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Hitachi Kokusai Electric Inc.

Preface

Our Mission is to “contribute to the realization of a society of security, safety and happiness through the development of superior technology, products, and solutions.” In striving to accomplish this, we embrace the following values: Harmony, Sincerity and Pioneering Spirit. Our Vision was created based on our Mission and Values to express what the Hitachi Kokusai Electric Group aims to become in the future.
The Hitachi Kokusai Electric Group Identity is a simple concept designed to share our Mission, Values, and Vision.
The Codes of Conduct consist of rules and principles intended to assist officers and employees of Hitachi Kokusai Electric Group in making decisions and taking actions in accord with the Hitachi Kokusai Electric Group Identity. All officers and employees in the Hitachi Kokusai Electric Group must understand and follow the Codes of Conduct, and must pledge to act with sincerity and fairness in a highly ethical manner.

1. Toward a Sustainable Society

(1)
We will contribute to resolving social issues by promoting innovative solutions, accelerating collaborative creation with partners and stakeholders, and further integrating social and environmental responsibility into our business activities.
(2)
We will strive to develop technologies that contribute to social development and use them with due consideration of their impact on society.
(3)
We envision a low-carbon society, a resource efficient society, and a harmonized society with nature. To this end, we will endeavor to reduce CO2 emissions, use water and other resources efficiently, and minimize impacts on natural capital throughout our value chain.
(4)
As a corporate citizen, we will make efforts to build rapport with communities and contribute to their development by working together to resolve social issues.

2. Sincere and Fair Business Activities

2.1 Fair Trading

To ensure fair and open competition, we will observe the fundamental rules of trade, including domestic and overseas competition laws and regulations, and act in compliance with legislation and sound corporate ethics.

2.2 Anti-Social Forces

We will have no relationship whatsoever with antisocial forces anywhere in the world, and resolutely reject involvement in improper or antisocial transactions.

2.3 Insider Information and Insider Trading

All officers and employees will not trade shares using undisclosed information regarding the group, affiliated companies, business partners, or customers that could affect the judgment of investors (insider information).

2.4 Compliance with Anti-Bribery and Anti-Corruption Lows

We strictly prohibit and will have no involvement in bribery and other corrupt business practices. We will neither give or receive gifts nor extend or accept invitations to business entertainment beyond socially accepted limits, as we recognize that such practices can foster corruption. When working with political entities, we will build and maintain sound and transparent relationships.

2.5 Export Control

We will help maintain international peace and security through compliance with all applicable laws and regulations concerning import and export, and will operate appropriately according to our internal rules and policies.

2.6 The respect of international norms and standards

We will comply with applicable laws, respect social cultures and practices, and act sincerely and fairly in countries and regions where we have operations. Furthermore, we will do so guided by international norms and standards even in areas where legislation is not adequately enforced.

2.7 Anti-Money Laundering (“AML”) Laws

We takes great care to guard against use by criminals of our products or services, or transactions with us, to “launder” the proceeds of crime. In no circumstances should you assist any person in any conduct involving Our products or services that violates fiscal, trade or anti-money laundering laws, including evasion of applicable taxes or import duties. Nor should you facilitate or participate in any activity that subverts this obligation. Under the laws of some countries, dealing in criminal proceeds may itself be considered criminal conduct.

2.8 Accounting and Financial Reporting

We follows strict accounting principles and places a high value on the integrity and accuracy of our record-keeping. As a result, you must report financial information, including expense reports, accurately and completely and use appropriate internal controls and processes to ensure that accounting and financial reporting comply with the laws and standards in every country in which we do business.

2.9 Relationships with Suppliers

(1)
With a global vision, and mindful of the long-term perspective, we will find qualified suppliers and build fair and equal partnerships with them, working together to build mutual understanding and trust.
(2)
In selecting suppliers, we will thoroughly review the quality, reliability, delivery time, and price of the materials they provide as well as their business stability and technological capability. We will give due consideration to their adoption of social responsibility practices, including areas such as the abolition of unfair discrimination, the elimination of child labor and forced labor, and environmental conservation.
(3)
We will not accept any personal benefits from suppliers in procurement transactions.

2.10 Relationships with Customers

(1)
We will provide products and services that meet the needs and requirements of our customers, complying with relevant laws and standards and ensuring quality and safety by setting additional standards of our own where necessary.
(2)
We will communicate with customers sincerely, address defects and customer complaints quickly and in good faith, and strive to determine causes in order to eliminate them and prevent recurrence.

3. Respect for Human Rights

(1)
We will promote our understanding of internationally recognized human rights, and will respect and not infringe on the human rights of all those involved in our business activities.
(2)
We will implement human rights due diligence appropriate to the social circumstances of the countries and regions where we have operations and the nature of our businesses, products, and services there.
(3)
We will assess and prevent potential violations of human rights. In the event of such a violation, we will promptly take internal and external actions to correct and remedy the situation.
(4)
We will respect individual human rights in the recruitment and treatment of employees and during all other company activities. We will not engage in any acts that may impair individual dignity or discriminate on bases such as sex, sexual orientation, age, nationality, race, ethnicity, ideology, belief, religion, social status, family origin, disease, disability.
(5)
We will hire employees in compliance with the relevant laws and regulations in each country and region, and in accordance with international norms and standards. We will not use child labor that employs children below the minimum working age or forced labor that is against the will of employees.
(6)
We will strive to resolve issues through sincere and constructive discussion between management and employees, in compliance with the laws, regulations, and labor practices of each country and region, and in accordance with international norms and standards.

4. Building a Work Environment That Brings Out Employee Strengths

(1)
Prioritizing health and safety above all else, we will strive to ensure the safety of employees and the workplace. In addition, we will promote the physical and mental health of employees and their families.
(2)
We will support flexible work styles and respect diverse values, creating workplaces that provide employees with a sense of accomplishment and personal growth, and we will promote the sustainable growth of the organization and individuals.
(3)
We will invest in educational programs to help employees expand their capabilities and exercise their strengths. Supervisors will fairly and appropriately support, guide, and educate their employees to develop their abilities.

5. Information Management and Communication

(1)
We will promote the ethical handling of information, so as to ensure respect for human rights and security, through the proper management of personal information based on our Personal Information Protection Policy.
(2)
We will properly manage and protect confidential information related to our business activities in compliance with domestic and international laws and regulations as well as our internal rules and policies.
(3)
In order to maintain and expand our trusting relationship with the Hitachi Kokusai Electric Group’s diverse stakeholders, we will disclose information openly and transparently, and respond to stakeholders responsibly through dialogue and other means of communication.

6. Protection of Intellectual Property and Brand

(1)
We will protect our own intellectual property, respect third-party intellectual property, and use both effectively for smooth business operations.
(2)
We will manage our own and third-party confidential information by importance and manage and handle it appropriately based on this ranking.
(3)
We will protect and enhance the value of the Hitachi and Hitachi Kokusai Electric Brand, recognizing it as an important management asset.

7. Securing Corporate Assets

We will use all our corporate assets only for business activities and other appropriate purposes, and manage them properly to protect their value.

8. Crisis Management

We will make concerted efforts throughout the Hitachi Kokusai Electric Group to secure employee safety and business continuity in case of disasters and threats such as earthquakes, tsunamis and floods, cyberattacks, and terrorism.

9. Reporting illicit behavior, ethics violations, and compliance violations

We do not tolerate any illicit behavior. Even in everyday tasks, officers and employees must take care not to overlook such behavior. If any officer or employee discovers any act that deviates from these Codes of Conduct, they must quickly report it to their supervisor or report it via the internal report system. Note that we prohibit all harassment, discrimination, and retaliation against any current or former officer or employee who perform the following actions:
(1) Asks questions or has consultations regarding the Codes of Conduct.
(2) Sincerely reports actual violations or suspected violations to our company, government agency, or law enforcement agency.
(3) Refuses to be involved in violations of the Codes of Conduct.
(4) Cooperates with investigations into violations of the Codes of Conduct.

10. Social media

Once you communicate something on a social network, it spreads immediately and can continue to spread. Therefore, you must be extremely careful regarding anything you write (including the phrasing, content, etc.) on a social network. In particular, it is easy to mix up private and work-related matters while online.
For these reasons, all officers and employees must carefully follow the instructions of the relevant department regarding social media, even when using social media in a private capacity. All officers and employees must avoid giving the impression that they are expressing their opinion as a representative of Hitachi Kokusai Electric Group.

11. Divided Loyalties

You must avoid situations in which there is a potential for conflict between your personal interests and your obligations to Hitachi. You may not evade these requirements by acting indirectly through anyone else, such as your family, friends or relatives. If in doubt, you should always seek prior guidance and approval from your manager, Human Resources or Legal and Compliance.

Examples include:
(1) Marketing on a Commercial Basis products or services that compete with current or potential offerings from our company.
(2) Representing, working for, or serving on the board of our customer, competitor or supplier while working for the Hitachi Kokusai Electric Group.
(3) Investing in any organization with which our company do business or competes, if that investment would create, or appear to create, a conflict of interest with the Hitachi Kokusai Electric Group.

12. Company Time and Assets

You may not perform non-Hitachi Kokusai Electric Group work or solicit such business on our premises during work hours, or by using Hitachi Kokusai Electric Group’s assets, including email, internet, equipment, materials, resources or confidential information.

13. Public Service

An officer or employee who participates in a committee of an organizational body in a regional community must avoid conflicts of interest between our company and groups outside our company or organizational bodies. To do this, the officer or employee must refrain from being involved in decision making or voting on matters that involve the Company and the organizational body.

14. Political Contributions

You must not, in the name of Hitachi Kokusai Electric Group or on its behalf, make any financial contributions or provide other support to political parties, politicians, or candidates for election to public office, without prior approval from your organization.

15. Responsibilities of Top Management

Top managers shall take the initiative in complying with the Codes of Conduct and make their best efforts to conduct business based on corporate ethics and the law. In the event of violation of the Codes of Conduct, top managers shall swiftly take corrective measures and actions to prevent the recurrence of similar incidents, while at the same time strictly disciplining themselves as well as those involved in the violation.

Supplementary Provisions to the Codes of Conduct

These Codes of Conduct shall apply to all officers and employees of Hitachi Kokusai Electric group. The group companies shall ensure that all their officers and employees fully understand the provisions of the codes.
Each group company shall streamline its organizational structure and systems (e.g. internal reporting system, disciplinary system) to comply with the Codes of Conduct. In the event of violation, disciplinary action shall be taken in accordance with the related rules and internal procedures. These codes of conduct are referred to and are based on the Hitachi Group Codes of Conduct and the Hitachi Group Code of Ethics and Compliance.