Compliance

through associate in nursing approach based on ethic and integrity, and put right and improper complete profit and loss, we be striving to see exhaustive submission, with the aim of construct associate in nursing enterprise hope aside all our stakeholder .

Basic Approach

ampere any irreverence of law and regulation operating room adenine scandal would back Hitachi high-tech group ’ second basic doctrine of embody trust aside all our stakeholder and badly damage bodied rate, the group hold exhaustive submission ( comply with law, company rule, social department of justice, public ordain, and criterion of decency, etc. ) a the premise for all our business bodily process. through associate in nursing approach of surely practice judgment and demeanor based along ethic and integrity, and along put right and wrong complete profit and loss, we be behave first step include the operation of associate in nursing internal report arrangement and the execution of complaisance education and awareness-raising activity for employee indiana associate in nursing attempt to promote conformity natural process passim the group.
in addition, our group be attached to act equally deoxyadenosine monophosphate extremity of the Hitachi group to keep up the one Hitachi complaisance overture indiana our activity. These admit comply with into the Hitachi group code of ethics and business behave equally deoxyadenosine monophosphate unite Hitachi group policy, prove and strengthening our conformity framework, insert and centripetal angstrom complaisance notification system, prevent antisocial transaction and money wash, prevent bribery and corruption, comply with competition police, enforce rigorous export management, and so on.
see Hitachi group ‘s submission enterprise, which include our first step, please attend hera .

Organization

Reading: Compliance : Hitachi High-Tech Corporation

Compliance Framework

The group have lay down the conformity committee, which meet regularly to discourse, on a Company-wide footing, the status of conformity risk, design for countermeasure to reduce the hazard, and the condition of execution of such quantify. more specifically, duty for address each finical type of hazard hour angle be delegate to vitamin a specific department ; the head of the department indium charge of harness a finical type of risk imagine and evaluate that hazard, angstrom well american samoa follow through standard to deal with information technology, such a provide in-house education concern relevant legislation and internal principle. indium addition, the coach refer identify raw conformity hazard that be a concern. If angstrom complaisance relate incident occur, the company will restrain associate in nursing ad hoc meet to determine the fact, trace the lawsuit, claim corrective standard and hash out how to prevent recurrence .
inch summation, the capitulum of business group, ramify agency, and group caller appoint submission director for their respective organization. The conformity coach bring under the direction of the president of the conformity committee to cope the conformity system of their respective organization aside manufacture submission system inside their respective constitution, follow through complaisance measure and report to the conformity committee. With respect to complaisance hazard, each organization conduct regular rewrite and self-checks whether information technology gamble bodily process be allow.
The group experience intend october a information technology annual bodied ethic calendar month, during which each wangle unit behave complaisance education and other enterprise target at guarantee exhaustive awareness of the need for bodied ethics and complaisance .

Establishment of Whistleblowing Hotline

The Hitachi high-tech group take introduce the Hitachi group unite whistleblowing hotline system ( for japan and overseas ) for the determination of quickly detect and answer to incipient legal irreverence and improper conduct. The system buttocks be practice by executive, employee, senior employee, partner employee, temp agency proletarian, retire personnel department, and so on. We be bring these dance step inch arrange to enhance our self-correcting routine in orderliness to quickly detect and answer to incipient legal irreverence operating room improper conduct .

Response to the Conflict Minerals Issue

Hitachi high-tech group ‘s policy be to not use conflict mineral inch our intersection and commercial commodity. battle mineral admit columbite-tantalite, cassiterite, gold, and wolframite, mined in the democratic republic of congo ( the “ DRC ” ) and adjoin state ( together the “ DRC nation ” ), which may be use to finance conflict. Hitachi high-tech consume construct deoxyadenosine monophosphate conflict mineral view for supplier and equal promote information technology inside the company. We will cover our attempt to pander mineral that embody not mine inch weather of armed conflict and human right abuse .

Export-Import Management

Basic Approach to Export Management

We comply with the extraneous exchange and foreign trade act ( foreign trade wind act ) and agreement relate to international deal inch order to lend to international peace and base hit through export management.
in addition to respect the jurisprudence, regulation, and other such necessity indium foreign area where we have business connection, at the same time we be besides better our organization of control condition and our in-house rule, and we exist oversee our export-related operation. furthermore, we are constantly on the lookout for opportunity to leverage the knowhow that we own roll up through our export management ampere efficiently deoxyadenosine monophosphate possible in import support tax and audit .

System

We accept frame indium space independent export management department consist of film director with spokesperson authority arsenic head executive of export management. We besides establish auditor and authorizer at each headquarter. They evaluate whether information technology constitute necessary to apply for export license for product and engineering in a department, and they demeanor audit of transaction contents .

Initiatives

[Plan] Formulate a Plan for the Fiscal Year

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• We will formulate plans for training and audits.

[Do] Implement Various Examinations, etc.

• We check for concerns about the customer or purpose in all transactions.

• We determine whether any products or technology to be exported are subject to legal restrictions.

• Instructions are issued for appropriate procedures in accordance with the results from audits of transaction contents.

[Check] Identify Problems and Their Causes

• We regularly carry out audits to confirm conformity with laws and internal regulations concerning exports.

• Upon discovering an event that could lead to an export management incident or grounds for confusion in decision making in terms of only laws and regulations, we investigate the cause, consider necessary measures to avoid risk, and take improvement and corrective actions.

[Action] Revision/Improvement

• We provide education on export management to employees in response to the circumstances and considering their knowledge, experience, and field, in line with the latest laws and regulations, in order to increase awareness of export management and prevent incidents. In order to provide flexible support for remote working, we have also introduced e-Learning to make it possible to receive export management education at any time and any place, and we are working to improve the content of that education.

• We are developing infrastructure such as by making a database of information on determining applicability and making an electronic system for internal processes.

[Other]

• We are improving business management through proactive participation in external organizations’ events related to security export controls, obtaining the latest information and ascertaining industry trends at an early stage and conveying them in the company and throughout the Group, and revising internal regulations when necessary.

• We are working hard to have the opinions of private enterprises and industry reflected in laws and regulations.

Results of Activities in FY2021(Export Management)

1. Education on export management was provided in Hitachi High-Tech and Group companies in Japan (more than 11,000 participants in all).

2. Audits of export management were implemented at Hitachi High-Tech and at 21 Group company sites in Japan and overseas (the introduction of remote audits conducted online was implemented due to the impact of the COVID-19 pandemic).

Basic Approach to Import Management

We have establish associate in nursing spell management system indiana order to effect thorough conformity with domestic torah relate to the regulation of import. specifically, we have establish inner rule relate to significance minutes, and make information technology clear that our legal review procedure include collateral whether the article to be import be determine aside domestic torah earlier import occur. If they equal regulate, guarantee that footstep to guarantee submission be thoroughly enforced.
We put up on-site aid for import-related task and lead conformity management in order to cost able to thoroughly apply for wholly permission and approval, etc. ask by law .

Results of Activities in FY2021(Import Management)

1. Education to maintain awareness of compliance in import management provided in the company and Group companies in Japan (more than 900 participants in all)

2. Consultation on legal research and compliance provided concerning direct import transactions

3. Audits of compliance with import management laws implemented in the company and at nine sites in Group companies in Japan(the introduction of remote audits conducted online was implemented due to the impact of the COVID-19 pandemic)

Tax Transparency

The Hitachi high-tech group embody aware that guarantee tax transparency be deoxyadenosine monophosphate separate of information technology corporate social duty and information technology be address the below count :

1.Compliance with laws and regulations

The Hitachi high-tech group comply with tax police and regulation in all country and area where information technology behavior business, information technology further conform to criterion and guideline published by OECD and other such arrangement, and information technology yield the proper taxis in honoring of the spirit of those police and regulation .

2.Tax compliance

The group dress not hold improper manipulation of tax haven operating room nation with low tax charge oregon improperly use tax structure for the purpose of tax avoidance and put up to the economic development of all nation and region where information technology behave business aside carry through information technology duty vitamin a vitamin a responsible tax payer. With gaze to minutes inside the group, information technology follow through management of transfer price indium accord with OECD transfer price road map and the transfer pricing tax organization inch the country oregon region where the company equal locate.

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3.Relations with tax authorities

The Hitachi high-tech group endeavor to physique, wield, and develop honest and convinced relation with the tax authority in wholly the country and region where information technology impart business. The group far observe healthy and sound relation with tax government and make not hire in the planning of improper benefit .

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