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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.

Compliance Framework

Basic Approach

Based on its Risk Management Rules and Compliance Rules, Hitachi High-Tech Group has established the Compliance Committee, which meets regularly to discuss the status of compliance risk, plans for measures to address this, and the implementation status 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 problem should occur, an extraordinary meeting is held, at which the Committee discusses its investigation into the facts at issue, inquires into root causes, recommends corrective action, and proposes measures to prevent reoccurrence.

The Group has established the position of Compliance Manager with responsibility for compliance at each business unit, branch office, and Group company (hereinafter "managing unit"; these Compliance Managers are hereinafter referred to as "managing unit CMs"). The Chair of the Compliance Committee is building a system for implementing various measures that will enable each managing unit CM as the Hitachi High-Tech Group' s Head of Compliance, to ensure full awareness of compliance-related rules and notices throughout each management unit and to ensure that training and other awareness activities are conducted.
Each managing unit reviews its own compliance risk regularly and checks whether or not its activities to address risk are appropriate.

The Hitachi High-Tech 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.

Misconduct and violations of laws, regulations, and rules impede the Hitachi High-Tech Group' s basic philosophy of being trusted by all our stakeholders and substantially harm our corporate value, so the Hitachi High-Tech Group regards thorough compliance (adhering to laws, internal regulations, social justice, and public morals etc.) as the basic premise of all of our corporate activities. Under our policy of consistently basing our decisions and behavior on ethics and integrity, and putting right and wrong over profit and loss, we are promoting compliance activities throughout the Group with operating a whistleblower reporting system and conducting activities to provide compliance education and information for our employees.

Establishment of the Whistleblower Reporting Service

In January 2004, we established a whistleblower reporting service to uncover and address violations of the law and incipient fraud as early as possible. In April 2004, we extended the definition of whistleblowers to include temporary agency workers, casual workers, and special fixed-term employees. Whistleblowers can choose to contact an external third-party organization and to report issues anonymously. The information provided to this reporting service is passed on to the Compliance Committee.

To ensure that this system operates effectively, the rules stipulate that the results of the investigation and any improvements or corrective measures must be reported to the whistleblower, with protection of the whistleblower as the top priority.

We also operate a whistleblower system at our overseas Group companies; the division with responsibility for compliance within the overseas Group companies or an external organization is assigned as the designated point of contact for each major headquarters, according to the legal system in the country concerned and the corporate structure of the company in question. Major issues can also be reported to this company' s point of contact for compliance issues. To ensure that this system becomes even more firmly established in future, we will use the intranet and compliance training to inform employees about the reporting service. Furthermore, since January 2016, we have established a whistleblower reporting service that is independent of management, which makes it possible to report to members of the Audit Committee with regard to breaches of laws relating to conduct of business by directors and executives etc., as well as strengthening our whistleblower system.

Whistleblower Reporting Process

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*1 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 practical training in the workplace.

Preventing Anti-social Transactions

Basic Approach

To further strengthen the Group' s efforts to eliminate relationships with anti-social forces, we specify in our guidelines on business practice that we "will base our actions on the law and correct corporate ethics, with an awareness of our social mission and responsibility." To translate this basic philosophy into reality, the company rules prohibit transactions with anti-social forces and prescribe the management system and procedures for preventing such transactions.

Specific Initiatives

  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.

Preventing Bribery of Public Officials in Japan and Overseas

As corporate activities become increasingly globalized and borderless, a growing awareness is emerging worldwide of the need to prevent the bribery of public officials for commercial purposes.

In an effort to prevent bribery throughout the Group, we have prescribed company rules concerning the prevention of bribery from a global perspective and prior procedures concerning an entertainment or an exchange of gifts. Clauses concerning the prevention of bribery have also been included in the Hitachi High-Tech Group Code of Conduct, which prescribes the specific standards of conduct by which all Group officers and employees should abide. Going forward, we will continue to ensure thorough adherence to these rules through various forms of education.

Export Management

Basic Approach

We comply with the Foreign Exchange and Foreign Trade Act (Foreign Trade Act) and agreements related to international trade in order to contribute to international peace and safety through export management. We maintain management systems and internal management regulations, as well as manage export-related tasks with the aim of achieving safer and more secure export management, all while complying with the laws and regulations of each foreign country to which we export. Furthermore, we are constantly on the lookout for opportunities to leverage the knowhow that we have accumulated through our export management as efficiently as possible in import support tasks.

Export Management Organizational Chart

Import Management

Basic Approach

We have established an import management system in order to effect thorough compliance with domestic laws relating to the regulation of imports. Specifically, we have established internal regulations relating to import transactions, and made it clear that our legal research procedures include confirming whether the articles to be imported are regulated by domestic laws before import occurs. If they are regulated, ensuring that steps to ensure compliance are thoroughly implemented.

We provide on-site assistance for import-related tasks and conduct compliance management in order to be able to exhaustively apply for all permissions and approvals, etc. required by law.

Response to the Conflict Minerals Issue

Hitachi High-Tech Group's policy is to not use conflict minerals in our products and commercial goods. Conflict minerals include columbite-tantalite, cassiterite, gold, and wolframite, mined in the Democratic Republic of Congo (the "DRC") and adjoining countries (together the "DRC countries"), which may be used to finance conflicts. Hitachi High-Technologies has constructed a conflict minerals survey for suppliers and is promoting it within the company. We will continue our efforts to procure minerals that are not mined in conditions of armed conflict and human rights abuses.