G – 61 F, 46380 Cheste, Spain |
| Fede USA LLC – 1444 Biscayne Boulevard, suite 212, 33132 Miami, United States of America |
| Beijing Fengmao Fede Agricultural Machinery Co. Ltd – Workshop 2, No 15, Yanqi North Third Street, Yanqi Economic Development Zone, Huairou District, Beijing, China |
| Ambimetrics SL – Carrer del Mestre Arrieta 53 B, 12006 Castellon de la Plana, Spain |
| Kubota Espana SA – Calle Fernando Alonso 15, 28914 Leganes, Madrid, Spain |
| Kverneland AS – Plogfabrikkvegen 1, 4353 Klepp stasjon, Norway |
| Kverneland Group Operations Norway AS – Plogfabrikkvegen 1, 4353 Klepp stasjon, Norway |
| Kverneland Holding France SAS – 275 Avenue du Ruet, 45760 Marigny-les-Usages, France |
| Kverneland Group France SAS – 275 Avenue du Ruet, 45760 Marigny-les-Usages, France |
| Kverneland Group Metz SAS – 17 Rue des Terres Rouges, 57100 Thionville, France |
| Kverneland Group Les Landes-Genusson SAS – 9 Rue du Poitou, 85130 Les Landes-Genusson, France |
| Kverneland Group Europe BV – Hoofdweg 1278, 2153LR Nieuw-Vennep, The Netherlands |
| Kverneland Group Nieuw-Vennep BV – Hoofdweg 1278, 2153LR Nieuw-Vennep, The Netherlands |
| Kverneland Group Mechatronics BV – Hoofdweg 1278, 2153LR Nieuw-Vennep, The Netherlands |
| Kverneland Group Benelux BV – De Dommel 38-40, 8253PL Dronten, The Netherlands |
| Kverneland Group Benelux BV, Belgium branch – Oude Gentweg 81, 8820 Torhout, Belgium |
| Kverneland Group Holding (DE) GmbH – Coesterweg 42, 59494 Soest, Germany |
| Kverneland Group Deutschland GmbH – Coesterweg 42, 59494 Soest, Germany |
| Kverneland Group Soest GmbH – Coesterweg 42, 59494 Soest, Germany |
| Kverneland Group International GmbH – Coesterweg 45A, 59494 Soest, Germany |
| Kverneland Group Gottmadingen GmbH – Industriepark 312, 78244 Gottmadingen, Germany |
| Kverneland Group Iberica SA – Polígono Industrial Zona Franca, Sector C, Calle F 28, 08040 Barcelona, Spain |
| Kverneland Group Holding (DK) A/S – Taarupstrandvej 25, 5300 Kerteminde, Denmark |
| Kverneland Group Denmark A/S – Taarupstrandvej 25, 5300 Kerteminde, Denmark |
| Kverneland Group Kerteminde A/S – Taarupstrandvej 25, 5300 Kerteminde, Denmark |
| Kverneland Holding (UK) Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Kverneland Group UK Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Vicon Agricultural Holding Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Kverneland Devizes Ltd – Walkers Lane, Lea Green, WA9 4AF, St Helens, Merseyside, United Kingdom |
| Kverneland Group Italia Srl –Via dell’Industria 22/A, 46043 Castiglione delle Stiviere, Italy |
| Kverneland Group Ravenna Srl – Via Alcide De Gasperi 34, 48026 Russi, Ravenna, Italy |
| ROC Srl – Via delle Industrie 2, 47824 Poggio Torriana, Italy |
| ROC America LLC – c/o The Corporation Trust Company, Orange Street 1209, 19801 Wilmington, Delaware, United States of America |
| Kverneland Group Sverige AB – Sätervägen 1, 60597 Norrköping, Sweden |
| Kverneland Group Ireland Ltd – Hebron Industrial Estate, R95 R2TA Kilkenny, Ireland |
| Kverneland Group Polska Sp. z o.o. – Kreta 87, 87-100 Torun, Poland |
| Kverneland Group Hungaria Kft – Karinthy út 63, 5008 Szolnok, Hungary |
| Kverneland Group CIS OOO – Novodmitrovskaya 2/2, 127015 Moscow, Russia |
| Kverneland Agricultural Equipment (Daqing) Co. Ltd – Industrial Park of Petroleum and Petrochemical Equipment Manufacturing, Daqing New High Tech Industrial Development Zone, Plant on the East Side, No 3, 163316 Daqing, China |