Hitachi’s
Expectations ofBusiness Partners
March 2024

Created by Compliance Division, Hitachi, Ltd.

© Hitachi, Ltd. 2024. All rights reserved.

TABLE OF CONTENTS

010203Introduction

Business Ethics & Compliance

Health, Safety and Environment

040506

Human Rights

Confidential Business Information
and Personal Data

Speak up and Report a Concern

Introduction
Hitachi is committed to doing business ethically and legally and seeks to work withbusiness partners who operate to the highest standards of integrity and quality.
Hitachi expects business partners to adhere to behaviors consistent with the HitachiGroup Code of Ethics and Business Conduct and applicable laws and regulations.
Hitachi also expects business partners to understand the importance of aligning withHitachi’s Mission, Values and Vision and to conduct business in a manner that does notcause adverse effects on people and our planet.

As a Hitachi business partner, Hitachi expects you to commit to and act in accordancewith the Hitachi Group Code of Ethics and Business Conduct and communicate these
expectations to your employees, contractors, and business partners when working with oron behalf of Hitachi.

2Business Ethics& Compliance

Hitachi is committed to complying with applicable laws and regulations and upholding the highest
standards of business ethics and conduct. As a Hitachi business partner, you are expected to promotetransparency and accountability in your business activities, including the implementation of effective
processes and procedures to:Prevent Bribery and Corruption and comply with applicableanti-bribery and anti-corruption laws and regulations. Refrainfrom offering or accepting anything of value to keepbusiness, secure business, or gain an unfair advantage.
Refrain from making facilitation payments on behalf of Hitachi
unless there is an immediate threat to life, safety, security, orfreedom. If you make a payment under these circumstances,notify Hitachi immediately.

Compete Fairly and comply with antitrust and competition laws in
all countries in which you do business with, or on behalf of, Hitachi.
Refrain from entering into an agreement with a competitor to divide
markets or customers, fix prices, manipulate thecompetitive bidding process, or exchange or discuss Hitachi’s
confidential, sensitive information. Refrain from abusing orexploiting a dominant market position to secure unfair terms or tounfairly consolidate or strengthen market power.

Give and Receive Gifts and Entertainment responsibly.
Refrain from offering or receiving gifts and entertainment onHitachi‘s behalf that are contrary to local laws or could beperceived as unduly influencing a business decision. Do notprovide Hitachi with cash or cash-equivalent gifts.

Prevent Money Laundering and comply with anti-money
laundering and anti-terrorism laws and regulations. Avoid activities
associated with criminal acts, including money laundering orterrorist financing.

Conduct your business transactions with transparency
and accurately record and classify transactions in yourcompany’s accounting books and records. Do not keep
hidden financial accounts or unrecorded funds. Report
relevant information in accordance with applicable laws andregulations.

Identify and Manage Conflicts of Interest and avoid situations inwhich personal interests, outside activities, financial interests, orrelationships conflict or appear to conflict with the interests relating
to Hitachi activities. Do not allow business dealings with, or on
behalf of, Hitachi to be influenced by personal considerations orrelationships.

For Security Trade Control, comply with national andinternational trade compliance laws, export control
regulations, economic sanctions, and customs laws that
control international transactions of products and services.
Obtain the required export licenses before proceeding withany export and comply with the license terms or
any exemption requirements.

Conduct Due Diligence on your business partners and mitigate
risks discovered during due diligence before they begin working foror on behalf of Hitachi. Monitor their performance to ensure theymeet your and Hitachi’s expectations.

3Health, Safety and Environment
Hitachi works to create a healthy, safe, and secure work environment. As a Hitachi business
partner, you are expected to:Understand and follow Hitachi’s health andsafety requirements when working with or on behalfof Hitachi.

Comply with applicable laws and regulations regarding
health and safety.

Develop a safe, secure, and healthy workplace foreveryone involved in Hitachi business activities.

Continually be involved in health and safety activities
to prevent occupational injuries and sickness.

Hitachi will address environmental issues and achieve a higher quality of life and a sustainable
society through its Social Innovation Business. As a Hitachi business partner, you are expectedto:Understand and follow environmental laws andregulations that apply to Hitachi business activities.

Understand the direct and indirect effects of yourbusiness activities on the environment and minimize theadverse effects such as carbon dioxide emissions,pollution, or waste.

4

Human Rights
Hitachi conducts business in a way that supports and respects the human rights ofall those involved in Hitachi’s business activities and follows international
conventions on human rights and labor laws and national laws and regulations. Asa Hitachi business partner, you are expected to:Comply with Hitachi’s commitment to humanrights, uphold the human rights of workers, andtreat them with dignity and respect.

Respect human rights, abide by international
standards, and avoid causing or contributing tonegative human rights impacts.
Comply with applicable laws, rules, andlegal requirements for abolishing slavery andall forms of forced or compulsory labor.
Not permit child, forced, or trafficked labor.

.

Promote equal employment opportunities. Do
not discriminate against anyone involved in yourbusiness activities.
Respect employees’ freedom of associationand the right to collective bargaining.

5Confidential BusinessInformation and Personal Data
Hitachi is committed to handling confidential business information responsibly.
Hitachi takes precautions to protect Hitachi’s and business partners’ informationfrom unauthorized access and disclosure and follows applicable data protection
laws when handling employees’ personal data. As a Hitachi business partner, youare expected to:
Handle Hitachi’s confidential businessinformation with care, protecting it fromattacks, disclosure, or misuse.

Observe and adhere to all applicable data
privacy laws and regulations on thecollection, processing, and securing of
Hitachi employees’ personal data.

Protect non-public information of Hitachi
by adopting industry best practices.

Respect the intellectual property of
Hitachi and provide appropriate protections
before using Hitachi’s intellectual property.

6Speak up and Report a Concern
Hitachi encourages everyone who works for or represents Hitachi to speak
up whenever they have a concern or see something wrong. As a Hitachi
business partner, you are expected to:Create a speak-up environment in your organization that does not tolerate any form of
retaliation against individuals who raise concerns in good faith or participate ininvestigations.
Have effective channels available for your employees, contractors, and business
partners to raise concerns regarding violations, or potential misconduct, unethicalbehavior, or unsafe actions.
Have adequate processes in place to ensure that concerns are taken seriously,
evaluated and managed appropriately, and treated with the utmost confidentiality.
Contact Hitachi to report any violations or suspected unethical or potentially harmful
acts involving Hitachi’s business activities. You may inform a member of Hitachi’s
management or use the Hitachi Global Compliance Hotline, which is available 24/7 andallows anyone to remain anonymous, where permitted by law.
Share the contact details of the Hitachi Global Compliance Hotline with youremployees, contractors, and business partners who work for or on behalf of Hitachi. The
contact details are provided below.

To reach the Hitachi Global Compliance Hotline:
Visit hitachi.ethicspoint.com
Call toll-free. Locate the number for your country on hitachi.ethicspoint.com
7

Business Partners are external companies, entities, organisations orindividuals with whom Hitachi Rail has, or may consider having, abusiness transaction or relationship.
This Addendum imposes additional expectations andrequirements on business partners that supply to Hitachi Rail.

Hitachi Rail
Addendum© Hitachi Rail Limited. 2024. All rights reserved.

InternalManagementSystems

Hitachi Rail expects business partners to comply with laws and regulations
and demonstrate internal management systems that support this:Establish processes and governance toidentify, monitor, understand, and comply withapplicable laws, regulations, and customer
requirements.
Violations of laws or regulations may resultin termination of the business relationshipwith Hitachi Rail, as well as any other legal andcontractual remedial actions available toHitachi Rail.
Establish processes to identify legal,
regulatory, environmental, health and safety,
and ethical risks associated with your labour
practices and operations.
Implement periodic self-evaluations or
audits to ensure conformity with legal andregulatory requirements, and customer contract
requirements including those related toenvironmental, social and governance (ESG)
responsibility.

Create and maintain accurate and truthful
documents, books, and records to: prevent
fraud; ensure legal, financial, and regulatorycompliance; conformity with customer
requirements, and adopt appropriate
safeguards to protect privacy, and confidential
and commercially sensitive information.
Establish processes to communicate andflow-down expectations to your own
workforce and suppliers, and monitor
their compliance.
Provide evidence of your internalmanagement systems and self-evaluations
or audits when requested to do so byHitachi Rail.

Product Quality and Safety

Privacy & Personal Data

Ensure sufficient product design safety andsell products with an awareness of yourresponsibility as a manufacturer. Product safety
shall be ensured in compliance with applicablelaws and regulations.

Any personal data (whether relating toemployees of Hitachi Rail or otherwise) thatyour Company controls or processes, will becollected, stored, processed, transmitted, andshared in accordance with laws andregulations related to privacy and personal
data protection, and information security.

Embrace opportunities for continuous
improvements facilitated and promoted withinyour quality management systems.

Intellectual Property &Confidential BusinessInformation
Respect and protect intellectual property
rights and confidential businessinformation. Transfer and use of technology
and know-how must be conducted in a way that
does not infringe on intellectual property rights,
and information of customers and suppliersmust be safeguarded in accordance with laws
and regulations, and adequate information
security controls.

Whistleblowing
Maintain a programme to ensure theprotection of supplier and employee
whistleblowers, unless prohibited by law.

Environment

Establish greenhouse reduction goals, andsupport Hitachi Rail regarding sustainability
and carbon initiatives. Please be aware of ourHitachi Group Sustainable Procurement
Guidelines.

To conserve biodiversity and ecosystems thatserve as the foundation for the survival of bothhumanity and business, procure raw
materials and products with an awarenessof their impact.

Identify the environmental impact ofmanufacturing activities and minimize theadverse effects on the community, theenvironment, and natural resources whilesafeguarding public health and safety.
Please be aware of our Hitachi Group Green
Procurement Guidelines.

Adopt policies and conduct due diligenceon the sources and chains of custody forminerals, such as tin, tantalum, tungsten, andgold contained within its manufactured
products. Due diligence shall be undertaken toreasonably assure the procurement of minerals
is consistent with the Organization for
Economic Cooperation and Development(OECD) Due Diligence Guidance for
Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk areas orequivalent due diligence frameworks.