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Hitachi

Hitachi High-Technologies GLOBAL

Through an approach based on ethics and integrity, and putting right and wrong over profit and loss, we are striving to ensure thorough compliance, with the aim of building an enterprise trusted by all our stakeholders.

Basic Approach

As any violation of laws and regulations or a scandal would hinder Hitachi High-Tech Group's basic philosophy of being trusted by all our stakeholders and severely damage corporate value, the Group holds thorough compliance (complying with laws, company rules, social justice, public order, and standards of decency, etc.) as the premise for all our business activities. Through an approach of surely practicing judgement and conduct based on ethics and integrity, and on putting right and wrong over profit and loss, we are conducting initiatives including the operation of an internal reporting system and the implementation of compliance education and awareness-raising activities for employees in an effort to promote compliance activities throughout the Group.

Organization

Compliance Framework

The Group has established the Compliance Committee, which meets regularly to discuss, on a Company-wide basis, the status of compliance risks, plans for countermeasures to reduce the risks, and the status of implementation of such measures. More specifically, responsibility for addressing each particular type of risk has been assigned to a specific department; the head of the department in charge of tackling a particular type of risk envisages and evaluates that risk, as well as implementing measures to deal with it, such as providing in-house education concerning relevant legislation and internal rules. In addition, the manager concerned identifies new compliance risks that are a concern. If a compliance related incident occurs, the Company will hold an ad hoc meeting to determine the facts, trace the causes, take corrective measures and discuss how to prevent recurrence.

In addition, the heads of business groups, branch offices, and Group companies appoint Compliance Managers for their respective organizations. The Compliance Managers work under the direction of the Chairperson of the Compliance Committee (who is responsible for compliance throughout the Group) to manage the compliance system of their respective organizations by constructing compliance systems within their respective organizations, implementing compliance measures and reporting to the Compliance Committee. With regard to compliance risk, each organization conducts regular revisions and self-checks whether its risk activities are appropriate.
The Group has designated October as its annual Corporate Ethics Month, during which each managing unit conducts compliance education and other initiatives aimed at ensuring thorough awareness of the need for corporate ethics and compliance.

Establishment of Whistleblowing Hotline

The Hitachi High-Tech Group has established a whistleblowing hotline, available to full-time employees, temporary agency workers, part-time workers, and fixed-term employees, for quickly detecting and responding to illegal or unethical activities. The whistleblowing hotline is operated in line with the legal system in each country and the business structure of each company. In April 2019, the Company established the HHT Group Global Hotline, a hotline for employees of overseas group companies to report to the Company's division in charge of compliance, thereby strengthening the internal whistleblowing system at overseas group companies. Information provided to the whistleblowing hotline is reported to the Compliance Committee and the Internal Control Management Committee.
In addition, the Company has been operating the Independent-from-Management Whistleblowing Hotline, which enables direct reporting to members of the Audit Committee if a whistleblower finds directors or executive officers violate laws or regulations in conduct of business.
In operating all these whistleblowing hotlines, the Company very strictly protects the confidentiality of whistleblowers' identities, and accepts anonymous reports. Furthermore, the Company prohibits any negative treatment of a whistleblower for having made an internal report.

Process of a Whistleblowing Hotline
Diagram: Process of a Whistleblowing Hotline

Initiatives

Compliance Education and Awareness Activities

We strive to ensure thorough compliance via ongoing compliance education for all levels of the company, from new staff to management executives.
We provide rank-specific training courses that provide participants with an understanding of the company's approach to compliance, compliance system, and whistleblower system. Case studies are also used during these courses to further improve compliance awareness.
The Legal Department and relevant departments also provide training courses and e-learning opportunities for employees who require a knowledge of specific laws and regulations in the course of their duties.
Furthermore, at each workplace, the managerial staff play a central role in using OJT* in the course of day-to-day operations to ensure full awareness of compliance and implement various measures.

  • * On-the-Job Training: Education and training provided to employees through business practice in the workplace.

Hitachi High-Technologies Global Compliance Program (HGCP)

Basic Approach

The Group develops business activities deeply rooted in corporate ethics and compliance, conforming to ethics and integrity. Hitachi High-Tech Group Codes of Conduct have been established for that very purpose, and form the basis for the Hitachi High-Technologies Global Compliance Program.
The Program mainly addresses the following three points: prevention of bribery, compliance with competition laws, and prevention of anti-social transactions.

Diagram: Hitachi High-Tech Group Code of Conduct

Prevention of Bribery

Bribery of government officials for purposes of commerce in company activities is illegal, and moves to strictly clamp down on bribery are spreading around the world. From a global perspective, the Group is working toward thorough prevention of bribery by establishing company rules on preventing bribery, global guidelines for examining third-party compliance, and global guidelines for procedures concerning entertainment, gift exchange, and so on. We will continue our thorough efforts through various form of training.

Compliance with Competition Laws

The Group supports fair and free market competition, and complies with international and domestic competition laws.
For the purpose of preventing, detecting, and dealing with conduct likely to restrict free competition, the Group has established rules on compliance with competition laws in all Group companies and organizations.

Prevention of Anti-Social Transactions

In order to more surely eradicate all connections with antisocial forces, we have stipulated a management structure and procedures for prohibiting and preventing anti-social transactions in company rules. The specific measures for doing so are described as follows:

  1. We have established a specialist body (the Business Ethics Council) to facilitate Group-wide management of the gathering of information about preventing transactions with anti-social forces, efforts to educate and raise awareness among all employees, and relevant procedures. The Council meets once a year to discuss the results of inspections carried out by each base and check that there are no problems to be addressed. In addition, the prevention of transactions with anti-social forces is covered in rank-specific education.
  2. In our efforts to act decisively to eliminate approaches from anti-social forces, we work in partnership with Group companies, the police, lawyers, and external organizations (such as the Special Violence Prevention Measures Association (Tokubouren) )
  3. In accordance with organized crime exclusion ordinances in force nationwide, we are including clauses concerning the exclusion of organized crime groups in our contracts, to ensure that we can terminate the relationship by such means as canceling the contract, in the event that we discover that the counterpart constitutes an anti-social force.

Anti-corruption Initiatives

The Hitachi High-Tech Group has established regulations related to the prevention of bribery as part of the HGCP, and is striving to ensure compliance by making guidelines on entertainment, gift exchange, and donations. The regulations and guidelines prohibit payments to government officials to facilitate mechanical procedures for permits and licenses, immigration control, customs clearance, etc. (in other words "facilitation payment"), and clarify procedures for the examination of transactions. The examination of transactions concerns more than just the level of social trust in all parties making requests for transactions and the places that provide products and services; we determine high risk, medium risk, and low risk, based on elements of risk involved in relations/contact with government officials, and carry out surveys in line with the determinations.
In addition, we are also working hard to prevent corruption by establishing guidelines on the employment of current/former government officials and employees’ due diligence.
We were not involved in any cases of violations or sanctions concerning bribery in FY2018.

Results of the Group's anti-corruption initiatives in the last three years
Indicator FY2016 FY2017 FY2018
Number of cases subject to inspection by the authorities for suspicion of violation of an anti-bribery law* 0 0 0
Expense incurred by a fine, penalty, or settlement for a violation of an anti-bribery law 0 yen 0 yen 0 yen
Number of cases of an employee being subject to legal punishment for violating an anti-bribery law 0 0 0
  • * Including the Penal Code and Unfair Competition Prevention Act of Japan, the U.S. Foreign Corrupt Practices Act, the UK Bribery Act 2010, and laws in other countries and regions that concern anti-corruption and government officials’ ethics, or provide for punishments related thereto (including laws for implementation of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the United Nations Convention against Corruption).

Wide-spread Awareness of and Strict Adherence to Hitachi High-Tech Code of Conduct

In 2011, the Group formulated the Hitachi High-Tech Group’s Codes of Conduct, which stipulate behavior that the Group’s employees should adopt and points for compliance. The Group is pursuing widespread awareness of the Code through such measures as level-specific training and e-learning. In July 2018, we revised the Code by reflecting in it modern demands, such as SDGs, which include the creation of a sustainable society, human rights and workstyles, and a variety of risk management. The Code has been translated into nine languages other than Japanese and been shared globally throughout the Group. In addition, the Group’s employees around the world are learning about the Code using multilingual e-learning resources.