Code

of Conduct
© Copyright 2021 Hitachi Energy. All rights reserved. Revision B (August 2021) , Document ID: 8DAA5000441
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CEO message
I am pleased to introduce our updated Code of Conduct that
will continue to set high standards for ethical business conduct
and that provides practical and clear guidance for all of our
employees. It has been updated to become our own Code of
Conduct for Hitachi Energy and it is aligned with the Hitachi
Group Compliance Program (HGCP). It expresses our strong
commitment to Integrity, setting out our high standards for
ethical business conduct while providing practical guidance.

It is vital that we are demonstrating to all our stakeholders To operate successfully we need to deliver continuously on our
through our decisions and actions that our operations, services, purpose: powering good for sustainable energy future, with
and daily business activities are based on principles of integrity. pioneering and digital technologies, as the partner of choice
for enabling a stronger, smarter, and greener grid. Integrity is
In this Code, you will find five personal commitments to integrity
a key contributor to delivering on this. It is essential for all our
that we all make as employees. Always adhere to these personal
everyday business practices and interactions, touching on all
integrity commitments when making decisions and executing
business priorities including our aspirations and goals in diversity
our business strategy.
and inclusion and Sustainability 2030.
I urge you to use the Code of Conduct in conversations with
your team and discuss it with our customers and partners. We
are all responsible for upholding the Code and accountable for Best regards,
our actions. If you have questions, need clarification, or are not Claudio Facchin
sure how our Code applies to your situation, reach out to your CEO Hitachi Energy
manager, your HR manager or your local or regional head of legal
or integrity for answers. If you suspect there has been a violation
of the Code, report it promptly so we have an early opportunity to
address it. Maintaining one’s integrity in a complex, competitive,
and fast-changing world is always challenging – ask questions,
speak up, remember your personal integrity commitments, and
use the resources we have made available for your guidance.
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Introduction
Our purpose is powering good for a sustainable energy future,
with pioneering and digital technologies, as the partner of choice for
enabling a stronger, smarter, and greener energy system.

We aim to accomplish this by embracing and living our values, We aim to accomplish this by embracing and living
and with Safety, Integrity and Quality as part of our DNA. our values, and with Safety, Integrity and Quality

As Hitachi Energy we are a global technology and market leader with a

as part of our DNA.
combined heritage of close to 250 years, employing around 36,000 people
in 90 countries. Headquartered in Switzerland, the business serves utility,
industry and infrastructure customers across the value chain, creating
solutions and innovation in collaboration with our customers.

This Code, supported by our Board of Directors, provides high standards

of business conduct and ethical guidance to everyone in our organization
around the globe. Acting with integrity underpins all the requirements of this
global Code of Conduct and these are our baseline rules for working with
others as we deliver on our purpose.Compliance is mandatory.

The Code contains five personal integrity commitments that apply to all
your business activities. It also introduces policy guidance for specific
compliance and integrity core areas that you might encounter from time to
time in performing your job responsibilities. Finally, to the extent you have
questions, need more information, or wish to report a concern, this Code
provides contacts, web links, and other references where such additional
information can be quickly obtained.
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Applicability
This Code applies globally to:

• Every employee, officer and director of Hitachi Energy,

including those of our wholly owned
affiliates and subsidiaries (the “Company”); and,

• Every employee, officer and director of any other business

or legal entities in which the Company owns a majority of
the shares or exercise effective control of the entity.

• Contractors who work for and conduct business on behalf

of Hitachi Energy
Managers are responsible for providing appropriate support to
enable their teams to understand the requirements of this Code,
the relevant supporting regulations, the international and local
laws of the countries in which they work, and how they should
be applied in practice.

We will make a good faith effort to implement the Code (or seek
adoption of a similar set of policies) in any operating business
or legal entity in which we do not own the majority of shares
or exercise effective control of the entity. We will also make
good faith efforts to have suppliers, representatives and other
contractors commit contractually to this Code or to their own
set of similar policies in connection with activities performed on
behalf of our Company.
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Our Personal
Integrity Commitments
1. We are honest, sincere and accountable to each other
for our actions — we promptly raise any questions or concerns
about potential violations of our Code.

2. We are polite and respectful to each other and our

stakeholders — we are fair, trustworthy and collaborative
in all our business activities.

3. We pioneer creative solutions consistent with our Code —

we follow applicable laws and our principles of ethics and
integrity.

4. We help build a sustainable future — we protect

the environment, exercise sound health and safety practices
and respect human rights.

5. We work with a strong sense of personal ownership

for our Company — we safeguard its reputation,
brand and assets.
Table of contents
CEO message

Introduction

Applicability

Integrity Commitments

1. Determination
How we help our customers to succeed

2. Responsibility
How we safeguard the company’s assets

3. Responsibility
We show responsibility when
we choose business partners with care

4. Responsibility
We show responsibility when we observe the highest
ethical standards in our interaction with government

5. Respect
We show respect for each other when
we help each other to succeed

6. Respect
We show respect when we acknowledge
our wider social responsibilities

7. Reporting concerns

Contact us
Determination
1.1. We show
determination
when we help our
customers to succeed
The success of our customers is key to the
success of Hitachi Energy. Customers look
to Hitachi Energy for innovation, reliability
and integrity. The standards of behavior
required in our client relationships are
designed to ensure that we consistently
deliver those values and avoid mistakes
that will harm our reputation.
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1.2. We focus on quality

We strive to help our customers gain a competitive advantage
by adding value through the delivery of the highest quality of
products and services that comply with applicable specifications,
customer requirements, industry standards and regulations.

1.3. We win trust by being honest

Trust is at the core of our business and it is built and maintained
through transparency and honesty. To be successful on a
sustainable basis, we have to build and maintain trust with each
customer and supplier through the integrity of our words and
actions. We don’t promise what we can’t deliver, and strive to
ensure that customers, suppliers, shareholders and colleagues
trust us to keep our word.
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1.4. We compete openly and fairly

We believe in a competitive, free enterprise system because it
guarantees that our hard work and innovation will be rewarded.
We will lose the trust of our customers if we treat them differently
from one another or conspire with competitors against them.

This system, as the basis of a free market economy, is protected

and promoted by competition law. Consequently, our actions
must always comply with all applicable antitrust and other laws
regulating competition in the countries where we do business.

While these laws vary from country to country, the Hitachi

Energy’s minimum standard can be defined as follows:

• We compete openly and independently in every market.

We do not make any agreements – formal or otherwise –
with competitors to fix or set prices, or allocate products,
markets, territories or customers.

• We do not obtain or share with competitors current or

future information about price, profit margins or costs,
bids, market share, distribution practices, terms of sales,
specific customers or vendors.

• We do not agree with or require a customer to resell our

products at certain prices.

• We do not act in a manner that unfairly favors or benefits

one customer over another competing customer.
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Be mindful of the antitrust risks presented by trade and

professional association meetings. As a Hitachi Energy
employee, you are required to:

• Attend only meetings of legitimate trade and professional

associations held for proper business, scientific, or
professional purposes.

• Before attending such meetings, you must familiarize

yourself with the internal antitrust regulations, including
participation approvals.

• Discuss any questionable agenda items with your

supervisor or with a member of Hitachi Energy’s legal
and integrity function (Global Function – Legal & Integrity)
before you attend the meeting.

• Leave the meeting and promptly advise your supervisor or

1.5. We trade globally
Function – Legal & Integrity, if you observe any activity at an Our commercial success depends on our ability to export
association meeting that appears to be illegal or suspicious. our products, technology and services to customers located
If you have any questions regarding compliance with antitrust around the world and to import, as necessary, the raw materials
laws, contact Global Function – Legal & Integrity immediately and components for those products from our global supply
chain. The import, export and transfer of goods, services and
technology, including technical data or information, is regulated
by national and international laws that affect our operations
in many ways.

The transfer of information and data across borders via email

or internet-based collaboration tools, or even the exchange
of information among citizens of different countries are strictly
regulated by many national laws. We comply with all applicable
trade laws and regulations that affect our operations, including
customs regulations, export control laws, and trade sanctions.
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1.6. We refuse
to make improper payments
Hitachi Energy’s reputation for transparency, honesty and
integrity must not be put at risk by the offer of improper
payments. We are careful in selecting only reputable suppliers,
channel partners and other business partners that share our
commitment to transparent, ethical and honest business
practices.

In dealing with public officials, political parties or their officials

or any private sector worker, Hitachi Energy employees must
neither offer, promise or give any undue financial or other
advantage, whether directly or through intermediaries, to obtain 1.7. We protect our credibility
or retain business or any improper advantage in the conduct
of business. Anti-Bribery and Anti-Corruption laws have severe by shunning gifts and favors
criminal penalties and reputational harm for individuals and
companies that engage in such unlawful practices. Accepting gifts and entertainment from business partners or
offering such favors undermines our credibility. It makes Hitachi
Energy vulnerable to accusations that business decisions are
influenced by factors other than merit.

Employees must therefore not offer, make, seek or accept gifts,

payment, customers travels, entertainment or services to or from
actual or potential business partners which might reasonably
be believed to influence business transactions, which are not
within the bounds of customary business hospitality or which are
prohibited by applicable law.
Responsibility
2.1. We show responsibility
when we safeguard
the company’s assets
We are all part of one Hitachi Energy team. We
show respect and support for colleagues and their
aspirations by caring for the environment we work
in, and the information systems, equipment and
other facilities needed for each of us to do the best
possible job. Helping each other to succeed also
depends on how we handle positions of authority,
access to privileged information and potential
conflicts of interest.
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2.3. We use information

systems professionally
Hitachi Energy’s information systems are there to help us work
efficiently and professionally. Generally, such systems should
be used only for business purposes, in a manner that does not
violate the rights or interests of Hitachi Energy, and in line with
rules issued by Hitachi Energy.

Remember that any communication via e-mail could be regarded

as a statement of Hitachi Energy. Therefore, employees must be
2.2. We are respectful careful not to release information that is commercially sensitive
or contentious or may have undesired contractual or other legal
of the company’s assets implications for Hitachi Energy.

Hitachi Energy strives to give employees the tools they need All laws governing copyright, defamation, discrimination and
– equipment and information – to be effective. Hitachi Energy’ other forms of written communication also apply to online and
physical assets, intellectual property rights and information e-mail communication. Unauthorized or unlicensed software
must be use and handled with care to safeguard property, must not be placed onto Hitachi Energy’s information systems
resources and assets and to avoid loss, theft or damage. facilities.
Information assets include organizational charts, technologies
Hitachi Energy’s information systems facilities must not be
and processes, manufacturing methods, as well as marketing,
used to attack the integrity of Hitachi Energy’s or third parties’
advertising, and business development studies and plans.
networks or data. This includes originating or forwarding chain
letters or unsolicited commercial e-mail (spam).

Information produced and stored on Hitachi Energy’s information

systems facilities is regarded as Hitachi Energy’s property, and
Hitachi Energy reserves the right to access all such information
except where limited by law or agreement. Employees are
responsible for keeping their electronic files and archives in an
orderly manner.
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2.4. We safeguard
confidential information
Information is an asset. We share some of it in press releases,
product information, the annual report and other public
documents. We provide timely, and accurate information to
others, ensure that our communications are professionally done,
and encourage open and respectful dialog with others. Any
other information that comes to employees in connection with
their work, whatever the source, must be kept confidential to
prevent others copying our work or poaching customers. It may
also include information that suppliers, customers or partners
may have entrusted to Hitachi Energy. Disclosing confidential
information (including that of third parties) in our company’s
possession could result in civil or criminal liability for the
2.5. We respect our intellectual
individual and the company.
property rights and of others
Mark information appropriately, keep it secure, and limit access
to those who need to know in order to do their jobs. Avoid We actively protect and defend our valuable technology and
discussing information in areas where you may be overheard, intellectual property portfolio resulting from our innovation and
such as airports, public transport, restaurants and bars, creations in the form of patents, copyrights, service marks
elevators, restrooms and cafeterias. Information is so valuable trademarks and domain names and safeguard the confidentiality
that it may be appropriate to ask any outside party given access of our trade secrets and know-how.
to confidential information to sign a confidentiality statement
Hitachi Energy protects its own secrets and respects the
approved by Global Function – Legal & Integrity.
intellectual property rights of others. Employees must not obtain
confidential information of other parties by improper means
or disclose it without authorization. Infringement of another’s
intellectual property is a serious matter and may constitute a
criminal offense.
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2.6. We avoid and manage

conflicts of interest
We act in the best interests of the company and all employees • Outside employment: participating in a position similar
owe a duty of loyalty to the company. Conflicts of interest can to the job at Hitachi Energy that may conflict with the
arise where personal interests or family and other allegiances performance of the job at Hitachi Energy, or working with
are at odds with the interests of the company. We can avoid an actual or potential competitor, supplier or customer of
conflicts of interest if we are aware of the challenge and take Hitachi Energy.
the necessary action. In general, we should avoid situations in
which personal interests, outside activities, financial interests • Family members and close personal relationships:
or relationships conflict or appear to conflict with the interests contracting with a business managed or owned by a family
of Hitachi Energy, and not allow business dealings on behalf of member or unmarried partner.
the company to be influenced by personal considerations or
• Investments: acquiring an interest in property or companies
relationships.
which Hitachi Energy may have an interest
The most frequent conflicts of interest arise where an employee in purchasing.
is in a position to award business contracts, hire staff, has
• Board memberships: acting as or accepting a position
access to information that may be of interest to the financial
as an officer, consultant or director of any business
markets, or is offered employment by a competitor. Here are
or organization involved in the power and automation
some examples of potential conflicts of interest.
technologies industry or involved with Hitachi Energy (such
as a partner, supplier, or customer).

• Significant ownership interests: owning certain amounts

of other companies that do or seek to do business with
Hitachi Energy, or which are competitors.

Employees who think they may be in a “conflict” must promptly

and fully inform their line manager or human resources
representative so that the company can determine whether a
conflict exists. They will be advised of the proper actions to take,
in line with the rules issued by Hitachi Energy.
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2.7. We protect
privileged information
Inside information is information not readily available to the Hitachi Energy has strict guidelines for the dissemination of such
public that an investor would consider important in deciding information, which includes financial data, plans for the future of
whether to buy or sell a company’s securities. the business. The laws prohibit anyone with inside knowledge
from trading the securities or disclosing the information. If
Because inside information may have considerable value to
employees are unsure whether they have “inside” information,
investors, it is governed by legislation designed to preserve
they should contact their line manager or a representative of
public confidence in and the integrity of the securities markets
Group Function – Legal & Integrity to discuss the situation.
in many countries.
Trading securities such as shares or bonds while in the
possession of inside information is both unethical and illegal
and will be dealt with decisively. It is not permitted to share
inside information with Hitachi Energy employees unless they
need to know and are aware of their obligations in handling the
information. It is against the law to “tip” or share information
with others, including a co-worker, family member or friend who
might make an investment decision based on inside information.
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2.8. We comply with

anti-money laundering rules
Hitachi Energy’s commitment to fairness, honesty and
openness extends to complying fully with all money-laundering
laws throughout the world. We do business with reputable
customers involved in legitimate business activities, conducting
2.9. We keep accurate
due diligence to ensure we know our customers, avoiding and complete financial records
unacceptable means of payment and being alert to any red
flags or other suspicious forms or methods of payment. Money Investors, creditors and others have a legitimate interest in
laundering generally occurs when funds from illegitimate sources Hitachi Energy’s accounts. The integrity of the accounts depends
are brought into legitimate financial channels to hide them or on the accuracy, completeness and timeliness of the entries.
make them appear legitimate. All Hitachi Energy business transactions must therefore be
timely, fully and fairly reported and recorded in accordance with
Employees must protect the integrity and reputation of Hitachi
Hitachi Energy’s accounting principles, procedures and other
Energy by helping to detect possible money laundering activities.
appropriate requirements. We adhere to international financial
They should learn to watch for warning signs, which may include
reporting standards (IFRS) and comply with the applicable laws
customers who are reluctant to provide complete information or
and internal accounting and reporting guidelines and regulations
wish to make payments in cash.
that govern our financial and tax accounting and reporting.
Improper or fraudulent documentation or reporting is illegal.

We act with integrity

2.10.
in handling corporate
opportunities
We respect the company’s assets and don’t seek to take
personal opportunities or personal gain discovered through the
use of Hitachi Energy property, information or position.
Responsibility
3.1. We show responsibility
when we choose business
partners with care
How Hitachi Energy does business is crucial to
its reputation and success, and business partners
should be seen as allies. In this section there are
guidelines on appropriate conduct towards suppliers,
agents and consultants, among others.

The standards in place in a joint venture should also

be compatible with those of Hitachi Energy.
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3.3. We collaborate
with agents and consultants
Commissions or fees paid to agents and consultants must be
reasonable in relation to the services provided. Employees must
not agree or pay commissions or fees that could be considered
to be improper payments.

Agreements with consultants, brokers, sponsors, agents or

other intermediaries shall not be used to channel payments to
any person or persons, including public officials or customers’
employees.
3.2. We are fair We rely on subcontractors to help us execute some projects and
in our relations with suppliers value the contribution they make to Hitachi Energy’s customer
relationships and to the company’s reputation. To protect and
We contract with reputable suppliers that share our commitment enhance Hitachi Energy’s reputation, we choose subcontractors
to ethical business conduct as expressed in our Supplier Code who will act in a manner consistent with this Code of Conduct.
of Conduct and the rule of law.

Hitachi Energy expects fair competition in its markets and

applies the same standard in dealing with suppliers. We set high
standards of quality, reliability, performance and productivity
for our suppliers and we select and/or deal with suppliers on
merit without favoritism or bias, strictly in accordance to our
internal procurement regulations. You must not let your business
dealings on behalf of the company be influenced by personal or
family interests. We will not accept any personal benefits from
suppliers in procurement transactions.
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3.4. We team up
with like-minded partners
for joint ventures and alliances
Hitachi Energy’s strength and success also depend on building
long-lasting relationships with partners that share our commitment
to ethical business principles. The standards of any joint ventures
should be compatible with Hitachi Energy’s.

3.5. We extend standards

of openness to lenders
and export credit agencies
Hitachi Energy will disclose all relevant material facts for
obtaining financing from an export credit agency or other
governmental lenders. It is also company policy to disclose
all material facts that would be responsive to any prospective
lender’s analysis. Certificates issued by Hitachi Energy as an
export credit agency supplier or exporter must be signed in
accordance with Hitachi Energy’s integrity regulations and
standards.
Responsibility
4.1. We show responsibility
when we observe the highest
ethical standards in our
interaction with government
Hitachi Energy interacts with different groups of
stakeholders, including customers, suppliers,
shareholders, the media, non-governmental
organizations and local officials. The interaction of
employees with governments around the world is of
particular importance. In this section guidelines are
set out on working with officials, and when, if at all,
political contributions are allowed.
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4.2. We cooperate fully with officials

Hitachi Energy does business in about 100 countries and values
good relations with governments and their agencies, regulators,
business and social institutions, public bodies, and state-
owned enterprises. National and local governments around the
world have specific and varied procurement laws to protect
the public interest. They generally prohibit offering benefits to
individual officials, and often include limitations on hiring current
or recently retired officials. Any conduct that may be viewed as
improperly influencing objective decision making is forbidden.

Hitachi Energy employees must be truthful and accurate in

interactions with government officials and observe the highest
ethical and integrity standards when conducting business with In dealing with a government, employees must know in advance
government representatives. and comply with applicable laws and regulations, and must not
contact government officials on behalf of the company unless it
is their job.

We let employees contribute to public affairs in their own time.

Employees must abstain from voting on or participating in any
decision that involves a relationship between that entity and the
company, in order to avoid any actual or apparent conflict of
interest.

Hitachi Energy funds, property or services must not be used to

support any candidate for political office, political party, official
or committee anywhere in the world. Any exceptions to this rule
must be cleared and approved in advance with Global Function –
Legal & Integrity.
Respect
5.1. We show respect
for each other when we
help each other to succeed
The people who work at Hitachi Energy come
from many different countries, backgrounds and
cultures. We can only appreciate the contribution
of each individual if we observe normal standards
of courtesy and respect when interacting with
one another. Hitachi Energy will also be judged by
outsiders according to the way they are treated in
their business dealings with the company. Clear
and regular communications, diversity, equality of
opportunity and upholding health and safety are
essential to fostering a working environment in which
everyone will feel welcome and comfortable.
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5.2. We foster regular

and open communication
Regular and open communication between managers and their
teams is key to business success. This communication, which
usually takes the form of meetings and briefings, should cover
business strategy, long-term objectives and short-term priorities.
Complemented by support from Hitachi Energy Group in the 5.3. We value mutual respect
form of newsletters, websites, training, presentations, etc.,
communication between employees and their superiors should and privacy and personal data
include making clear how employees are contributing to Hitachi
The privacy of personal information – whether from employees,
Energy’s business goals.
customers, contractors or vendors – is to be respected at all
Employees have a right to receive their superior’s times and protected. Protecting personal data is not simply
assessment of their performance, which is expected to about being compliant with laws, it is a fundamental value of
ascertain progress and, where appropriate, to include trustworthiness and ethics for Hitachi Energy. We collect, use,
proposed plans for further development. store, handle, and disclose individual personal information fairly,
transparently, and securely for legitimate business purposes
and in accordance with the Hitachi Energy privacy policies and
applicable laws. Employees may, however, not claim any privacy
privileges for communications transacted through Hitachi Energy
facilities, beyond those provided by local legislation. We build
data protection into the design of our products and services
and implement appropriate safeguards to protect personal data
against unauthorized or excessive use or disclosure.
25 | H I TA C H I E NERG Y | CODE OF CONDUCT

5.4. We celebrate diversity

We come from many different countries and cultures and are committed to
building a globally diverse and inclusive workplace culture on a foundation
of mutual respect and tolerance. Dozens of different businesses in countries
around the world have come together over the years under the Hitachi
Energy umbrella, and Hitachi Energy’s culture welcomes them all, regardless
of gender, nationality, age or physical ability, or any other aspect of diversity.
Employees must conduct their business activities with co-workers,
customers, stakeholders and business partners with respect for all people
without regard to differences or similarities.
5.5. We respect human rights
We provide goods and services that improve the quality of life
Hitachi Energy hires and promotes people based on their abilities following
of people around the world by expanding access to affordable
the employment and labor laws, regulations and collective bargaining
and sustainable energy through pioneering technologies. We
agreements in the countries in which we do business, including those
support the principles contained within the Universal Declaration
relating to anti-discrimination, bullying and harassment, working time
of Human Rights, the UN Guiding Principles on Business
hours, child, parental leave and similar regulations. Employees will not
and Human Rights, the OECD Guidelines for Multinational
engage in or support discrimination in hiring, compensation, access to
Enterprises and the ILO Core Conventions on Labour Standards.
training, promotion, termination or retirement based on gender, age, ethnic
We promote and respect internationally recognized human
and national origin, caste, religion, disability, sexual orientation, union
rights in our business activities, and we expect our suppliers
membership or political affiliation.
and business partners to share this commitment, including
prohibitions on child, forced labor and modern slavery. We
ensure that materials in our products originate from socially
responsible and sustainable sources, and do not participate in,
contribute to, or facilitate business activities that cause conflict
or violate human rights.
26 | H I TA C H I E NERG Y | CODE OF CONDUCT

5.6. We work to create

an environment free of harassment
Employees won’t feel welcome and comfortable at Hitachi
Energy if they, their co-workers or anyone who has business
5.7. We set the highest health
dealings with Hitachi Energy faces harassment. Harassment – be and safety standards
it face-to-face, written, electronic, or verbal – won’t be tolerated.

Harassment can take many forms. People may feel harassed by It is our duty to our colleagues, their families and their
slurs, intimidating or aggressive acts or words, by derogatory communities to safeguard the health and safety of every
jokes or inappropriate gestures, or by unwelcome physical or employee at work. Hitachi Energy’s stringent health and safety
verbal conduct. Harassment can also be the communication policies and reporting requirements are in place to protect the
or display of offensive material linked to any of the aspects lives and good health of employees.
of diversity mentioned above, such as gender, religion, race,
Hitachi Energy’s ground rules for employees are: work safely
nationality, sexual orientation or physical ability. Violations of
and protect yourself, your co-workers, the community and the
our employment regulations will result in disciplinary actions,
environment. The policies, procedures and programs apply
up to and including termination of employment or immediate
worldwide to promote safe and healthy working conditions,
dismissal.
protect the environment, and support Hitachi Energy’s
commitment to compliance with applicable laws and regulations.

You should know and comply with the law and related company
policies if you have responsibilities in areas that are subject to
safety and/or environmental regulations.

5.8. We manage potential threats, It is also imperative to report dangerous conditions and other
unacceptable health, safety or environmental conditions
crises or security incidents immediately so that workplace accidents are minimized, and
corrective actions can be taken.
We adhere to international standards and sound principles of
security and crisis management that are flowed down to our
regional and local operations with the goal of ensuring safety and
business continuity.
Respect
6.1. We show respect when
we acknowledge our wider
social responsibilities
We at Hitachi Energy pride ourselves in being “at
home” in the communities in which we operate.
Observance of the rule of law is a basic underpinning
of our licence to operate.

In this section we look at what Hitachi Energy

can expect from employees in areas ranging
from compliance with the law to protection of the
environment. Promoting a sustainable approach to
business, both in the way in which we operate and the
technologies we provide, are key elements of good
corporate citizenship, of being “at home” globally.
28 | H I TA C H I E NERG Y | CODE OF CONDUCT

6.2. We respect the law

Upholding Hitachi Energy’s reputation for integrity requires
absolute compliance with the law for Hitachi Energy and all
employees. Employees are expected to be familiar with the law
as it applies to their job, and management is expected to provide
necessary instruction and advice.

For example, Hitachi Energy is strongly committed to non-

6.3. We promote
discriminatory and fair standards, to the protection of the sustainable development
environment, and to the health and safety of employees.
Every Hitachi Energy employee contributes to achieving
Hitachi Energy expects employees to comply with all laws the company’s sustainability goals by supporting economic
designed to protect health, safety and the environment, to obtain progress, environmental stewardship and social development.
all required permits, and to operate facilities in strict accordance One aspect involves taking appropriate initiatives that improve
with the relevant laws. the quality of life in the communities and countries where Hitachi
Due to the complex regulatory framework within which Hitachi Energy operates.
Energy conducts business, issues of legal compliance may arise. On Sustainability means that Hitachi Energy treats all stakeholders
occasion, there may be disagreement on whether Hitachi Energy is in a socially responsible manner. Employees can contribute
in full compliance with the law and litigation may occur. At all times, by promoting open dialog with stakeholders on Hitachi
Hitachi Energy will act responsibly and abide by the final decisions Energy’s economic, social and environmental contributions and
rendered by the courts. performance. To do so, employees should familiarize themselves
Issues of compliance with the requirements of governmental with Hitachi Energy’s policy on sustainability, and its economic,
agencies may also arise. It is important for Hitachi Energy environmental and social requirements.
management to be informed of any such issues at an early date.

Employees have a responsibility to inform management

immediately if there is any indication that such an issue may exist.
29 | H I TA C H I E NERG Y | CODE OF CONDUCT

6.5. We are active members

of our communities
Just as Hitachi Energy, on a corporate level, strives to exercise
citizenship by reaching out to the wider community – through
specific projects, charitable donations and practical support
6.4. We support for worthy initiatives – the company also encourages individual

environmental responsibility employees to make an active civic contribution.

All Hitachi Energy employees have the responsibility to

comply with the letter and the spirit of environmental laws and
regulations and respect the environment wherever they work.

We are aiming for a low-carbon, resource efficient and a

harmonized society, working on reducing our CO2 emission
while using other resources efficiently to minimize the impact on
our planet through our value chain.
Reporting
concerns
7.1. Employees’
Responsibilities
under the Code
This Code of Conduct imposes on Company
employees important responsibilities and high
standards for integrity and compliance — we
want everyone to feel a strong sense of personal
ownership and to make a commitment to ethical
business conduct and adherence to our Code.
31 | H I TA C H I E NERG Y | CODE OF CONDUCT

These responsibilities include the following: Our leaders have special responsibilities to set the right tone for
integrity by serving as role models for ethical conduct, ensuring
• Reading and acknowledging this Code carefully so that that their employees are trained on the relevant compliance risks,
you understand it and can incorporate your Integrity knowing the integrity and compliance risks in their organizations
Commitments into your daily work routines; and taking active steps to mitigate them, and creating
a culture of compliance and integrity in their organizations where
• Being aware of and alert to the integrity and compliance
employees feel comfortable raising concerns.
risks that you and your organization face on a daily basis
and report it when needed; Our leaders serve as role models for ethical business conduct
by setting the right tone from the top guaranteeing that all our
• Knowing where and how to raise an integrity concern, and
employees are fully trained and aware of the relevant integrity
where to get integrity help if you need it;
risks and taking remedial steps to address them. They are
• Reporting promptly any misconduct that might involve responsible for creating a culture of integrity and an environment
a violation of this Code or a violation of law; where employees feel comfortable raising concerns at any time.

• Cooperating fully, transparently and truthfully with any

integrity investigations;

• Refraining from retaliation against anyone who raises an

integrity concern in good faith or participates truthfully in
an integrity investigation;

• Taking your assigned integrity training in a timely manner; and,

• Maintaining a high standard of ethical conduct in all your

business activities to avoid any reputational and legal risks
that might arise against the Company.
32 | H I TA C H I E NERG Y | CODE OF CONDUCT

7.2. Reporting concerns

One of your most important responsibilities under the Code
is to report promptly any conduct that might be inconsistent
with or in violation of this Code. Prompt reporting of concerns
is important to our business success because it allows the
Company to investigate and take any necessary corrective
actions quickly, before a small issue becomes more complicated,
costly and difficult to manage. By quickly reporting violations,
you are helping the Company maintain our good reputation
7.3. Reporting channels
and participating constructively in its governance model. It is a
In addition to reporting through your manager, human resources
breach of this Code to fail to report promptly conduct of which
manager or to a representative of the Legal and Integrity, here
you are aware that you believe in good faith might be in violation
are alternative ways you may report a compliance concern:
of this Code.

We provide multiple channels through which you can report • To the Company’s Business Ethics Hotline;
a concern, including to your manager, your human resources
• To the Company’s Ethics Web Portal;
manager or your local or regional head of Legal and Integrity. You
may also choose to report a concern anonymously. You are not • By e-mail or telephone through the contact information on
required to provide your name or other identifying information the Legal & Integrity intranet page; or
when you report a concern, but you need to provide sufficient
• By letter addressed to Hitachi Energy, Ltd., Brown Boveri
detail so that the Company can follow up appropriately. If you
Strasse 5, 8050 Zurich, Switzerland, to the attention of
provide contact information, we may follow up with you on an
Hitachi Energy Ethics.
anonymous basis if additional information or detail is needed.
We take your integrity and compliance concerns seriously and
each one is treated confidentially to the maximum extent practical.
33 | H I TA C H I E NERG Y | CODE OF CONDUCT

7.5. Penalties for violation

Each employee is responsible for ensuring that his or her
conduct and the conduct of anyone reporting to the employee
fully comply with the applicable laws, this Code of Conduct, and
the company policies. Compliance and integrity, both personal
and by subordinates, will be a factor in periodic performance
appraisals. Hitachi Energy applies “zero tolerance” and will
take disciplinary action, up to and including termination of

7.4. Our Commitment employment, against employees who violate the law, this Code
of Conduct or company policies.
Against Retaliation
We seek to cultivate a culture where employees and other
stakeholders feel comfortable raising integrity and compliance
concerns without fear of retaliation. The Company will not tolerate
any adverse employment or other retaliatory action taken against
any person or organization that reports a concern in good faith
or against an employee or other individual who cooperates and
provides truthful information in a compliance investigation. Any
employee who retaliates against another employee, person
or organization for raising a compliance concern in good faith
or participating truthfully in a compliance investigation will be
subject to severe discipline up to and including termination of
employment.

In this context, a concern is raised in “good faith” when there is a

reasonable basis to believe that there has been a violation of the
Code of Ethics and the concern is not motivated in whole or in
part for the purpose of seeking retribution, creating ill-will, settling
a personal dispute or causing harm or embarrassment to another.
Contact us
Head of Integrity Senior Investigator
Dominique Abrokwa Dilliraj Paneru
dominique.abrokwa@hitachienergy.com dilliraj.paneru@hitachienergy.com

Region Head of Integrity - Europe Investigator and Process Manager

Winnifred Haas-Konings Fares Ather
winnifred.haas-konings@hitachienergy.com fares.ather@hitachienergy.com

Region Head of Integrity – North Asia Head of Global Trade Compliance

Maggie Zheng Zhang Maxine Kennett
maggie-zheng.zhang@hitachienergy.com maxine.kennett@hitachienergy.com

Region Head of Integrity – Middle East & Africa Head of Integrity Switzerland
Yasmeen Elkenawy Pascale Lutz
yasmeen.elkenawy@hitachienergy.com pascale.lutz@hitachienergy.com

Region Head of Integrity – NAM Global Integrity Junior Specialist

Richard Breunig Lili Minasyan
richard.breunig@hitachienergy.com lili.minasyan@hitachienergy.com

Region Head of Integrity – SAM

Legal & Integrity Intranet Page
Rodrigo Merg
Legal & Integrity Web Page
rodrigo.merg@hitachienergy.com
Hitachi Energy Ltd
Region Head of Integrity – South Asia
Mukesh Kumar Brown Boveri Strasse 5, 8050 Zurich, Switzerland
mukesh.kumar1@hitachienergy.com Phone: +41 58 588 60 06

Head of Office of Special Investigations

Sanne Warmerdam
sanne.warmerdam@hitachienergy.com