Page 1 of 5

Hitachi Group
Whistleblowing Policy
Owner: Compliance Department, Compliance Division
Publication Date:
Effective Date:
Applicability: Global
Introduction
Hitachi, Ltd., together with its group companies, subsidiaries, and affiliates (collectively, Hitachi),maintains a culture of openness and is committed to the highest standards of sincerity, accountability,and ethical conduct.
An essential characteristic of our open culture is the availability of appropriate channels for Hitachi
employees and other stakeholders to report concerns in good faith and the ability to do so without fearof reprisal.
Hitachi Group Code of Ethics and Business Conduct identifies various channels to report a concern.
These channels include managers, Human Resources, Legal, Ethics & Compliance departments, andthe Hitachi Global Compliance Hotline (thereafter referred to as hotline). Hitachi employees and otherstakeholders can report a concern anonymously, where permitted by law, through the hotline if theywish to do so.
It is the responsibility of every Hitachi employee to speak up and report misconduct when they see it.
Managers have a responsibility to listen to concerns and respond appropriately.
The Global Compliance Office is accountable for the oversight and management of the hotline andconcerns management process.
1. Scope and exclusion
This policy applies to: all current and former Hitachi employees (whether full-time or part-time);
 those belonging or once belonged to administrative, management or supervisory boards ofHitachi;
 those who supply/supplied goods or services to Hitachi, including secondees, externalconsultants, contractors (extended workforce) or to those working under the supervision of suchpersons; agency personnel;
 customer executing sales contract with Hitachi;
 those who acquire information during a recruitment process or pre-contractual discussions withHitachi; shareholders of Hitachi; and civil servants;
who are seeking to report a concern about actual or suspected misconduct (in the European Union(EU), such concerns will include the Relevant Concerns listed in Annex 1, and all such individuals arereferred to collectively as Relevant Individuals).
This policy also applies to third persons with a connection to the persons mentioned above (such as
their colleagues or relatives, persons providing them with assistance, or legal entities connected tothem).

Page 2 of 5This policy does not govern employee grievances, complaints relating to job performance, or the terms
and conditions of employment, which are not by their nature complaints which relate to a potential
malpractice / material misconduct.
If this policy indicates a requirement that is less restrictive than the local regulatory requirements or inconflict with the local law, the applicable regulatory requirement must be followed, and Hitachi, Ltd.’s
Chief Compliance Officer shall be notified. Any deviation from this policy shall be requested in writingfrom Hitachi, Ltd.’s Chief Compliance Officer.
This policy may be amended from time to time and may be supplemented with additional local measuresto account for local law or local regulatory requirements.
2. Terms and definitions
The following terms and definitions in this policy align with International Organization for Standardization
standards.
 Shall indicates a requirement per Hitachi policies and procedures.
 Should indicates a recommendation.
 May indicates a permissive statement and an option that is neither mandatory nor specificallyrecommended.
3. Policy requirements
3.1. Reporting a concern
3.1.1.The availability of various speak-up channels within Hitachi (managers, HumanResources, Ethics and Compliance and Legal departments, and the hotline) allows
people to choose the channel most suitable to their circumstances. Concerns can bereported in writing or orally, including through face-to-face meetings, upon request by thereporting person, or through the hotline (telephone or online). NAVEX, an independent
third party receives, and processes reports in a secure and confidential manner. Thehotline is available 24/7 and allows a person to remain anonymous, where permitted bylaw. Where a person requests a face-to-face meeting, the meeting shall be arranged totake place as soon as reasonably possible.
3.1.2.While Hitachi would like employees to feel comfortable speaking up internally and allow
the company the chance to deal with the issue, nothing in this policy prohibits employees
from reporting possible violations of laws or regulations including but not limited to any
relevant government agency or entity for the concerned jurisdiction, which may beappropriate in certain circumstances.
3.1.3.Any concern reported by a person shall be taken seriously and addressed appropriately,promptly, and (as far as is possible in the circumstances) confidentially, with appropriate
feedback provided to the person.
3.2. Evaluation of concerns
3.2.1.Concerns shall be evaluated promptly and effectively to determine the appropriate courseof action. Such evaluation should be completed within three business days of receiving
the concern, but no later than seven calendar days.
3.2.2.Evaluation of material misconduct shall include consultation with the Hitachi, Ltd.’s ChiefCompliance Officer or their delegate, each business unit’s or group company’s head ofcompliance or their delegate, Human Resources or Legal as appropriate.
3.2.3.Persons designated to receive and/or investigate concerns shall have the competency,
capacity, and appropriate authority to manage and follow up on the reports. Thesepersons shall be independent and abstain from the case if they have any conflicts ofinterest related to the case and report the conflict of interest according to the Conflicts ofInterest protocols.

Page 3 of 5

3.2.4.Persons shall be notified of the receipt of the concern promptly and in any event withinseven business days of raising it. Appropriate lines of communication shall be maintainedwith the person, and further information may be sought from them as required.
3.2.5.Hitachi, Ltd.’s Chief Compliance Officer or each business unit’s and/or group company’shead of the compliance shall be notified of any material misconduct including where aconcern becomes material misconduct during the investigation.
3.3. Protection
Hitachi has a zero tolerance policy for retaliation of any kind against persons who reportconcerns.
3.3.1.This policy is designed to offer protection to persons who had reasonable grounds tobelieve that a concern had arisen at the time of reporting.
3.3.2.Protection is available to persons reporting a concern anonymously if the conditions of
this policy are met.
3.3.3.Protection shall be provided against all forms of actual, threatened or attempted
retaliatory measures (in the EU, these will include the specific measures listed in Annex
1). Persons can also consult a legal advisor to obtain advice on the procedures andremedies available to them, their protection against retaliation and their rights as awhistleblower.
3.3.4.Protection cannot apply to those who report information already fully available in thepublic domain or unsubstantiated rumors and hearsay where they do not have areasonable belief in a possible concern.
3.3.5.Except for cases where identifying the person who reported the concern is essential toconduct the investigation, Hitachi officers/employees shall not attempt to identify thereporter and those supporting the investigation.
3.3.6.Any act of retaliation shall be treated by Hitachi as a violation of its applicable rules andpolicy and could result in disciplinary action up to and including dismissal.
3.3.7.Disciplinary action may be taken by the company against any employee deliberately
raising false and malicious allegations or otherwise acting in bad faith.
3.4. Confidentiality
3.4.1.Strict confidentiality shall be applied, to the extent possible, to handling concerns,
including investigation details and the identity of the person making the allegation.
3.4.2.Hitachi shall take all reasonable steps to maintain confidentiality as far as possible during
and after the reporting and investigations processes to ensure that the person making thereport, the reported concern, or any other persons or items mentioned in the report are
not improperly disclosed to non-authorized persons.
3.5. Investigation
3.5.1.Hitachi is committed to following up appropriately, promptly, and (as far as is possible inthe circumstances) confidentially, with appropriate feedback provided to the person on
concerns raised.
3.5.2.Hitachi officers/employees are required to cooperate with investigations conducted inaccordance with this policy.

Page 4 of 5

3.5.3.The forms of malpractice/ material misconduct which could warrant an investigation andmight require formal disciplinary action (including termination of contract or dismissal in
the most serious cases) include but are not limited to:a) Breach of Hitachi’s internal policies and Hitachi Group Code of Ethics and BusinessConductb) Fraud or corruption, including briberyc) Irregularities involving accounting or other financial proceduresd) Commission of any criminal offensee) Conduct which is, or may be, in conflict with Hitachi’s interests, for example,
inappropriate contacts with a business competitorf) Dishonesty or other irregularities in dealing with customers and suppliersg) Conduct that endangers the health and safety of the public, employees and other
Hitachi workers and visitorsh) Failure to comply with a legal obligationi) Environmental damage arising from Hitachi’s activities or those of its employees orworkers on Hitachi businessj) Discrimination, bullying and harassmentk) Act or omission resulting in damage or risk of harm to human rights or theenvironmentl) Breach of any other legal or regulatory requirement
3.5.4. Chief Compliance Officer (each group company ’ s) or each company ’ s head ofcompliance shall appoint an investigator who will take responsibility for the investigation,
including notifying the investigator of the confidential obligations they would be bound to.
The criteria for selecting an investigator and the way of appointment (by email or inwriting) are outlined in the Concerns Management policy.
3.6. Response and timescale
3.6.1.it is imperative that the person making the report is informed of the investigation progressand outcome within a reasonable timeframe -- not exceeding three months -- and as muchas legally possible without breaching confidentiality to build and maintain trust in theeffectiveness of the concerns management process, including whistleblower protection.
In complex cases where this timeframe could be longer, the person should be informed
within a reasonable timeframe and given an expected completion date for theinvestigation. Even where Hitachi might be constrained by confidentiality, it shall still try
to provide the reporter with as much information as possible about the steps that havebeen taken in response to their concerns.
3.6.2.When reporting a concern via the hotline (telephone or internet), persons must selectoptions that correctly correspond to their disclosure. Accordingly, the report is received
and processed by NAVEX in a secure and confidential manner in compliance with
European data protection legislation. NAVEX forwards the report to the designatedperson in the relevant business to process.
3.6.3.After the report is submitted via the hotline, the person making the report is given a PIN(Personal Identification Number) to use online to follow the progress of their report andrespond to any questions from the investigator. Adequate information on the case isnecessary to launch and complete the investigation. Hence, it is imperative for the person
to periodically check and respond any outstanding questions from the investigator.

Page 5 of 5

Annex 1 - EU Annexure
Definitions: A relevant concern refers to possible breaches of EU law in the areas listed in Article 2(1) ofDirective (EU) 2019/1937, including: (a) public procurement; (b) financial services, products andmarkets, and prevention of money laundering and terrorist financing; (c) product safety andcompliance; (d) transport safety; (e) protection of the environment; (f) radiation protection andnuclear safety; (g) food and feed safety, animal health and welfare; (h) public health; (i) consumer
protection; (j) protection of privacy and personal data, and security of network and informationsystems; (k) breaches affecting the financial interests of the European Union as referred to inArticle 325 Treaty on the Functioning of the European Union (TFEU) and as further specified inrelevant European Union measures; and (l) breaches relating to the internal market, as referred
to in Article 26(2) TFEU, including breaches of European Union competition and State aid rules,
as well as breaches relating to the internal market in relation to acts which breach the rules ofcorporate tax or to arrangements the purpose of which is to obtain a tax advantage that defeats
the object or purpose of the applicable corporate tax law.
 For the purposes of Section 3.3.3, such retaliatory measures shall include, but not be limited to,the following: (a) suspension, lay-off, dismissal or equivalent measures; (b) demotion orwithholding of promotion; (c) transfer of duties, change of location of place of work, reduction inwages, change in working hours; (d) withholding of training; (e) a negative performanceassessment or employment reference; (f) imposition or administering of any disciplinary measure,
reprimand or other penalty, including a financial penalty; (g) coercion, intimidation, harassment orostracism; (h) discrimination, disadvantageous or unfair treatment; (i) failure to convert atemporary employment contract into a permanent one, where the Relevant Individual had
legitimate expectations that they would be offered permanent employment; (j) failure to renew, orearly termination of, a temporary employment contract; (k) harm, including to the person’s
reputation, particularly in social media, or financial loss, including loss of business and loss ofincome; (l) blacklisting on the basis of a sector or industry-wide informal or formal agreement,
which may entail that the Relevant Individual will not, in the future, find employment in the sector
or industry; (m) early termination or cancellation of a contract for goods or services; (n)cancellation of a license or permit; (o) psychiatric or medical referrals.