Through an approach based on ethics and integrity, and ethical grounds rather than immediate profitability, we are striving to ensure thorough compliance, with the aim of building an enterprise trusted by all our stakeholders.
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 ethical grounds rather than immediate profitability, we are conducting initiatives including the operation of an internal reporting system and the implementation of compliance education and awareness-raising activities for emplboyees in an effort to promote compliance activities throughout the Group.
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 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.
The Hitachi High-Tech Group has introduced the Hitachi Group unified whistleblowing hotline system (for Japan and overseas) for the purpose of quickly detecting and responding to incipient legal violations and improper conduct. The system can be used by executives, employees, senior employees, partner employees, temporary agency workers, retired personnel, and so on. We are taking these steps in order to enhance our self-correcting functions in order to quickly detect and respond to incipient legal violations or improper conduct.
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 and compliance departments and other relevant departments also provide training courses, e-learning, and other such education 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.
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 Group Compliance Program.
The Program mainly addresses the following three points: prevention of bribery, compliance with competition laws, and prevention of anti-social transactions.
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 regulations determining procedures to follow before and after entertainment, gift exchange, and so on. We will continue our thorough efforts through various form of training.
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.
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:
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 procedural rules for entertainment, gift exchange, and donations. The regulations, rules, 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. When examining transactions, we assess risks based on the social credibility of business partners who have made requests to engage in new transactions, the provision site of products and services, relationships and contacts with public official, and other risk factors and conduct investigations based on the assessment results. In some instances, the Group requires the implementation of due diligence that includes matters relating to bribery and corruption prevention to make decisions regarding risk assessments when commencing business with a new business partner. This due diligence process also applies when selecting sales agents.
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.
The Group formulated the Hitachi High-Tech Group Codes of Conduct and informs employees about them through rank-specific training, e-learning, and other means. In addition to the Japanese version, the Codes have been prepared in nine other languages and provided to all Group companies throughout the world. In addition, Group employees globally undergo training on the Codes using e-learning materials that have been translated into multiple languages.
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