Hitachi Group
Code of Ethics andBusiness Conduct
Your guide to responsible
behavior, every day

Effective March 1, 2023

Dear Hitachi Group Colleagues:
At Hitachi, we are a diverse group of people with different backgrounds, experiences,
identities and perspectives, working together to solve social challenges such as
climate change and urban population growth while ensuring the health and safety of
our employees and creating a workplace where everyone can thrive.
Hitachi employees worldwide have helped Hitachi build an invaluable asset: areputation for operating with honesty and fairness. We recognize that our reputationfor ethically doing business will continue to be a competitive advantage.
Our Mission – contribute to society through developing superior, original technology
and products – supported by our Values (Harmony, Sincerity, and Pioneering Spirit)and the ideas of Kihon-to-Seido (Basics and Ethics) will continue to guide us as
we expand our global footprint and support people’s quality of life with data andtechnology.

Keiji Kojima
President & CEO
Hitachi, Ltd.

When faced with challenging or difficult situations, refer to the Hitachi Group Code of
Ethics and Business Conduct for guidance. It will provide you with the guidance andconfidence you need to make the right choice and do what is right, no matter where
you are in the world. If you are still uncertain about the right choice, reach out to oneof our speak-up channels for help and to report concerns. Hitachi values your help
in avoiding and uncovering possible misconduct. Hitachi prohibits retaliation against
anyone who shares a concern in good faith or participates in an investigation.
I ask you to read the Code (pages 5 through 36), understand it, ask questions andraise concerns as necessary. By following our Code, we can earn and sustain
the trust of society, our customers and colleagues, which is fundamental to ourcompany’s success.

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Our Mission,
Values and Vision
Originally set by Hitachi founder Namihei Odaira, the Mission has been carefully passed on to
generations of employees and stakeholders throughout Hitachi’s more than 100-year history.
The Values reflect the Hitachi Founding Spirit, which was shaped by the achievements of our

Our Values emulate the founding spirit of Hitachi,

company predecessors as they worked hard to fulfill Hitachi’s Mission.

and have been embraced with care and guided
by our predecessors for more than a century.

The Vision has been created based on the Mission and Values. It is an expression of what theThis spirit resonates through the way we think

Hitachi Group aims to become in the future as it advances to its next stage of growth.

and operate, as we collectively strive to deliver
solutions that create new value globally.

The Mission, Values and Vision are made to be shared in a simple concept: Hitachi Group Identity.
Harmony
The Hitachi Group Code of Ethics and Business Conduct consists of rules and principles to assist

The willingness to respect the opinions of others

officers and employees make decisions and take actions consistent with the Hitachi Group Identity.

and discuss matters in a manner that is thoroughand frank, but fair and impartial, and once a
conclusion has been reached, to cooperate andwork together to achieve a common goal.
Sincerity
To act with a sense of ownership and honesty at
all times and never pass the buck. The spirit tomeet society’s expectations and generatecredibility for Hitachi.
Pioneering Spirit
To work creatively, using novel approaches toenter new areas. To always act as a pioneer within
our areas of expertise and to have the passion to
pursue higher goals beyond our capabilities.

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Hitachi Group Code of
Ethics and Business Conduct
Table of Contents
Be AwareDeal Fairly With Others

Why Hitachi Has a Code

Build Trust with Customers

Who Is Covered by Hitachi’s Code
What Employees Need to Do

Develop Relationships with
Procurement Partners

What Leaders Need to Do

Compete Fairly

How You Can Make Good Decisions

Comply with Trade Compliance Laws

How You Can Report Concerns

Prevent Bribery and Corruption

What Happens When You Report a
		 Concern

Protect What Is Ours

Communicate Responsibly
Trade Securities Fairly and Legally

Care For Our Communities

Safeguard Our Assets

Care For Our Planet

Protect Our Intellectual Property

Respect Human Rights

Protect Non-Public Information

Appreciate Diversity, Equity
and Inclusion

Demonstrate Accountability
Select Business Partners Carefully
Identify and Manage Conflicts
		 of Interest

Provide a Workplace That Is Free
From Harassment
Promote Health and Safety
Invest in Our Communities

Maintain Accurate Financial Records
Prevent Money Laundering
Give and Receive Gifts, Travel and		 Entertainment Responsibly
Safeguard Confidential Business		 Information and Personal Data
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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Be AwareWhy Hitachi Has a Code
Who Is Covered by Hitachi’s Code
What Employees Need to Do

Why Hitachi Has a Code

What Leaders Need to Do

You make countless decisions at work each day. Our Code can

How You Can Make Good Decisions

help you navigate challenging situations and guide your decisions.

How You Can Report Concerns
What Happens When You Report a Concern

The Code enables you to:• Comply with Hitachi’s policies and protocols,
		 as well as applicable laws and regulations;• Conduct yourself honestly and ethically; and• Understand what Hitachi expects from you.

Who Is Covered by
Hitachi’s Code
The Code applies to anyone who works for or represents Hitachi.
The Code also applies to members of the board of directors,
management, employees and contractors of Hitachi.
Hitachi also expects business partners to adhere to behaviorsconsistent with our Code and applicable laws and regulations
when working with or on behalf of Hitachi.

If applicable local laws are more restrictive than this Code, you must comply
with those local laws. Non-compliant actions can result in disciplinary
action, fines, penalties or termination. If there are discrepancies between thetranslated versions of this Code, the Japanese version will prevail.
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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

As a Hitachi employee, you are responsible for ethical conduct bydemonstrating Hitachi’s Values through your words and actions.
These words and actions enable an environment of ethicalbehavior by being fair, honest and transparent in all circumstances.
Doing what is right includes avoiding participation in any
fraudulent, illegal, or illicit activity or activity perceived as such.

What Employees Need to Do

What Leaders Need to Do

Be knowledgeable. Read and be familiar with the Code and Hitachi’s
policies and protocols as well as business unit/group company or local
policies, procedures and protocols. Complete your ethics and businessconduct training promptly. Pay attention to activities that are inconsistent
with doing what is right.

Model the Code and our Values. Make ethical decisions, live our
Values and demonstrate them in everything you do.

Follow the law. Learn about applicable laws and regulations and how
to apply them to your job. If you are unsure about applicable laws or
regulations, speak with your manager or a Human Resources, Complianceor Legal team member.

Be informed. Refer to the Code, know where to go for resources andanswer employee questions.

Ask for help. Speak with your manager or a Human Resources,
Compliance or Legal team member before acting when an answer isunclear.
Speak up. Raise concerns about potential misconduct or violations of ourCode, policies and protocols, laws and regulations. Cooperate fully andtruthfully if you are part of an investigation.

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Set expectations. Discuss the importance of ethics and let employees
know you expect them to do what is right.

Talk about the Code. Engage your team in discussions during teammeetings about doing business ethically and honestly.
Be responsive and promote a speak-up environment. Encourage
employees to come to you with ethical conduct questions or concerns.
Listen to them carefully and offer guidance. Refer them to our speak-up
channels when necessary.
Take action. If you become aware of a violation or potential misconduct,
speak up immediately. Never retaliate or allow others to retaliate.

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Demonstrate Accountability

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How You Can
Make Good Decisions

Care For Our Communities

If you are in a situation where the ethicalchoice is not clear, ask yourself:

Doing what is right andethical is our goal.

Is it consistent with our Code?

NO

YES

Is it legal?

NO
YES

Does it comply with Hitachi’s
policies and protocols?

NO

YES

Does it support Hitachi’s
Mission, Values and Vision?

NO

YES

Would I be comfortable if myactions were made public?

NO

YES

Hitachi Group|If not sure about any question:

If yes to all:If no to any:

Discuss it with your manager or a Human Resources,
Compliance or Legal team member.

Do it. Your decision is
the right one.

Do not do it. It may put you,someone else or Hitachi at risk.

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Demonstrate Accountability

How You Can Report a Concern
Maybe you sense that something is not right in your work environment. Perhaps you
saw something or heard about an act that may violate our Code, Hitachi’s policies andprotocols or laws and regulations. If so, you have a responsibility to report your concerns
about potential misconduct even if you are uncertain that a violation has occurred.

Speak-up Channels

Deal Fairly With Others

Care For Our Communities

What Is Retaliation?
Any action that would deter someone
from reporting a concern or participating
in an investigation.
Examples of retaliation include demotion,harassment, job reassignment, threats orother actions taken against someone
because they raised a concern or
participated in an investigation.

Hitachi offers a variety of speak-up channels for more help and to report concerns.

Speak• Your manager;• Next-level manager or another manager you trust; or• Human Resources, Compliance or Legal team.
Or, contact the Hitachi Global Compliance Hotline.

Call• An independent third party runs this reporting service.
• The hotline is available 24/7 and allows you to remain
anonymous, where permitted by law.
To reach the hotline:

Visit

Visit hitachi.ethicspoint.com

Call

Call toll-free. Locate the number for your country
on hitachi.ethicspoint.com
Translation services are available.

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Zero-Tolerance for
Retaliation
Hitachi values your help in avoiding anduncovering possible misconduct. Hitachi
prohibits retaliation against anyone
who shares a concern in good faith orparticipates in an investigation.
Hitachi will investigate any charge of retaliation.
Employees who engage in retaliation will be
subject to disciplinary action.

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What Happens When You
Report a Concern

You make a reportin good faith.
You may choose
to report
anonymously,
where permitted
by law.

6

5
The investigation
proceeds.
Participate fully in an
investigation if you
are asked.

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Your report is logged
in the concerns
management system.

It helps theinvestigation if you
provide your name
and/or contact
information.

Code of Ethics and Business Conduct

Care For Our Communities

When you report a concern, you help us handle issues properly, address problems
before they occur and remedy situations that have already happened. You also help
build trust with each other and with our customers and business partners.

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4Your report is routed
to the appropriate
internal resources.

We develop an
investigation plan.

7
The allegations areverified or found to
be without merit.

The appropriate
action is taken.
Determine if
any process
or program
enhancements
are needed.

Determine
if policies orprocedures
need to bemodified.

Determine if
discipline isneeded.

Other actions
as appropriate.

9Be Aware

Protect What Is Ours

Protect
What Is Ours
Safeguard Our Assets
Protect Our Intellectual Property
Protect Non-Public Information

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Safeguard Our Assets
Hitachi and its employees protect electronic, financial and physicalassets provided or made available to you throughout youremployment.

Our commitment
Hitachi provides resources to you to help manage our business
effectively and efficiently while serving our customers. Guard theseresources against abuse, carelessness, fraud, loss and theft by using
them according to Hitachi’s policies and protocols.

In Your Daily Work
Know what to protect. Examples of Hitachi assets include:• Physical assets – buildings, equipment, office		 furniture and tools.
• Technology – computers, hardware, phones, tablets,
		 software and access to systems.
Secure Hitachi’s assets. Do not use Hitachi assets for personal
benefit. Do not dispose of or sell Hitachi’s assets without appropriate
approval.
Report misuse. If you see someone engaging in an unethical activity
or know someone is misusing assets, speak with your manager or a
Human Resources, Compliance or Legal team member.

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Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Protect Our Intellectual Property
Hitachi protects and uses intellectual
property, including our brand.

Our commitment
Intellectual property

We treat Hitachi’s intellectual property as a valuable Hitachi asset andIntellectual property is a valuable, intangible asset which derives

an essential part of our competitive advantage. We will effectively use

from the work of the mind.

intellectual property for the sustainable development of our business.

Examples include:• Brand names• Software• Designs• Ideas• Trade secrets • Works of art• Inventions

In Your Daily Work
Protect Hitachi’s intellectual property. Ensure appropriate
protections such as filing an application for registration or entering
into non-disclosure agreement before using intellectual property for

Patents, registered trademarks, copyrights or other legal
measures protect intellectual property.

our business or disclosing confidential information outside Hitachi.
Respect third parties’ intellectual property. Respect the intellectual
property of others and ensure we use it only where we have obtained
the right to do so from the owner of the intellectual property.

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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Protect Non-Public Information
Hitachi and its employees handle information with care,
protecting it from attacks, disclosure or misuse.

Material non-public information

Our commitment

Information that would affect an investor’s decision to buy or sell a

We are committed to keeping our non-public information protectedcompany’s securities. Examples include information about Hitachi’s

and safe. We also respect our business partners and customers byacquisition or divestiture plans, competitive intelligence, financial

not disclosing their confidential or proprietary business information.

information, long-term strategies and research and development.

In Your Daily Work
Access only the information you need. Never access information
unless you have authority to do so, and use Hitachi-approved tools
when you share and store information.
Protect your Hitachi user account information and passwords.
Never share this information with anyone. Follow IT policies.
Use strong email security practices. Review emails carefully andreport suspicious emails immediately to the IT Information Security
team. Never click on any unfamiliar links or respond to unusual
requests. Do not use Hitachi passwords for personal accounts.

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Be Aware

Protect What Is Ours

Demonstrate Accountability

Demonstrate
Accountability

Deal Fairly With Others

Care For Our Communities

Select Business Partners Carefully

Select Business
Partners Carefully

Identify and Manage Conflicts of Interest

Hitachi is committed to doing business ethically and legally and seeks

Maintain Accurate Financial Records
Prevent Money Laundering

to work with business partners who operate to the highest standardsof integrity and quality.

Give and Receive Gifts, Travel and Entertainment Responsibly

Our commitment

Safeguard Confidential Business Information and Personal Data

Before entering into business with a business partner, Hitachicompletes a risk-based screening or reputational due diligence process
on potential business partners. We periodically repeat this process forbusiness partners with whom Hitachi has a long-term relationship.

In Your Daily Work
Choose wisely. If you are responsible for business partners, engage
your Compliance or Procurement team to help perform due diligence.
This screening process identifies a business partner’s potential risk andcapabilities, experience, financial status, price, quality and reputation.
Voice your concerns immediately. If you work with business
partners, confirm they understand the importance of complying withlaws and aligning to our Mission, Values and Vision. Monitor theirperformance to ensure they meet their obligations. Read and stay
current with your business partner’s financial, legal or reputational
status, especially if the business partner is in a high-risk country. If
you learn about information or suspect activity that could put Hitachi
at risk, voice your concerns immediately.

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Demonstrate Accountability

Identify and Manage
Conflicts of Interest
Hitachi’s employees have interests and relationships
outside of work but act in Hitachi’s best interest.

Deal Fairly With Others

Care For Our Communities

Our commitment
We do not allow our interests to affect the business decisions wemake as Hitachi employees. When our outside activities conflict orappear to conflict with our responsibilities as a Hitachi employee,
we disclose situations that could be considered a conflict of interest.

In Your Daily Work
Disclose conflicts of interest. Disclose as soon as you become

Conflict of interest
When a person chooses personal gain over duties to
Hitachi or uses their position for personal gain. The
appearance of a conflict can damage
Hitachi’s reputation.

aware of an actual, potential or perceived conflict of interest to yourmanager. Agree upon a mitigation plan and follow the plan.
Seek advice. When in doubt, consult the Compliance or Legal teamfor guidance.

Is It a Conflict?
Ask yourself:
Could my personal interests
or relationships influence thedecisions I make?

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Code of Ethics and Business Conduct

Could it look that way tosomeone else?

If yes, it is most likely
a conflict of interest.

If yes, it is most likely
a conflict of interest.

Seek guidance when
you are not sure.

Seek guidance when
you are not sure.

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Care For Our Communities

Maintain Accurate
Financial Records
Hitachi presents an honest and accurate
financial image of our business.

Our commitment
We are committed to accurate recordkeeping and reporting to help
Hitachi meet our legal and regulatory requirements and protect
shareholder value.

In Your Daily Work
Properly record transactions. Never alter, conceal, make false
statements and entries or omit the true nature of any transaction.
Regardless of the value, record all transactions to reflect the trueand fair value in reasonable detail. Record and classify transactionsin the proper accounting period and the appropriate account anddepartment. Do not keep hidden financial accounts or unrecorded
funds.
Manage records properly. Follow policies that relate to disposal,
maintenance and storage of documents. Never destroy informationneeded for an audit, investigation or legal proceeding. If you receivea legal hold notice, follow the guidelines in the notification. And if you
are unsure about what is required, check with the Legal team anddocument retention policies.
Speak up. Use one of the speak-up channels if anyone asks you
to falsify a financial record or if you suspect accounting practices
mishandling. Also, contact one of the speak-up channels if you
suspect misuse of our funds or property or our customers orbusiness partners.

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Deal Fairly With Others

Care For Our Communities

Prevent Money Laundering
Hitachi guards against using our products
or services or transactions to launder theproceeds of crime.

Our commitment
We are committed to conducting business only with customers
and business partners involved in legitimate business activities andwith money from legitimate sources. We comply with anti-money
laundering and anti-terrorism laws in all countries where we operate.

In Your Daily Work
Money laundering
This illegal process disguises funds created through criminal

Be knowledgeable. Read and stay current with the Code andHitachi’s policies and protocols. Complete mandatory ethics andbusiness conduct training promptly.

activity such as drug dealing, fraud, human trafficking, tax
evasion or terrorism. It makes the funds look as though they are

Conduct due diligence. Screen prospective business partners tolegitimate, usually by transferring the proceeds through legitimate

ensure they are involved in legitimate business activities.

businesses. It also includes using legitimate funds to support
criminal activity or terrorism.

Know the laws and regulations. Comply with anti-money
laundering laws and regulations. Consult with a Compliance or Legalteam member if you have questions or need help.
Speak up. If you encounter something suspicious, consult with yourmanager or a Compliance or Legal team member.
Stay alert. Watch for activities and transactions that are more
susceptible to acts of money laundering and require increased
monitoring.
Take a stand. Remember that by preventing money laundering, youare protecting Hitachi and preventing a crime.

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Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Give and Receive Gifts, Travel andEntertainment Responsibly
Hitachi employees act responsibly when giving andreceiving gifts, travel and entertainment.

Gifts, travel and entertainment guidelines
Use good judgment when accepting gifts, travel or entertainment andrespect the recipient’s own business ethics policies or protocols.

When you are accepting gifts, travel or entertainment:• Identify the business purpose in advance.
• Both parties must be present.
• Avoid accepting gifts and entertainment during a bidding process.
• Do not accept expensive gifts or entertainment, such as travel and		 lodging, premier sporting events that are above nominal value.
• Attend entertainment in a setting suitable for conducting business.

When you are offering gifts or entertainment:

Our commitment
Hitachi values the relationships with our business partners andcustomers. We provide business courtesies — gifts, travel orentertainment — when it supports a legitimate business purpose
and is reasonable and appropriate under the circumstances.
We do not offer gifts, travel or entertainment that may unduly
influence a business decision or is contrary to local law. Likewise,
we do not accept gifts, travel and entertainment if the giver expects
favorable treatment or improperly influence a business decision.

• Speak with your manager if the value of the gift or entertainment		 is extravagant.
• Ensure the event is in a setting appropriate for conducting business.
• Report entertainment costs accurately for recordkeeping purposes.

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In Your Daily Work
Know when to say “No.” Offers of gifts, travel or entertainmentthat do not comply with our policies and protocols can also
create a conflict of interest. Know what is allowed – and what isnot – and turn down offers that violate our policies or protocols
or that someone might perceive as a violation.
Explain our protocol on gifts, travel and entertainment
to new business partners. The exchange of gifts, meals,
entertainment and hospitality helps build better relationships withcustomers and business partners. Although local customs about
gifts and entertainment vary, do not accept a gift if it will obligate,appear to obligate or influence your decision making. A goodtime to explain our protocol is several weeks before holidays or
periods in which it is socially customary to give gifts.

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Give and Receive Gifts, Travel and Entertainment Responsibly

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Deal Fairly With Others

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Safeguard Confidential BusinessInformation and Personal Data
Hitachi is committed to handling confidential
business information responsibly.

Our commitment
We protect Hitachi’s confidential business information and takeprecautions to protect information from unauthorized access anddisclosure. We also protect Hitachi’s customers’ and business
partners’ confidential business information.

In Your Daily Work
Respect the trust that businesses place in you. When dealing
with confidential business information, show that you understand andrespect its importance to the person and Hitachi.
Tell people how you are using the information. Be honest andtransparent about how you will use confidential business information.
Protect the information. Safeguard business information fromunauthorized access or disclosure. Report any known or suspected
unauthorized access or disclosure to a Data Protection, Legal orCompliance team member as soon as possible.
Follow data protection laws and our policies. Learn about ourdata policies, procedures, and the laws that apply to you and observe
them when handling data.
Seek guidance. If you have questions about data protection, contact
a Data Protection, Legal or Compliance team member.

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Deal Fairly
with Others

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Build Trust With Customers
Hitachi places the highest value on our interactions with customers,
recognizing that a long and fruitful customer relationship is one of our

Build Trust With Customers

most valued assets.

Develop Relationships with Procurement Partners

Our commitment

Compete Fairly

We provide products and services that meet the needs and requirements

Comply with Trade Compliance Lawsof our customers. To ensure quality and safety, we comply with relevant

Prevent Bribery and Corruption
Communicate Responsibly
Trade Securities Fairly and Legallylaws, standards and conditions of the contracts with customers related
to quality and set additional standards where necessary.

In Your Daily Work
Serve our customers. Develop, produce or provide products andservices that meet the needs and requirements of our customers.
Comply with customer contracts, relevant laws and standards, ensure
quality and safety and consider environmental and societal effects.
Communicate with customers. Represent our products and services
accurately by making competitive comparisons fairly and promising what
we can deliver ethically and legally. Address customer complaints or
defects quickly and identify causes to eliminate them in the future.
Properly record testing and inspection. Never alter, conceal,make false statements and entries or omit the true nature of any
testing and inspection.
Seek guidance. If you have questions about quality and safety inconnection with customer interactions, contact a Quality Assurance,
Legal or Ethics and Compliance team member.
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Develop Relationships
With Procurement Partners
Hitachi treats procurement partners with
fairness, honesty and respect.

Deal Fairly With Others

Care For Our Communities

Our commitment
We expect our procurement partners to uphold values like ours andconduct business in a manner that does not cause adverse effects on
people and our planet. We mitigate supply chain risks and leverage
our purchasing power to drive positive social and environmental
outcomes by promoting ethical and responsible business practices.

In Your Daily Work
Find qualified procurement partners. If you are responsible forselecting procurement partners, review factors such as the businessstability, delivery time, license fees, price of the materials, services,quality and reliability and technological capability.
Also, check their adoption of social responsibility practices, including
abolishing unfair discrimination, eliminating child or forced labor andenvironmental conservation.
Know when to say “No.” Offers of gifts, travel or entertainmentthat do not comply with our policies and protocols can also create aconflict of interest. Turn down any gifts, travel or entertainment fromprocurement partners in procurement transactions.
Speak up. If you believe that a procurement partner violates laws
or regulations, consult with your manager or a Human Resources,
Compliance or Legal team member.

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Compete Fairly
Hitachi is committed to fair competition
and abides by applicable competition laws.

Our commitment
We compete fairly and comply with competition laws in all
countries in which we do business. We know that everyone
benefits from a competitive marketplace, so we follow the antitrust and fair competition laws in locations where we operate.
We also avoid the appearance of unfairly restricting anothercompany’s ability to compete against Hitachi.

Honest methods to gather competitive
information• Online research• Look at their social media channels• Customer feedback• Competitor’s job openings

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In Your Daily Work
Obey competition laws. Never enter into an oral or writtenagreement or understanding with a competitor to:• Divide markets or customers.
• Fix prices.
• Manipulate a competitive bidding process.
• Exchange or discuss sensitive information such as prices,		 customers, discounts, market share, product development
		 plans, capacity, sales territories, sales volumes, supply
		 terms or strategic plans.
Seek guidance. Competition and anti-trust laws are complex
and often situation specific. If you have questions, ask a Legal orCompliance team member, particularly for help with:• control of the supply of consumables servicing
		 and spare parts;• exclusive distribution arrangements;• loyalty or volume discounts;

Compete Fairly

Be Aware• territorial restrictions.
Be mindful of appearances. Avoid contact with competitorsthat might raise a suspicion of improper or inappropriate
conduct.
Gather competitive information fairly. If you gather
information about our competitors, use honest methods. Do not
encourage anyone to give you confidential information. Do not
engage in inappropriate discussions or anti-competitive conduct
while attending an industry association meeting or trade show. If
you become aware of this behavior, distance yourself from it andnotify a Compliance or Legal team member as soon as possible.

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Comply with Trade
Compliance Laws
Hitachi exports and imports goods worldwide,
following international trade laws and export controls.

Our commitment
We comply with national and international export control regulations
that control the cross-border transfer of our products and services,
economic sanctions and customs laws.

In Your Daily Work
Understand export and import policies. Export controls canapply to the physical movement of goods and intangible transfers ofsoftware and technology. An export includes hand-carrying goods ora laptop containing software or technical information across a border.
Be informed. Before making an export, know what you are exportingand its export classification, the country to which you are exporting,the recipient and end-user, and the intended end use of the item.
Comply with trade regulations. Obtain required export licenses
before proceeding with any export. Comply with the license terms or
any exemption requirements. Contact your International Trade team if
you are unsure about the laws, customs and practices that govern a
trade transaction.

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Prevent Bribery and Corruption
Hitachi does not tolerate acts of bribery or corruption.

Anything of value

Cash, donations to nonprofits (charities), gifts, entertainment, business
opportunities, meals, offers of employment and products or services
can be a bribe. There is no minimum or maximum amount associatedwith this term.

Bribery or bribe

Giving or receiving anything of value in exchange for an improper
decision or action.

Our commitment
We are committed to upholding the highest standards ofbusiness ethics and preventing bribery and corruption. We do
not offer or accept anything of value to keep business, securebusiness or gain an unfair advantage.

Facilitation or grease payment

Small payments that are made to a government official to speed up
routine government actions like processing paperwork, delivering mailor installing phones.

Government official

Employees of any government anywhere in the world or employees ofgovernment-controlled entities. The term also includes political parties
and party officials, candidates for political office, employees of public
international organizations, such as the United Nations.

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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

In Your Daily WorkBe knowledgeable. Read the Code and Hitachi’s policies and protocols.
Complete ethics and business conduct training promptly.
Know the laws and regulations. Comply with applicable anti-bribery andanti-corruption laws and regulations. Consult with a Compliance or Legal teammember if you have questions or need help.

Refuse to offer, pay or accept bribes. Report any request for – or offer of – abribe or kickback to your manager or a Human Resources, Compliance or Legalteam member.
Give and receive gifts, travel and entertainment responsibly. Ensure that
gifts, travel or entertainment are not given or accepted in circumstances in which
they could be – or give the appearance of being – bribes. Bribes to gain favor
are unacceptable in all circumstances and laws prohibiting bribes to government
officials and, in some cases, employees of commercial enterprises can carrysevere monetary and criminal penalties and negatively affect Hitachi’s reputation.
Limit the use of petty cash. Hitachi discourages the use of petty cash in our
offices around the globe. If local management approves the use of petty cash
for valid business purposes, document withdrawals and maintain appropriate
documentation to record accounting entries accurately.

Prevent Bribery and Corruption

Conduct due diligence. Before entering a business relationship, engage yourCompliance team to help perform due diligence on business partners. Select only
those who align with our Values and commitment to doing what is right.

Do not make facilitation payments. Hitachi does not permit facilitation
payments unless there is an immediate threat to life, safety, security or freedom.
If you make a payment under these circumstances, report it to a Compliance orLegal team member as soon as you can.
Speak up. If you encounter something suspicious, consult with your manager ora Human Resources, Compliance or Legal team member before proceeding.
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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Communicate Responsibly
Hitachi understands our words’ effect, so wecommunicate thoughtfully and responsibly.

Our commitment
Our reputation is one of our greatest assets, and it is up to each of us
to protect it. We use social media wisely and refer outside inquiries
about Hitachi’s business to our Branding and Communications team.

In Your Daily Work
Post responsibly on social media. Make it clear in your postingsor profile that your views are yours. Never disclose confidential
information about Hitachi, our business partners, customers, orcompetitors. Never post anything that might constitute bullying,harassment, intimidation, or a threat. Be mindful that social media
posts are usually permanent and global in reach.
Help Hitachi speak with one voice. Never speak for Hitachi or
your company if you are not authorized to do so. Remember, receive
approval from your manager and, if necessary, also from Hitachi’sBranding and Corporate Communications team before you discuss
your role as a Hitachi employee outside of Hitachi.

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Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Trade Securities Fairly
and Legally
Hitachi promotes trust by supporting
fair and open securities markets.

Insider Information
Information about a public company that has not been
made public, and that can affect the company’s stock price

Our commitment
We do not trade based on insider information or tip others by sharingthat information to trade. Board of directors, management andemployees trade only on publicly available information.

In Your Daily Work
Do not trade on insider information. It is illegal to buy orsell Hitachi stock or shares in our business partners if you haveinformation unknown to the public.

positively or negatively.
Examples:• Corporate partnerships• Pending merger or acquisition• Product recall• Shortfall in earnings

Do not share insider tips. Do not share insider information outsideof Hitachi, even with family members or friends. Never recommend
or suggest that anyone else buy or sell securities (often stock) of any
company when you have insider information about that company.
Speak up. Consult with a Compliance or Legal team member if
you are unsure about a situation or circumstance before providing
information or executing a trade.

Insider Trading
Insider trading is when someone who has insider
information trades a public company’s stock.
Examples:• Buying or selling securities based on insider information• Sharing non-public information about Hitachi companies
		 to friends and family who trade the stock

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Be Aware

Protect What Is OursCare For Our
Communities

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Care For Our Planet
Hitachi will address environmental issues and achieve a higher qualityof life and a sustainable society through our Social Innovation Business.

Care For Our Planet

Our commitment

Respect Human Rights

We believe in operating a sustainable business to preserve our planet

Appreciate Diversity, Equity and Inclusionand follow applicable laws and regulations that affect Hitachi. We will

Provide a Workplace That Is Free From Harassment
Promote Health and Safety
Invest in Our Communitites

collaborate with employees, business partners, customers, investors
to realize a decarbonized society where greenhouse gas emissions
such as carbon dioxide are net zero. We will also work to createa resource-efficient society that efficiently uses water and otherresources and reduces chemical substance emissions.

In Your Daily Work
Learn about Hitachi’s environmental strategies. Help Hitachiachieve its Environmental Vision, Long-term Environmental Targets,
Environmental Action Plan and Mid-term Management Plan.
Follow laws and regulations. Understand and follow
environmental laws and regulations that apply to the business andyour work, as well as Hitachi’s policies and protcols.
Minimize adverse environmental effects. Understand the direct
and indirect effects of your daily actions on the environment andminimize the adverse effects such as carbon dioxide emission,
pollution or waste.

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Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Respect Human Rights
Hitachi conducts business in a way that supports
and respects human rights.

Our commitment
We respect the human rights of all those involved in our businessactivities. All human beings are born free and equal in dignity, fairness,
respect and rights.
We follow the international conventions on human rights and laborlaws and national laws and regulations in each market in which
Hitachi operates. Where conflicts between internationally recognizedhuman rights and national laws exist, and the national laws are lessprotective of human rights, we will follow processes that seek ways tohonor international human rights principles. For example, we respect
the individual rights of children, linguistic or religious minorities,
indigenous people, migrant workers and their families, persons withdisabilities and women.

30Protect What Is Ours

Demonstrate Accountability

Human rights particularly relevantto the workplace are:
• Abolition of slavery and all forms of forced or compulsory labor;• Freedom of association;• Equal pay for equal work;• Equality at work;• Just and favorable remuneration;• Non-discrimination; and• Organize and participate in collective bargaining.

Deal Fairly With Others

Care For Our Communities

In Your Daily Work
Respect human rights and freedoms. Read the HitachiGroup Human Rights Policy and avoid infringing the rights ofothers. Abide by international standards and avoid causing orcontributing to adverse human rights effects.
Comply with Hitachi’s commitment to human rights. Do
not permit child, forced, prison or trafficked labor. If you recruit orhire employees, adhere to national laws and regulations.
Speak Up. Report a suspected human rights violation to yourmanager or another speak-up channel. Hitachi will promptly
investigate concerns and pursue action to mitigate any adverse
human rights issues.

Respect Human Rights

Be Aware31

Be Aware

Protect What Is Ours

Appreciate Diversity, Equity
and Inclusion
Hitachi believes diversity and inclusion are
crucial to building innovation, growth and along-term sustainable business.

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Our commitment
We promote diversity, equity and inclusion, equal employment opportunities,
and fair treatment in the workplace. Diversity and inclusion support thediverse needs of society and our customers, and everyone benefits fromthe richness of different perspectives and points of view.

Diversity, Equity and Inclusion are the source of our innovation and growth.
Hitachi has a place for everyone, welcoming differences in colleagues’
background, age, gender, sexuality, family status, disability, race, nationality,
ethnicity and religion.
We respect and value these and other differences because only throughdifference can we understand our markets, create better ideas and drive
innovation which contributes to society.
At Hitachi we treat everyone fairly, recognizing difference to allow everyone
to contribute.
With a diverse workforce, broad experience, and an inclusive culture we willmeet our customers’ needs and drive our company’s sustainable growth.

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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

In Your Daily Work

Focus on fairness. Practice equal opportunity in every action and embrace
the diversity of all Hitachi employees. Do not discriminate against any
employee or applicant.
Promote trust and respect. Promote and encourage an inclusive work
environment, free of harassment. Create an atmosphere where everyone can
express opinions, encourage people to speak up and listen carefully.
Promote equal employment opportunities. Discrimination is neveraccepted at Hitachi and might be illegal in some locations. Do notdiscriminate against applicants, employees or business partners based on
characteristics such as:• Age• Citizenship status• Color• Gender• Gender identity or expression• Genetic information (or those of a family member)• Marital status• Medical condition or disability• Military or veteran status• Pregnancy status• Race, national origin or ancestry• Religion or religious creed• Sex• Sexual orientation• Any other characteristic protected by applicable laws
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Code of Ethics and Business Conduct

Appreciate Diversity, Equity and Inclusion

Embrace our diversity. Treat each other with respect and dignity.
Understand the culture and viewpoints of others, so Hitachi benefits fromthe creativity and innovation that results from employees with different
experiences, perspectives and cultures working together.

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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Provide a Workplace That
Is Free From Harassment
Hitachi believes that everyone deserves respect anda workplace free from harassment.

Harassment
Unwanted, unwelcome, and uninvited behavior that demeans, offends orthreatens an individual and results in a hostile environment.
Examples include bullying, intimidation, physical aggression or stalking.

Our commitment
We do not tolerate harassment by anyone at Hitachi and work toensure that everyone feels comfortable and respected at work. It iseveryone’s responsibility to prevent any type of harassment.

In Your Daily Work
Speak up. Sometimes harassment can involve persistent
mistreatment that threatens someone’s physical or emotional
wellbeing. If you see or experience bullying or intimidating behavior,
do not let it continue – you have a responsibility to speak up.
Recognize signs of harassment. When behavior interfereswith someone’s work or creates a hostile environment, it may beharassment. It can take various forms and be physical, sexual, verbal
or visual.

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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Promote Health and Safety
Hitachi works to create a healthy, safe andsecure work environment.

Our commitment
Health and Safety Policies:• Continually be involved in health and safety activities to prevent
		 work-related injuries and sickness by designating employees’		 health and safety as management’s top priority.
• Comply with each company’s local laws and regulations regarding

We work together to ensure our safety by adopting practices to prevent
work-related accidents and promote employees’ and families’ mental
and physical health. In addition, we will work to secure employee
safety and business continuity following natural disasters such as
earthquakes, tsunamis and floods or cyberattacks and terrorism.

		 health and safety.
• Develop a safe and comfortable work environment by encouraging
		 employees to maintain their health and taking a proactive stance on		 health and safety activities in the workplace.
• Require an understanding of Hitachi’s principle and the promotion
		 of health and safety awareness from all business partners of the		 Hitachi Group.
• Contribute to the creation of a safe and pleasant society by		 emphasizing activities that make health and safety a top priority in		 all of Hitachi’s business activities.

In Your Daily Work
Prevent safety risks. Comply with health and safety
policies to ensure safe and healthy workplaces in supportof our Health and Safety Always Comes First philosophy.
Be proactive to protect your health and safety and thesafety of those around you. Use appropriate personal protective
equipment to help prevent injuries and illnesses. Report incidents,
injuries and near misses to your manager right away.
Maintain a safe workplace. Identify and address risks and findways to improve our health and safety practices. Immediately
report violence or threats of violence by, or against, any employee,
procurement partner or visitor to your manager.

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Be Aware

Protect What Is Ours

Demonstrate Accountability

Deal Fairly With Others

Care For Our Communities

Invest in Our Communities
Hitachi encourages employees to take an active role inmaking a difference in their community or globally in their
daily work or through social contribution activities.

Our commitment
We work to improve where we live and work through innovation andsocial development, contributing to the United Nations’ Sustainable
Development Goals. We also invest in developing, empoweringand nurturing future generations, together with our employees
and stakeholders, in the areas of STEAM (science, technology,
engineering, arts and mathematics), the environment and community
engagement.

In Your Daily Work
Contribute responsibly. Hitachi encourages you to make personal
contributions to causes and organizations you support. Follow ourpolicies and regulations when making contributions. Do not pressureother employees, business partners or customers to contribute to or
join your preferred nonprofits (charities), groups or political activities.
Respect differing political views. If you engage in civic activities
or share political beliefs, do not use Hitachi’s time to do so. Make
it clear that your perspective is your own. Review the Conflicts ofInterest protocol and disclose the conflict, if applicable. Speak to yourmanager if you plan to seek or accept a public office or other politicalactivities or have questions.

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Use the Code to Make
Good Decisions and Ethical Choices
As the world around us continues to change – at a faster rate today than when we started – we reaffirm ourcommitment to the Hitachi Identity and Basics and Ethics. We remind ourselves daily that our work is not just about
what we achieve but how we achieve it. How we conduct our business is as important as the products we sell andthe services we provide. That means complying with the laws of the communities where we do business.
In addition, customer and investor attention to Environmental, Social and Governance (ESG) matters in organizationsis at an all-time high. Upcoming regulations from regulatory bodies around ESG disclosures will formalize the need forcompanies to define, track and report on their ESG progress with regulatory consequences for misleading or falsified
information.
You are a Hitachi Ethics and Compliance team member, so I ask you to employ fairness and integrity at the heart ofeverything you do. By working this way, each of us will play an active part in shaping our culture, building trust, andhelping us deliver on our Mission.

David Karas,
Chief Compliance Officer,
Hitachi, Ltd.

Our Code (pages 5 through 36) reflects what is important to Hitachi and you. The Code applies to all members of the
Hitachi community – directors, employees, business partners, and procurement partners who do business with us.
We expect everyone to embrace our commitment to ethically doing business.
Let the Code guide you to make honest, fair decisions and comply with the laws and policies that apply to our
conduct. At its heart is a simple guideline: do what is right and speak up whenever you have a concern or see
something wrong.

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Code of Ethics and Business Conduct37

Speak-up Channels
Hitachi offers a variety of speak-up channels for more help and to report concerns.

If you have questions about The Code of Ethics and BusinessConduct and Hitachi Group Compliance policies and protocols.
Speak• Your manager• Next-level manager or another manager you trust• Human Resources, Compliance or Legal team member

Emailask-ethics@hitachi.com
Not to be used for reporting a concern

If you want to report potential misconduct or ethical concerns
Speak• Your manager• Next-level manager or another manager you trust• Human Resources, Compliance or Legal team member

Visithitachi.ethicspoint.com

Call

Call toll-free. Locate the number for your country on hitachi.ethicspoint.com
The Hitachi Global Compliance Hotline is available 24 hours a day, sevendays a week.
Translation services are available.

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Code of Ethics and Business Conduct

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CanadaSwitzerland

United Kingdom

ThailandJapan

BrazilUSA

For more information, contact:
Compliance Division, Hitachi, Ltd.
6-6, Marunouchi 1-chome, Chiyoda-ku, Tokyo
100-8280 Japanhitachi.com/ethics
ask-ethics@hitachi.com

Vietnam

India

China

Korea

Hitachi Group Code of Conduct
Hitachi Group Code of Ethics and Business Conduct (pages 5 through 36)
Revised/Renamed: December 2022 (Effective March 1, 2023)
Revised: February 2018
Released: August 2010
Hitachi Group Code of Ethics and ComplianceReplaced by Hitachi Group Code of Ethics and Business Conduct: March 1, 2023
Released: May 2020