DocuSign Envelope ID: D0270359-9123-402C-A158-8291800F0C3F

HITACHI RAIL AUSTRALIA

Modern Slavery Statement 2023

H I TAC H I R A I L . C O MDocuSign Envelope ID: D0270359-9123-402C-A158-8291800F0C3F

MODERN SL AVERY STATEMENT 2023

HITACHI RAIL AUSTRALIACONTENTS
01

Introduction

02

02

Twelve Month Snapshot

02

03

Hitachi Rail Australia’s Structure, Operations and Supply Chains

03

04

03.1

Hitachi Rail Australia’s Structure

03

03.2

Operations of Hitachi Rail Australia, Hitachi Rail India & Hitachi Rail Malaysia

03

03.3

Supply Chains of Hitachi Rail Australia, Hitachi Rail India & Hitachi Rail Malaysia

04

03.4

Potential Risks in Operations and Supply Chains of Hitachi Rail Australia, Hitachi Rail India& Hitachi Rail Malaysia

04

Actions taken in the 2022-2023 Reporting Period

05

04.1

Policies and Procedures of Hitachi Rail Australia, Hitachi Rail India & Hitachi Rail Malaysia

05

04.2

How Hitachi Rail Australia assesses, controls and monitors risks

06

04.3

Assessing the effectiveness of Hitachi Rail Australia’s policies and procedures

06

04.4

Commitments for the 2022/23 Reporting Period

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HITACHI RAIL AUSTRALIA

01 INTRODUCTION
Hitachi Rail STS Australia Pty Ltd (ABN 34 068 707 380)
(Hitachi Rail Australia) is committed to supporting andrespecting human rights, including the abolition of modern
slavery and all forms of forced or compulsory labour,
wherever it does business.

This is the fourth Modern Slavery Statement prepared by Hitachi
Rail Australia (Statement), in compliance with the AustralianModern Slavery Act 2018 (Cth) (Act). This Statement sets out the
key activities Hitachi Rail Australia has undertaken since 1 April
2022 to deliver on our commitments.

Hitachi Rail Australia is committed to acting ethically and withintegrity in all our business dealings and relationships andminimising the risk of slavery or human trafficking in our businessand supply chains. Hitachi Rail Australia engages its workforce tohelp them understand what modern slavery is, how to recogniseit, and how to act on risk indicators of these issues within ourbusiness and supply chain.

This Statement covers Hitachi Rail Australia’s operations, andincludes those of its subsidiaries, Hitachi Rail STS Malaysia Sdn
Bhd (Hitachi Rail Malaysia) and Hitachi Rail STS India Pvt Ltd(Hitachi Rail India). References to “Hitachi Rail” in this Statement
describe policies and initiatives which the Hitachi Rail group ofcompanies (see section 3.1) employs at the global level, as they
apply to Hitachi Rail Australia and our subsidiaries.

02 TWELVE MONTH SNAPSHOTOn a local level, Hitachi Rail Australia:
f Adopted the Hitachi Group Code of Ethics and BusinessConduct (2023) (Code of Ethics), which replaces theprevious Hitachi Rail Code of Ethics (2020). The new
Code of Ethics further emphasises Hitachi Rail Australia’scommitment to the abolition of slavery and all forms offorced or compulsory labour and details its commitment tocaring for its communities;

Hitachi Rail has, at the global level:f Further strengthened the expertise and resourcing of its
compliance function under the supervision of the Chief
Compliance Officer, including the appointment of dedicatedsenior compliance managers for anti-bribery and anticorruption, compliance operations, whistleblowing andinvestigations;f Deployed training between November 2022 and January2023 to its internal buyers and category managers
regarding the registration with and use of EcoVadis, which
is a tool that allows Hitachi Rail to benchmark and risk
score suppliers against a range of sustainability and humanrights criteria;

f Deployed the first tranche of bespoke Modern Slavery
training to staff of Hitachi Rail Australia, Hitachi Rail
Malaysia and Hitachi Rail India;
f Continued to ensure that its workforce undertakes
mandatory training regarding the Code of Ethics;
f Revised its suite of subcontract documents to update
compliance, modern slavery, anti-bribery, anti-corruption
clauses to ensure that suppliers comply with all applicablelaws, including the Act, the Hitachi Rail Supplier Code of
Conduct (2021) (the Supplier Code of Conduct) and theCode of Ethics;

f Continued its engagement with key stakeholders regarding
modern slavery and human trafficking including Responsible
Sourcing, Worst Forms of Child Labour, Business & Human
Rights Working Groups and the Global Child Forum; andf Launched an online platform in February 2023 called
Jaggaer for supplier onboarding, which includes a risk
model for compliance due diligence checks whereby
country and industry human rights risks, are assessed.
Jaggaer includes documented acceptance by suppliers of
the Supplier Code of Conduct as part of the onboarding
process; andf Drafted and commenced internal stakeholder engagement
regarding a new Hitachi Rail Modern Slavery Policy.

f Continues to review transactions between Hitachi Rail
Australia or its subsidiaries, and high risk jurisdictions.
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HITACHI RAIL AUSTRALIA

03 HITACHI RAIL AUSTRALIA’S STRUCTURE, OPERATIONS AND SUPPLY CHAINS
03.1
Hitachi Rail Australia’s Structure
Hitachi Rail Australia is part of a larger group of companies that are subject to direction and coordination of Hitachi, Ltd. (Hitachi). Hitachi
Rail Australia is wholly owned by Hitachi Rail STS S.p.A, which in turn is wholly owned by Hitachi Rail Limited, the holding company of
Hitachi’s Railway Systems Business Unit. A chart depicting the organisational structure of Hitachi Rail Australia and that of its subsidiaries
Hitachi Rail Malaysia and Hitachi Rail India is set out below:

Hitachi, Ltd.
100% ownership - ultimate holding company

Hitachi Rail Limited
100% ownership - senior parent

Hitachi Rail STS S.p.A
100% ownership - parent company

Hitachi Rail STS Australia Ply Ltd.
(Hitachi Rail Australia)
100% ownership

Hitachi Rail STS Malaysia Sdn Bhd(Hitachi Rail Malaysia)

99.99% ownership

Hitachi Rail STS India Pvt Ltd(Hitachi Rail India)

03.2 Operations of Hitachi Rail Australia, Hitachi Rail India & Hitachi Rail Malaysia
Hitachi Rail is a fully integrated, global provider of rail
solutions across rolling stock, signalling, operations, service &maintenance, digital technology and turnkey solutions. HitachiRail’s mission is to contribute to society through the continuous
development of superior rail transport solutions.
Drawing on the wider Hitachi Group’s market leading technology
and research and development capabilities, Hitachi Rail Australia
strives for industry leading innovations and solutions that candeliver value for customers and sustainable railway systems that
benefit wider society.
Major projects being delivered by Hitachi Rail Australia, and its
subsidiaries Hitachi Rail India & Hitachi Rail Malaysia, during the2022/2023 reporting period include:f Design and delivery of a new railway signalling system(ETCS) for South East Queensland as part of the Cross River
Rail Project;f Klang Valley Double Track Phase I and Southern Double
Track projects in Malaysia;
f Design, Manufacture, Supply, Installation, Testing &Commissioning of Signalling & Train Control System andVideo Management System and Telecommunication for
Chennai Metro Rail Limited, India;
f Design, Manufacture, Supply, Installation, Testing andCommissioning of Control and Signalling, Telecom and Low
Current Systems for Kolkata E-W Metro Project, India;
f Manufacture, Supply, Installation, Testing andCommissioning of Train Control, Signaling and
Telecommunication Systems, Supply of Spares and Trainingof Operation & Maintenance personnel for Noida - Greater
Noida Metro Project, India; andf Modernisation of signalling and telecommunication systems
on Ghaziabad-Kanpur Section, India.

f the Queensland New Generation Rollingstock Project,which involves upgrading the rail fleet in South East
Queensland to be ETCS compatible;f Continuing partnership with Rio Tinto in developing its
world-first autonomous heavy freight long distance rail
network, known as AutoHaul®, operating since 2018;03

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03.3
Supply Chains of Hitachi Rail Australia, Hitachi Rail India& Hitachi Rail Malaysia
Hitachi Rail Australia, Hitachi Rail India & Hitachi Rail Malaysia
do not undertake any manufacturing activity in the development
and delivery of systems and services for their operations.
The highly specialised products and components required toassemble these systems and services are supplied from within the
Hitachi Rail group’s factories based in Italy, France, the USA andJapan, with final assembly, installation and commissioning work
undertaken by workers in Australia, Malaysia and India.

HITACHI RAIL AUSTRALIA

03.4
Potential Risks in Operations and Supply Chains ofHitachi Rail Australia, Hitachi Rail India & Hitachi Rail
Malaysia
Hitachi Rail has identified the following jurisdictions as giving riseto the highest risk of modern slavery and human trafficking:f Afghanistanf Algeria
f Belarus
f Burundi
f Chinaf Comorosf Cubaf Eritrea
f Iran (Islamic Republic of)f Korea, Northf Lesotho
f Myanmarf Nicaragua
f Papua New Guinea
f Russian Federation
f South Sudan
f Syrian Arab Republic
f Turkmenistan
f Venezuela (Bolivarian Republic of)f Libya

Hitachi Rail Australia, Hitachi Rail India & Hitachi Rail
Malaysia rely primarily on direct relationships with
manufacturers (predominately related Hitachi group entities)
and approved OEM resellers for the purchase of materials
for their projects including circuit boards, mechanical andplastic parts, cables, industrial PCs, on-board equipment andelectromechanical components.
Hitachi Rail Australia, Hitachi Rail India & Hitachi Rail Malaysia
also lease a number of commercial and warehouse facilities tosupport their operations, and procure cleaning and maintenanceservices from external service providers. Engagement of these
services is undertaken using standard terms and conditions, which
require providers to undertake to comply with Hitachi Rail policies
regarding ethical behaviour and standards.

f Somalia
f Yemen
We have reviewed all transactions between Hitachi Rail
Australia, Hitachi Rail India & Hitachi Rail Malaysia and the highrisk jurisdictions set out above. There was one intra-company
transaction with a related entity in China during the 2022-2023
reporting period, and no evidence of wrongdoing was identified.
Specific measures we take to identify, assess, control and monitor
risks are set out in further detail in Section 4.2 of this Statement.

04

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04 ACTIONS TAKEN IN THE 2022-2023 REPORTING PERIOD
Since publication of its last statement, Hitachi Rail has also:f Updated its Whistleblowing & Speak-Up Policy (2023)
that promotes a “speak-up” culture whereby anyone
can report, in good faith, actual or suspected violationsor breaches of laws, regulations, the Code of Ethics, or
its policies and emphasises that Hitachi does not tolerate
retaliation against whistleblowers;
f Published an internal Compliance Programme Manual(2023) that describes how to prevent, detect and respondto compliance risks and misconduct, and promote a cultureof ethical conduct; andIn addition to the key activities captured in the “Twelve Month
Snapshot” at Section 2 of this Statement, this Section sets out
Hitachi Rail policies and procedures, and how we identify,
assess, respond to and monitor risks in our operations and supply
chain to respond to the potential risks set out above.
04.1
Policies and Procedures of Hitachi Rail Australia, Hitachi
Rail India & Hitachi Rail Malaysia
Hitachi Rail Australia’s commitment to prevent modern slavery or
human trafficking in its business and supply chains is underpinned
by appropriate policies that are reviewed and updated to reflect
its evolving business globally.
The recently updated Code of Ethics applies to all membersof Hitachi Rail Australia’s governance and control bodies,
executives, workforce and supply chain. The Code of Ethics
reflects Hitachi Rail Australia’s commitment to:

f Drafted and commenced stakeholder engagement
regarding the publication of a Modern Slavery Policythat sets out Hitachi Rail’s expectations for the conduct of its
workforce and contractors to help eliminate slavery and allforms of forced or compulsory labour.
Hitachi Rail supplements the above with the following relevantinternal policies and manuals, which are subject to continuous
review and improvement:f Environmental Policy (2022);
f Quality Policy (2022);
f Product Safety Policy (2022);
f Health and Safety Policy (2022);
f Security Policy (2022);
f Whistleblowing Policy (2022);
f Social Accountability Manual (2022);

f Abolition of slavery and all forms of forced orcompulsory labour;f Corporate Social Responsibility Governance
Manual (2022)

f Freedom of association;f Enterprise Risk Management Frameworkf Equal pay for equal work;f Integrated Risk Management Framework Manual (2021);

f Equality at work;f Other written employment practices and procedures that
ensure fair recruitment and treatment of employees.

f Just and favourable remuneration;f Non-discrimination; andf Protection for the organisation of and participation incollective bargaining.

Hitachi Rail continues to makes its policies available to all workers
and internal parties globally through publication on our internal
document management system. These policies are regularly
reviewed and updated.

Hitachi Rail Australia requires its suppliers to comply with the
Supplier Code of Conduct, which expressly precludes the use offorced, bonded, indentured, involuntary or exploitative labour,
slavery and human trafficking. The Supplier Code of Conduct
was developed to reflect the 10 Principles of the United Nations
Global Compact.
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04.2
How Hitachi Rail Australia assesses, controls and monitors risks
Hitachi Rail Australia identifies, assesses, controls and monitors
the risk of modern slavery and human trafficking in the industries
and jurisdictions identified as being high risk, and its supply
chain more generally, through our supplier due diligence. Core
activities include:f Hitachi Rail Assessment & Screening: Initial desktop
assessment of all suppliers for, anti-money laundering,anti-bribery and corruption, adverse media, sanctions,watchlists and politically exposed persons. Prospective
suppliers are required to agree to adhere to the Supplier
Code of Conduct and complete the Hitachi Rail Australia
screening questionnaire that includes information tounderstand the supplier’s compliance with regulatory
requirements and best practices. This screening is repeatedon a periodic basis. As noted above, this process has been
automated and harmonised under the online platform,
Jaggaer, since the last reporting period.
f Audit: Hitachi Rail Australia has a framework in place
for all current procurement processes. These are all tested
internally and externally through rigorous audits thatlook at compliance and the application and adherence toprocesses. Where there is a non-conformance report orrecommendation, Hitachi Rail Australia builds them into theprocess development.
f Whistleblowing & Speakup: Hitachi Rail provides various
speak-up channels for any person, internal or external to its
our business, seeking to report a concern regarding actualor suspected misconduct that may be a violation or breachof any applicable law or regulation, its Code of Ethics, or
any of its policies. Hitachi Rail’s speak-up channels include
managers, members of our Human Resources or Legal &Compliance functions, and our dedicated 24-7 Hitachi
Global Compliance Hotline, which provides for online or
telephonic reporting. Hitachi Rail additionally provides
for specific email addresses for supervisory bodies andother eligible recipients as speak-up channels, as requiredby certain local laws and regulations where it operates.
As noted above, Hitachi Rail does not tolerate retaliation
against whistleblowers
f Compliance: Hitachi Rail has a dedicated global
compliance team, led by its Chief Compliance Officer. The
compliance team is supported by other functions, includingInternal Audit, Legal, Human Resources, Procurement
and Sales.
f Contracts: Hitachi Rail Australia binds suppliers to comply
with all applicable laws, including the Act and our Supplier
Code of Conduct.

f Training: Raising awareness and building expertise isanother process used by Hitachi Rail Australia to manage
human rights risks. Hitachi Rail Australia ensures that all
new members of its workforce undertake mandatory annual
training on its Code of Ethics (translated into 15 languages)
within three months of joining. This training is refreshedannually for its whole workforce. The training explains how
to spot and report potential or actual breaches of the Codeof Ethics, including in relation to human rights, and details
the consequences for failing to comply with the Code of
Ethics. Further, since its last Modern Slavery Statement,
Hitachi Rail Australia has deployed bespoke Modern
Slavery e-learning to its workforce globally that helps
them identify potential instances of Modern Slavery in its
business and supply chain, and explains its procedures forpreventing and reporting the same.
04.3
Assessing the effectiveness of Hitachi Rail Australia’s
policies and procedures
Hitachi Rail Australia is committed to ensuring that we source
responsibly, trade ethically and prevent human trafficking within
our business and supply chain.
To assess the effectiveness of our activities, Hitachi Rail Australia:
f Undertakes periodic reviews of its supplier base to identify
potential risks of exposure to modern slavery within its
supply chain;f Reviews the modern slavery statements of our key suppliersand competitors;
f Seeks to identify and mitigate risks wherever they arise; andf Reviews all transactions between Hitachi Rail Australia,
Hitachi Rail India & Hitachi Rail Malaysia with any countries
deemed high risk.

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HITACHI RAIL AUSTRALIA

04.4
Commitments for the 2023/24 Reporting Period
Planned activities for the period from 1 April 2023 to 31 March2024 are:f Ensure 100% of new members of the workforce with accessto eLearning have completed Code of Ethics training within
3 months of new employee start datef Ensure that 100% of existing workforce with access toeLearning have undertaken refresher Code of Ethics
training annually;f Ensure 100% of workforce with access to eLearning havecompleted Modern Slavery training by 31 March 2024;
f Continue to ensure that anti-slavery clauses and compliancewith the Supplier Code of Conduct are embedded into all
high-risk contracts;
f Ensure that every identified instance of modern slavery andlabour exploitation is addressed.
This Statement was approved by the Hitachi Rail STS Australia Pty
Ltd Board of Directors.

Sarfaraz Samnakay
Country Representative and Executive Director, Australia
Hitachi Rail STS Australia Pty Ltd07

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