Every action matters. Speak up!
Questions and Answers
Hitachi is committed to conducting business with fairness, integrity, respect for the law, and our Mission, Values, and Vision.
Despite this commitment, you may observe conduct that concerns you or that seems to violate the Hitachi Group Code of Ethics and Business Conduct or our policies, regulations and protocols. If you observe or suspect misconduct, you are encouraged to speak up. You allow Hitachi to investigate and address the issue by doing so. Remaining silent about potential misconduct may worsen the situation and undermine Hitachi’s reputation and trust.
Hitachi values the help of employees who identify and speak up about potential concerns. Speaking up is encouraged, and employees who speak up are protected from retaliation if they raise their concerns in good faith.
HITACHI GLOBAL COMPLIANCE HOTLINE OVERVIEW
What is the Hitachi Global Compliance Hotline?
The hotline, including online intake or by phone, is one of our speak-up channels to raise concerns about ethical issues and potential misconduct. It is a service Hitachi offers for current and former employees, officers, customers, suppliers and other stakeholders.
Who operates the hotline?
NAVEX, an independent third party, operates the hotline.
Why do we have the Hitachi Global Compliance Hotline?
Hitachi is committed to creating and maintaining an environment where anyone can raise concerns about ethical issues and potential misconduct without fear of retaliation. Like many global companies, Hitachi provides the Hitachi Global Compliance Hotline as an optional service for employees to speak up.
Discuss questions and concerns with your manager. If not, the Hitachi Global Compliance Hotline provides an additional way to receive help if you feel uncomfortable asking questions or expressing concerns to management.
When should I use the Hitachi Global Compliance Hotline?
Use the hotline if you have concerns about ethical issues and potential misconduct. Alternatively, you could raise your concern through your management, HR or Legal. Your decision to use the hotline is voluntary.
ETHICAL CONDUCT CONCERNS
What is an ethical concern or issue?
An ethical issue includes any actual or suspected breach of Hitachi Group’s Code of Ethics and Business Conduct and any other improper or illegal conduct. It also includes any violation of the Hitachi Group’s Code of Ethics and Business Conduct by our third parties who have committed to obeying it.
The hotline does not cover employee grievances, complaints relating to job performance, or the terms and conditions of employment. These issues are not complaints that relate to potential malpractice or material misconduct.
What category or types of concerns should I raise?
The table below shows examples of ethical issues.
| Bribery and corruption | Unlawful or improper offering payments and money laundering |
| Conflict of interest | Allegations of conflicts of interests existing between an employee and family members |
| Corporate Policy Violations | Hitachi Group Code of Ethics and Business Conduct and policy or protocol violation |
| Data Privacy Violation | Cyberfraud (impersonation, phishing or spoofing), data privacy violation, disclosure or misuse of personal data |
| Disclosure of confidential information | Disclosure of company confidential information or disclosure of third-party confidential information |
| Facilitation Payments | The offering of an amount of money or advantage to a public official in order to expedite or secure a routine government action |
| Fair Competition | Bid rigging, market collusion or price fixing |
| Fraud | Counterfeiting, fictitious purchases or vendors or trading on insider information |
| Harassment and Discrimination | Employment or labor law violation, sexual harassment, workplace discrimination, or workplace harassment |
| Health, safety and environment | Environmental violation, Nuclear safety or operational safety |
| Human rights violation | Fair trade violations, human rights issues or modern slavery |
| Legal or contractual issues | Allegations that concern breakdowns in legal agreements |
| Misuse or theft of Hitachi assets | Improper use of Hitachi information systems and misuse of Hitachi resources |
| Partner integrity | Contract conditions breach, false reporting or misrepresentation |
| Product or services quality concerns | Misconfiguration or unnecessary services, products or services quality concerns |
| Security | Possession of prohibited items, terrorist incident, theft or robbery |
| Trade compliance | Export or trade compliance issues |
| Violation of financial records or results | Violation of financial records, management accounting issues and revenue recognition issues |
Why should I report what I know? What is in it for me?
We all have the right to work in a positive environment. With that right comes the responsibility of acting ethically and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment. Corporate misconduct can threaten the livelihood of an entire company.
Does management want me to raise my concerns?
Yes. Hitachi requires employees to raise concerns as soon as they become aware of potential misconduct. Raising a concern can minimize the possible negative effect on Hitachi and our people regarding financial, legal or reputational risks and health and safety threats.
Should I raise the concern first with my manager, HR or Legal?
If you are unsure whether the concern is justified and you feel comfortable contacting your management, HR or Legal, please do so. Contact the hotline if you do not feel comfortable raising the concern with your manager or management, and HR or Legal confirms that your concern could be an ethical issue or potential misconduct.
What if my manager or other managers are involved in a concern?
Only a select number of respective Hitachi Group Company compliance team members in charge of the investigation have access to reports. The EthicsPoint system and distribution protocols are designed so any individuals named in the report are not notified about or granted access to reports in which they have been named.
Can I get in trouble for using the Hitachi Global Compliance Hotline?
No. Hitachi provides the hotline for your use and protection. Retaliation against anyone who raises an ethical concern in good faith is unacceptable. If a reporter informs Hitachi about retaliation, Hitachi takes this seriously and investigates. Hitachi will discipline anyone who engages in retaliation.
CONFIDENTIALITY
I understand that any report I send from a company computer generates a server log that shows every website with which my computer connects. Will this log identify me as a report originator?
EthicsPoint does not generate or maintain any internal connection logs with IP addresses, so no information linking your computer to Ethics Point is available. EthicsPoint is contractually committed to not pursuing a reporter’s identity. If you feel uncomfortable making a report on your work PC, use a PC outside our work environment (such as one located at a friend’s house or a public library or internet café) through the EthicsPoint secure website.
Is the Hitachi Global Compliance Hotline secure?
Yes. Your concern or question is entered directly onto the EthicsPoint server over a secured connection. EthicsPoint’s servers do not connect to Hitachi’s information technology systems. Only a select number of global departments within your respective Hitachi Group Company responsible for managing and following up on your report have access to this information.
May I remain anonymous?
You may remain anonymous in all countries except those that prohibit anonymous reporting. Although it may be easier in many cases to address your issue by identifying yourself, you are not required to do so. If you remain anonymous, EthicsPoint or Hitachi will not make an effort to identify you.
Can I communicate with the investigators while remaining anonymous?
Yes. When you report a concern via the hotline, the system will provide a report key and prompt you to select a password.
Store the report key and password in a safe place. With this key, the investigators can maintain communication with you. They, or you, could ask for further information and provide feedback to you where necessary.
SPEAK-UP: ONLINE OR PHONE
How do I use the Hitachi Global Compliance Hotline?
The hotline has two methods of intake. With EthicsPoint, you can raise a concern in confidence by web intake or by telephone. Choose one channel, do not duplicate the report by using both channels.
Web intake portal
The first channel is the intake portal. The intake form consists of questions to identify the relevant details of your concern or question and is to understand:
- what happened,
- who are involved,
- where and when did it happen and;
- how did it happen.
The web intake portal is available 24 hours a day, seven days a week, every day of the year. You may access it from any computer that has an internet connection.
If you have documents, photos, recordings or videos, you could upload to the web intake portal.
Toll-free telephone by country
The second channel is a toll-free telephone number by country. This service is available 24 hours a day, seven days a week, every day of the year. A professionally trained EthicsPoint operator will guide you through a series of questions to identify the relevant details of your concern or question to understand:
- what happened,
- who are involved,
- where and when did it happen; and
- how did it happen.
The operator will also ask you to provide supporting documentation, if available. If you have documents, photos, recordings or videos, you could upload them to EthicsPoint after you complete the report, and the system generates the encryption key.
At the conclusion of the call, the operator will summarize the information you have submitted and make any necessary changes to ensure that you are satisfied with the accuracy of your question or concern.
The hotline offers toll-free numbers in countries where Hitachi operates and is available in more than 50 languages. Multilingual operators are available so callers can ask questions or raise concerns in their native or preferred language.
May I partially complete the form and return to complete it later?
No. If you close your internet browser while completing the form, the EthicsPoint web intake portal will not save the information you have entered, so choose a time and place to use the system to complete the form.
What information do I need to provide?
Provide information in as much detail as possible. Details should include the who, what, when, where, why, and how concerning the allegation(s) raised. If possible, you can attach evidence such as documentation or emails that help substantiate your claim(s). Reports that do not reasonably satisfy conditions of completeness may not be reviewed or investigated further.
What should I do if the system does not list the concerned location?
Select a nearby country and include the actual location in the case description.
ETHICAL CONDUCT QUESTIONS AND INVESTIGATION PROCESS
What happens when I ask a question?
When you ask a question, the system will direct it to the respective Hitachi Group Company compliance team, who will respond to you through the hotline.
What happens when I raise a concern?
Whether made by web intake or telephone, all concerns are reviewed promptly by a professionally trained EthicsPoint intake specialist. The EthicsPoint intake specialist will send a report to the designated global department within your respective Hitachi Group Company responsible for managing and following up on your report.
The appointed team members will start the investigation if you provide sufficient details.
If necessary, Hitachi will take appropriate remedial action while the investigation is ongoing. Those responsible for following up on your matter are trained professionals who handle the issue with discretion.
All reports, through web intake or telephone, are entered into a database for recordkeeping and case management. Only representatives within your respective Hitachi Group Company have access to this information.
Do I receive confirmation of my report? What is the timeframe of confirmation?
Yes. You receive a confirmation that your report has been received, usually within one to seven business days. After the conclusion of the investigation, you will receive a message notifying you that the investigation has been closed. The email will indicate that all appropriate actions, if or where necessary, have been taken. You do not receive details about the investigation for confidentiality reasons.
FOLLOW-UP ON REPORTED CONCERNS
What if I remember something important about the incident after completing the intake form?
When you raise a concern, either using the web or by telephone, the system will provide a report key and prompt you to select a password.
With the report key and password, you can return to the EthicsPoint system by Internet or telephone and access the original report. At that point, you can add more details.
How will I receive information on the status of my case?
The system will provide a report key and prompt you to select a password. Record the report key and password and keep them in a safe place. Use your report key and password to re-contact EthicsPoint to check on the status of your case, provide more information, or answer follow-up questions from those investigating the matter.
If I remain anonymous, how can investigators contact me for a follow-up?
When given your report key and password, you can follow up with EthicsPoint by telephone or web, even if you report anonymously. If an investigator wants to contact you regarding your concern, the investigator can leave you a message or ask you a question through EthicsPoint.
What should I do if I lose my report key or password?
Because of the confidentiality level maintained for reports, the process requires you to file a new report if you lose your report key or password. You can mention in the latest report that this matter relates to another report you filed earlier.