Hitachi Group Procurement Partners

Hitachi Group
Sustainable Procurement Guidelines

October 2023

(6th Edition)

Hitachi, Ltd.
Value Integration Division1

1.

Hitachi Group Policies and Initiatives...................................... 4

1-1. Hitachi Group Policies ........................................................................... 4
1-2. Hitachi Group Procurement Initiatives .................................................. 82.

Hitachi Group Supplier Code of Conduct ................................ 9

A. Labor ......................................................................................................... 9
B. Health and Safety .................................................................................... 12
C. Environment ........................................................................................... 14
D. Business Ethics ...................................................................................... 16
E. Management System ............................................................................... 18
F. Product Quality and Safety ..................................................................... 20
G. Prevention of Personal and Confidential Information Leakage ............ 20

3.

Revision History ..................................................................... 222

These Guidelines were established based on Hitachi Group’s various policies (theHitachi Group Codes of Ethics and Business Conduct (revised in March 2023), etc.),
initiatives (including the results of human rights due diligence), widely recognized global
standards, and other references.(*)(*)References:-

United Nations Universal Declaration of Human Rights
https://www.un.org/en/about-us/universal-declaration-of-human-rights
United Nations Guiding Principles on Business and Human Rights
https://www2.ohchr.org/english/bodies/hrcouncil/docs/17session/A.HRC.17.31_en.pdf
OECD Guidelines for Multinational Enterprises
http://www.oecd.org/daf/inv/mne/48004323.pdf
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from
Conflict-Affected and High-Risk Areas
http://www.oecd.org/corporate/mne/mining.htm
ISO 9000（QUALITY MANAGEMENT）
https://www.iso.org/iso-9001-quality-management.html
ISO 14001（ENVIRONMENTAL MANAGEMENT）
https://www.iso.org/iso-14001-environmental-management.html
ISO 45001（Occupational health and safety）
https://www.iso.org/standard/63787.html
RBA（Responsible Business Alliance）Code of Conduct 7.0（2021）
https://www.responsiblebusiness.org/code-of-conduct/
JEITA（Japan Electronics and Information Technology Industries Association）
The Guideline (2020）*Currently Japanese only
https://www.jeita.or.jp/japanese/pickup/category/2020/200331.html

Definition:
procurement partner(s):Hitachi refers to its suppliers as “procurement partners”
who build business together on an equal footing.

3

1. Hitachi Group Policies and Initiatives
1-1. Hitachi Group Policies
A. Hitachi Group Corporate-wide Policies
A-1

Hitachi Group Identity

Our Mission is to "contribute to society through the development of superior, originaltechnology and products." In striving to accomplish this, we embrace the values ofHitachi Founding Spirit: Harmony, Sincerity and Pioneering Spirit. Our Vision was
created based on our Mission and Values to express what the Hitachi Group aims tobecome in the future. The Hitachi Group Identity is a simple concept designed to share
our Mission, Values, and Vision.

Hitachi Group Identity：Hitachi (hitachi.com)
A-2

Hitachi Group Code of Ethics and Business Conduct

The Hitachi Group Code of Ethics and Business Conduct consists of rules andprinciples to assist officers and employees make decisions and take actions consistent
with the Hitachi Group Identity.
Code of Conduct・Compliance : Hitachi Global
A-3 Hitachi Group Human Rights Policy
4

Hitachi formulated the Hitachi Group Human Rights Policy in 2013, and we view thispolicy as one of our highest internal standards. The Hitachi Group supports therealization of human rights by contributing to society through the development ofsuperior, original technology and products, and delivering innovations that answer
society’s challenges. As a prerequisite to this, Hitachi seeks to meet its responsibility torespect human rights.
Hitachi Global Human Rights Policy

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Hitachi Group Procurement Policies
B-1 Procurement policy
1. Partnership policy
At Hitachi we fully realize the value of developing trusting relationships with our valued
procurement partners.
2. Our open-door policy
Regardless of whether a procurement partner is a domestic or overseas company, we do
our utmost to insure free competition.
3. Fair business relationship policy
It is our policy to always maintain a fair business relationship with all of our procurement
partners.
4. Selection of procurement partners policy
We evaluate and select procurement partners based upon criteria such as quality, price,lead time, quality of management, technical standards and abilities.
B-2 Guidelines for Procurement Activities
These guidelines define business transaction standards which shall be applied to all
Hitachi executives and employees in connection with their activities purchasingnecessary materials, products, services, and information from outside sources.
1. Overall procurement activities of Hitachi shall adhere to the Hitachi Group Code of
Conduct.
2. HITACHI shall maintain proper partnerships, mutual understanding, and reliable
relationships with procurement partners with a view to the long term results.
(1) HITACHI shall treat all procurement partners impartially and be prohibited fromfavoritism such as giving unfair priority to any specific procurement partners.
(2) HITACHI respects fair business dealings with procurement partners and will avoid
any improper act which might cause a loss to a procurement partner apart fromnormal and customary business transactions(3) HITACHI shall keep procurement partners ‘trade secrets strictly confidential andprevent them from being revealed or improperly used.
3. HITACHI develops procurement partners to maintain competitiveness from aworldwide point of view.
(1) HITACHI responds to all procurement partners’ offers sincerely, and is always willingto offer the information necessary for procurement partners to complete on an evenplaying field.
(2) HITACHI shall periodically check and review procurement partners’ performance andwill consider offering more advantageous business opportunities when comparison
with other resources allows.
4. Through a designated selection process, procurement partners shall be evaluated byproduct quality, reliability, delivery, price, procurement partners’ business stability,
technical development ability, fair and transparent information release, compliance6

with societies’ rules, regulation compliance, respect for human rights, elimination of
discrimination in respect of employment and occupation, elimination of all forms offorced and compulsory labor, environmental preservation activities, social
contributions, good working environment, and recognition of social responsibilities
with business partners.
(1) HITACHI shall not request quotations from procurement partners with whom there isno intention to enter into a future business relationship.
(2) In accordance with specified internal procedures, the role and responsibility forspecifications, terms and conditions, product acceptance and inspection belongs toeach Requester, Procurement Department and Inspection Department.
(3) Procurement Departments shall be a representative of HITACHI when contractingwith procurement partners.
5. HITACHI members are prohibited from receiving any personal gifts or offers fromprocurement partners.
B-3 Hitachi Group's policy for Responsible Supply Chain of Minerals
The Hitachi Group is committed to responsible procurement activities as its policy toensure that the procurement of materials containing conflict minerals (tin, tantalum,
tungsten, and gold) and cobalt does not encourage the activities of armed groups,
human rights violations including child labor, corruption, and environmental destruction in
the conflict and high-risk regions.
The Group also respects the OECD Due Diligence Guidance for Responsible Supply
Chains of Minerals from Conflict-Affected and High-Risk Areas and conducts moredetailed investigations based on the Guidance while understanding social issues and the
expected roles of companies in the regions.
For its procurement partners, the Group will continue to inquire into their minerals’country of origin and supply chains using the Conflict Minerals Reporting Template(CMRT) issued by the Responsible Minerals Initiative (RMI), and request its procurement
partners to procure minerals from smelters certified under RMI’s Responsible Minerals
Assurance Program (RMAP).

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1-2. Hitachi Group Procurement Initiatives
Hitachi attaches great importance to sustainability in its value chains. Hitachi Group’s
procurement division began working on corporate social responsibility (CSR) in supply
chain management in the early 2000s and has accelerated and advanced this initiat ive
since February 2009, when the Hitachi Group announced its participation in the United
Nations Global Compact.(*) In dealings with its procurement partners, the Group commits
itself thoroughly to procurement activities based on its policies and codes of conduct
introduced in “1-1. Hitachi Group Policies.” In addition, the Group has distributed theSupply Chain CSR Procurement Guidelines to roughly 30,000 procurement partners todisseminate its Sustainable procurement policies, and asked them to conduct CSR
monitoring (completing a check sheet for the Hitachi Group Supply Chain CSR
Procurement Guidelines) and auditing with the aim of minimizing procurement risks. The
Group has formulated the Hitachi Group's policy for Responsible Supply Chain of
Minerals to address the issue of materials containing conflict minerals, and is promoting
responsible procurement activities based on international guidelines.
Hitachi is advancing its initiatives with a strong belief that developing business activities
with a focus on sustainability will lead to mutual prosperity for the Hitachi Group and its
procurement partners. Hitachi deeply appreciates its procurement partners carefully
reading and following these Guidelines with the above purposes in mind.
For the latest information and other details concerning Hitachi Group’s sustainability,
please visit the following website.
Hitachi Group Sustainability (hitachi.com)(*)The United Nations Global Compact, or UNGC, was proposed by then UN
Secretary-General Kofi Annan at the World Economic Forum (Davos Forum) in1999 and officially launched at the UN Headquarters in New York on July 26,
2000. As of May 2021, the UNGC has been signed by more than 17,000
organizations (including roughly 5,700 businesses) that are undertaking
activities based on ten principles in the four areas of human rights, labor, theenvironment, and anti-corruption.

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2. Hitachi Group Procurement partner Code of Conduct
A. LaborYour company must uphold the human rights of workers and treat them with dignity andrespect as understood by the international community. This applies to all types ofworkers, including temporary staff, migrant workers, students, and direct employees.
(1) Recruitment and Employment of Workers
Your company must not use forced, bonded (including debt bondage) or indentured
labor, involuntary or exploitative prison labor, slavery, or human trafficking. This includes
transporting, harboring, recruiting, transferring, or receiving persons by means o f threat,
force, coercion, abduction, or fraud for labor or services. Unreasonable restrictions mustnot be imposed on workers entering and exiting company-provided facilities (including, if
applicable, worker dormitories and living quarters) and workers’ freedom of movement in
the facilities. As part of the hiring process, your company must provide all workers with awritten employment agreement that includes employment terms and conditions stated intheir native language or a language properly understood by them. Foreign migrant
workers must receive the employment agreement prior to departure from their homecountry, and no substitution or changes are permitted in the employment agreement
upon arrival in the destination country unless these changes are made to meet local laws
and provide equal or better terms. All work must be voluntary, and workers are free toleave work at any time or terminate their employment without penalty or punishment if
reasonable notice is given as per their contract.
Your company must not retain or otherwise destroy, conceal, or confiscate workers’
identification certificates or immigration documents (government-issued identification,
passport, work visa, personal ID card, etc.). Employers are allowed to retain these
documents only if such retention is required by law, but even in this case, workers areallowed access to their documents at all times.
Your company must not make workers bear recruitment fees or other expenses related totheir employment charged by employers’ agents or sub-agents. Any such costs found tohave been paid by workers will be refunded to the workers.
(2) Employment of Young Workers
Your company must not use child labor at any stage of manufacturing. The term “child”
refers to any person under the age of 15, under the age for completing compulsory
education, or under the minimum age for employment in each country, whichever ishighest. Your company must have an appropriate mechanism to verify the age of its
workers. Legitimate workplace learning programs are approved as long as they comply
with all laws and regulations. Workers under the age of 18 (young workers) are not to9engage in work, including night shifts and overtime, that may jeopardize their health orsafety.
Your company must ensure appropriate management of student workers by properly
maintaining their employment records, conducting rigorous due diligence of educational
partners, and protecting student workers’ rights in accordance with applicable laws andregulations. Your company must also provide all student workers with appropriate
support and training for their tasks. As for student workers’ wages, in the absence of
local laws, the wage rates for student workers, interns, and apprentices will be at least
the same as those for other entry-level workers performing equal or similar tasks.
(3) Working Hours
Studies on business practices have revealed that overwork is clearly linked to lower
productivity, higher turnover, and a greater risk of injury and illness. Your company must
therefore ensure that working hours do not exceed the limit set by local laws. Further, thetotal weekly working hours, including overtime, must not exceed 60 hours or the legal
working hour limit, except in the case of emergencies or unusual circumstances. All
overtime work must be voluntary. Efforts must also be made to prevent workers frombeing overworked, and workers will be granted appropriate days off (at least one holiday
that complies with local laws or 24 consecutive hours of rest in any seven -day period,
whichever is longer).
(4) Wages and Benefits
Compensation paid to workers must comply with all applicable wage laws, including
those relating to minimum wages, overtime work, and legally mandated benefits. In
compliance with local laws, workers must be paid for overtime work at a rate higher thantheir regular hourly rate. Workers must be timely provided with easy-to-understand pay
slips that include sufficient information to verify accurate compensation for the work
performed during each payment period. All temporary, dispatch, and outsourced workers
are to be used within the limits of local laws.
(5) Humane Treatment of Workers
No workers will be subjected to harsh or inhumane treatment that includes violence,
gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental
or physical coercion, bullying, public shaming, or verbal abuse; nor will there be thethreat of any such treatment. Your company must clearly define and communicate toworkers its disciplinary policies and procedures in support of these requirements.

10(6) Non-Discrimination/Non-Harassment
Your company must be committed to a workplace free of harassment and unlawful
discrimination, and not engage in discrimination or harassment based on race, color,age, gender, sexual orientation, gender identity and expression, ethnicity or national
origin, disability, pregnancy, religion, political affiliation, union membership, veteranstatus, protected genetic information, or marital status in recruitment and employment
practices such as wages, promotions, rewards, and access to training opportunities.
Workers must be provided with reasonable accommodation for religious practices. In
addition, workers or potential workers must not be subjected to medical tests, including
pregnancy and virginity tests, or physical exams that could be used in a discriminato ry
way.
(7) Freedom of Association
Your company must respect the right of all workers to form and join trade unions of theirown choosing, bargain collectively, and participate in peaceful assembly as well as theright to refrain from such activities in accordance with local laws. Workers a nd/or theirrepresentatives must be able to openly communicate and share their ideas and concernswith management regarding working conditions and management practices without fearof discrimination, reprisal, intimidation, or harassment.

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B. Health and Safety
Your company must recognize that a safe and healthy work environment enhances thequality of products and services, product consistency, and workforce stability and morale,
in addition to minimizing the occurrence of work-related injuries and illnesses. Your
company must also recognize that continuously providing information and education toworkers is essential to identify and resolve health and safety issues in the workplace.
Widely recognized management systems, such as ISO 45001 and the ILO Guideline on
Occupational Safety and Health Management Systems, may provide useful information toformulate corporate codes.
(1) Occupational Safety
Your company must identify and assess its workers’ exposure to potential health andsafety hazards (chemical, electrical and other energy sources, fire, vehicles, and falls),
and mitigate the hazards using the Hierarchy of Controls. This approach includes
eliminating hazards, substituting processes and materials, controlling through proper
design, implementing engineering and administrative controls, preventive maintenance,and safety work procedures (including lockout/tagout), and providing ongoing
occupational health and safety training. When hazards cannot be controlled properly bythese means, workers must be given appropriate, well-maintained personal protective
equipment, and education on the risks related to these hazards must be provided
effectively in a language properly understood by workers. Appropriate measures mustalso be taken for pregnant women and nursing mothers, such as work reassignment toavoid serious hazards, eliminating or reducing occupational health and safety risks
involving their work assignment, and providing reasonable accommodation for nursing
mothers.
(2) Emergency Preparedness
Your company must identify and assess potential emergency situations and events,and minimize the impact by implementing emergency plans and response procedures,
including emergency reports, notification to employees, evacuation procedures, andtraining and drills for workers. Emergency drills must be conducted at least once a year
or as required by local laws, whichever is more stringent. Emergency measures include
appropriate fire alarm and suppression systems, visible and unobstructed exit routes,
facilities with appropriate emergency exits, contact information for emergency
responders, and recovery plans. These measures and procedures must focus on
minimizing harm to life, the environment, and property.
(3) Occupational injury and illness
Your company must have procedures and systems in place to prevent, control, track,and report occupational injuries and illnesses. These procedures and systems must
include provisions to encourage reporting from workers, classify and record injury andillness cases, provide the necessary medical treatment, investigate the cases in detail,implement corrective measures to eliminate the causes, and facilitate the workers’ return
to work.

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(4) Industrial HygieneYour company must identify, assess, and control workers’ exposure to chemical,
biological, and physical agents based on the Hierarchy of Controls. If potential hazards
are identified, your company must seek opportunities to eliminate or reduce the hazards.
If elimination or reduction is not feasible, the hazards must be controlled through proper
design, and engineering and administrative controls. When hazards cannot be controlled
properly by these means, workers must be provided with and use appropriate, w ellmaintained personal protective equipment free of charge. Protection programs must be
implemented continuously and include education on the risks associated with thesehazards.
(5) Accommodation for Physically Demanding WorkYour company must identify, assess, and control the risk of injury for workers engaged
in such work as manual material handling, physically demanding tasks, repetitive heavy
lifting, prolonged standing, and forceful assembly tasks in order to prevent probl ems fromoccurring.
(6) Machinery Safeguarding Measures
Your company must assess safety hazards of production and other machinery.
Physical guards, interlocks, and barriers must be installed and properly managed andmaintained where machinery poses an injury risk to workers.
(7) Sanitation, Food, and HousingYour company must provide workers with ready access to clean toilet facilities, potablewater, and sanitary food preparation, storage, and eating facilities. Worker dormitories
provided by your company must be maintained in a clean and safe condition, and beequipped with appropriate emergency exits, hot water for bathing and showering, proper
lighting, heating, ventilation, individually secured accommodations for storing personaland valuable items, and reasonable personal space with easy access.
(8) Health and Safety Communication
Your company must provide appropriate workplace health and safety information andtraining on all identified workplace hazards (including, but not limited to, mechanical,
electrical, chemical, fire, and physical hazards) to workers in their native language or alanguage properly understood by them. Health and safety-related information must be
clearly posted in facilities or placed in locations identifiable and accessible to workers.
Training will be provided to all workers prior to the beginning of work an d regularly
thereafter. Workers will be encouraged to raise health and safety concerns without
retaliation.

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C. Environment
Your company must recognize that environmental responsibility is integral to the
manufacture of world-class products, and identify the environmental impact ofmanufacturing activities and minimize the adverse effects on the community, theenvironment, and natural resources while safeguarding public health and safety. For
Hitachi Group’s green procurement approaches, please refer to the Hitachi Group Green
Procurement Guidelines.
(1) Environmental Permits and ReportingYour company must obtain, maintain, and update all required environmental permits (e.g.
discharge monitoring), approvals, and registrations, and comply with their operationaland reporting requirements.
(2) Pollution Prevention and Resource Reduction
Your company must minimize or eliminate pollutant emissions and waste generation at
the source by installing additional pollution control equipment, modifying production,
maintenance, and facility processes, or implementing other means. The use of natural
resources, including water, fossil fuels, minerals, and virgin forest products, must be
controlled through modifications of production, maintenance, and facility processes,
materials substitution, reuse, conservation, and recycling, or other means.
(3) Environmentally Hazardous Materials
Chemicals, waste, and other materials posing a hazard to humans or the environment
must be identified, labeled, and managed to ensure their safe handling, movement,
storage, use, recycling or reuse, and disposal.
(4) Solid Waste
Your company must implement a systematic approach to identifying, managing,
reducing, and responsibly disposing of or recycling solid waste (non-hazardous).
(5) Air Emissions
Your company must characterize, routinely monitor, and control air emissions of volatileorganic chemicals (VOCs), aerosols, corrosives, particulates, ozone depleting
substances, and combustion byproducts generated from operations, and treat thesesubstances as required prior to discharge. Ozone depleting substances are to beeffectively managed in accordance with the Montreal Protocol and applicable regulations.
Your company must routinely monitor its handling of substances emitted into the air andthe performance of its air emission treatment systems.
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(6) Materials Restrictions
Your company must comply with all applicable laws, regulations, and customer
requirements regarding the prohibition or restriction of specific substances in products
and during manufacturing, including labeling for recycling and disposal.
(7) Water Management
Your company must implement a water management program that documents,characterizes, and monitors water sources, use, and discharge, while seeking
opportunities to conserve water and controlling contamination routes. All wastewatermust be characterized, monitored, controlled, and treated as required prior to discharge
or disposal. Your company must routinely monitor its wastewater treatment systems andwater tanks to ensure optimal performance and regulatory compliance.
(8) Energy Consumption and Greenhouse Gas Emissions
Your company must establish a corporate-wide greenhouse gas reduction goal. Energy
consumption and all relevant Scope 1 and 2 greenhouse gas emissions must be tracked
and documented, and their comparisons with the reduction goal publicly reported. Your
company must seek ways to improve energy efficiency and minimize its energy
consumption and greenhouse gas emissions.
(9) Conservation of Biodiversity and Ecosystems
To conserve biodiversity and ecosystems that serve as the foundation for the survival ofboth humanity and business, your company must procure raw materials and productswith an awareness of their impact while keeping the following items in mind.
--

Preferential procurement of paper and office supplies confirmed to be producedwith consideration given to biodiversity and ecosystems
Ecologically friendly approaches to mining raw materials and developing,producing, and procuring raw materials, components, and products
Consideration for the local ecosystem, such as protecting rare species in theregion before land acquisition or rebuilding and avoiding habitat fragmentation
Promotion of nature conservation activities, including growing forests with native
species and planting trees to conserve ecosystems
Pollution prevention from the perspective of ecosystem conservation, 3R (reduce,reuse, and recycle) activities, and continuous improvements of energy
conservation activities
Request for procurement partners to promote ecosystem conservation

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D. Business Ethics
Your company must uphold the following highest standards of business ethics to meetits social responsibilities and to achieve success in the marketplace.
(1) Continuing Commitment to Business IntegrityYour company must maintain the highest level of integrity to continue its business, anduphold a zero-tolerance policy that prohibits all forms of bribery, corruption, extortion,and embezzlement. All business transactions must be conducted with transparen cy andaccurately reflected in your company’s accounting books. Monitoring and proceduresmust be implemented to ensure compliance with anti-corruption and related laws.
(2) Elimination of Improper Advantages
Your company must not promise, offer, authorize, give, or accept bribes or othermeans of obtaining undue or improper advantages. This prohibition covers promising,offering, authorizing, giving, or accepting anything of value, either directly or indirectl y,through a third party in order to acquire or retain business, assign business to someone
else, or otherwise gain improper advantages. Monitoring, record keeping, andprocedures must be implemented to ensure compliance with anti-bribery and anticorruption laws.
(3) Disclosure of Information
All business transactions must be conducted with transparency and accuratelyreflected in your company’s accounting books and records. Your company must disclose
information regarding its labor, health and safety, environmental conservation efforts,business activities and structures, financial status, and performance in accordance withapplicable regulations and prevailing industry practices. Falsification or
misrepresentation of events occurring in your company’s supply chains or implemented
measures is unacceptable.
(4) Intellectual PropertyYour company must respect and protect intellectual property rights. Transfer oftechnology and knowhow must be conducted in a way that does not infringe on
intellectual property rights, and information of customers and procurement partners mustalso be safeguarded.
(5) Compliance with Fair Business, Advertising, and Competition Laws
Your company must conduct its business activities in accordance with fair competition
rules, and its activities must comply with all applicable competition laws, such as
accuracy and integrity in advertising. Appropriate measures must also be taken to prot ect
customer information.

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(6) Protection of Whistleblowers and Elimination of Retaliation
Your company must maintain a program to ensure the protection of procurement
partner and employee whistleblowers, unless prohibited by law, and disseminate andsupport a process to enable its personnel to raise concerns without fear of retaliation. A
system that allows allegations of wrongdoing to be reported must be guaranteed.
(7) Responsible Minerals Procurement
To reasonably assure the procurement of minerals is consistent with the Organization
for Economic Co-operation and Development (OECD) Due Diligence Guidance for
Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas orequivalent due diligence frameworks. Your company must adopt policies and conduct
due diligence on the sources and chains of custody for minerals such as tin, tantalum,
tungsten, and gold contained within its manufactured products. Please refer to the
Hitachi Group's policy for Responsible Supply Chain of Minerals to better understand our
procurement approaches.

17E. Management System
Your company must adopt or establish a management system with a scope related tothe contents of this Code. The management system must be designed to ensure thefollowing:a. Compliance with applicable laws, regulations, and customer requirements
related to your company’s operations and products;
b. Conformance with these Guidelines; andc. Identification and mitigation of operational risks related to these Guidelines.
The management system must also facilitate continual improvements.
The management system must contain the following elements:(1) Company Commitment
Your company must provide corporate social and environmental responsibility policy
statements affirming its commitment to compliance and continual improvements that areendorsed by the executive management and posted in its facilities in the local language .
(2) Management Accountability and ResponsibilityYour company must clearly identify the senior executive and company
representative(s) responsible for ensuring the implementation of its management system
and associated programs. Senior management must review the status of the
management system on a regular basis.
(3) Response to Legal and Customer Requirements
Your company must establish a process to identify, monitor, and understand theapplicable laws, regulations, and customer requirements, including the items listed inthese Guidelines.
(4) Risk Assessment and Management
Your company must establish a process to identify legal compliance, environmental,
health and safety risks(*) as well as labor practices and ethical risks associated with its
operations. To manage identified risks and ensure regulatory compliance, your com pany
must determine the relative significance of each risk and implement appropriate
procedural and physical controls.
(*)Areas to be included in a risk assessment of the environment, health, and safety are
production bases, warehouse/storage facilities, plant/facility support equipment,laboratories and test areas, sanitation facilities (toilets), kitchens/cafeterias, and worker
housing/dormitories.

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(5) Setting of Improvement Objectives
Your company must present written performance goals, targets, and implementationplans to improve its social, environmental, and health and safety performance, including
a periodic assessment of your company’s performance in achieving these objectives.
(6) Development of Training ProgramsYour company must establish training programs for managers and workers to
implement its policies, procedures, and improvement objectives and to meet theapplicable legal and regulatory requirements.
(7) Communication with Workers, Procurement partners, and Customers
Your company must establish a process to communicate clear and accurate
information about its policies, practices, expectations, and performance to workers,
procurement partners, and customers.
(8) Worker Feedback, Participation, and GrievanceYour company must establish ongoing processes, including an effective grievancemechanism, to assess workers’ understanding of the practices and conditions covered bythese Guidelines and promote continuous improvements after obtaining feedback andidentifying violations. A safe environment must be provided for workers to voice
grievances and offer feedback without fear of reprisal or retaliation.
(9) Audits and Assessments
Your company must implement periodic self-evaluations to ensure conformity withlegal and regulatory requirements, these Guidelines, and customer contract requirements
related to social and environmental responsibility.
(10) Corrective Actions
Your company must establish a correction process to respond to the deficiencies
identified by internal or external assessments, inspections, investigations, and reviews.
(11) Documentation and Records
Your company must create and maintain documents and records to ensure regulatorycompliance, conformity with company requirements, and appropriate confidentiality toprotect privacy.
(12) Procurement partner ResponsibilityYour company must establish a process to communicate these Guidelines toprocurement partners and monitor their compliance.

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F. Product Quality and Safety(1) Product Safety
Your company must ensure sufficient product design safety and sell products with anawareness of its responsibility as a manufacturer. Product safety must be ensured incompliance with laws and regulations, with consideration also given to the safety thatshould be expected from products. Laws, regulations, and safety and other standards
related to product safety (Japan: Act on Product Safety of Electrical Appliances andMaterials, Consumer Product Safety Act, Household Goods Quality Labeling Act,detailed rules in various laws and regulations, Japanese Industrial Standards (JIS), etc.;
overseas: Underwriters Laboratories (UL), British Standards Institution (BSI), CanadianStandards Association (CSA), etc.) must be observed. Product safety must also include
traceability (procurement of parts and materials, manufacturing processes, etc.) andother management methods and prompt response to problem solving.
(2) Promotion of Quality Assurance Activities
Your company must formulate a quality assurance policy and accordingly proceed withquality assurance activities on a daily basis to make continuous improvements throughthe Plan-Do-Check-Act (PDCA) cycle. To this end, your company will establish andpromote a quality management system that develops an organizational structure, outlines
an activity plan, and specifies responsibility assignment and procedures. For major
quality management systems, please refer to ISO9000, ISO/TS16949, and ISO13485.
G. Prevention of Personal and Confidential Information Leakage(1) Protection against Threats to Computer Networks Including Cyberattacks
Your company must take measures to prevent threats to computer networks, including
cyberattacks, from affecting its internal and external operations. These threats include
viruses, worms, spyware, ransomware, social engineering, and targeted attacks.
Computers or servers infected with viruses and other malware may leak customer andconfidential information or attack other companies’ computer networks, causing serious
harm due to the stagnation of daily operations and the loss of trust. In addition, carefulattention must be paid to targeted attacks and other types of threats by hackers who may
break into computer networks and leak or destroy a variety of information, resulting insimilar damage.
(2) Privacy Protection
Your company must be committed to effectively protecting personal information andprivacy of all people involved in its business, including procurement partners, customers,
consumers, and workers. Personal information must be collected, stored, processed,20

transmitted, and shared in accordance with laws and regulations related to privacy andinformation security.
(3) Measures to Prevent Personal Information Leakage
Your company must ensure that personal information(*) is not obtained, used, disclosed,or leaked illegally and unfairly by formulating codes and policies to be complied with byworkers, while thoroughly managing the information through the PDCA cycle.
(*)Personal information refers to information about a living individual that can be used to
distinguish that specific individual’s identity, such as name, date of birth, and otherdescriptions (including anything that easily matches other information to identify a
specific individual).
(4) Measures to Prevent Leakage of Customer and Third-party Confidential
Information
Your company must ensure that all confidential information(*) of customers and third
parties is not obtained, used, disclosed, or leaked illegally and unfairly by thoroughlymanaging the information through the PDCA cycle.
(*)Confidential information refers to information disclosed in a written form (including
electromagnetically or optically recorded data information) that is designated asconfidential in an agreement or information orally disclosed after confidentiality is
notified.

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3. Revision History
Edition
1
2

Date
January,2009
June, 20093

January,
2017４

July, 2021

5
6March, 2023
October,
2023

Details
Created 1st edition of the Hitachi Supply Chain CSR
Promotion Guidebook.
In the "Introduction", added/inserted text declaring
participation in The United Nations Global Compact.
(1) Changed the title to "Hitachi CSR Procurement
Guideline".
(2) In the "Introduction", added/inserted text related to SDGs
and COP21.
(3) Deleted the "Hitachi Group CSR Activities Policy" andreplaced it with the "Framework of CSR Management".
(4) Inserted the "Hitachi Group Human Rights Policy".
(5) Inserted the "Hitachi Group Conflict Minerals Procurement
Policy".
(6) From page 13 on onwards, inserted the "CSR
Procurement Guideline" while referring to contents of the"Hitachi Group Code of Conduct", as based on the "EICC
Code of Conduct Version 5.1".
(1) Changed the title to "Hitachi Group Sustainable
Procurement Guidelines".
(2) Established based on Hitachi Group’s various policies(the Hitachi Group Codes of Conduct (revised in February2018), etc.), initiatives (including the results of human rights
due diligence), widely recognized global standards, and otherreferences.
Replaced “supplier” to “procurement partner”.
(1) Changed based on Hitachi Group Codes of Ethics andBusiness Conduct (revised in March 2023), etc.).
(2) Changed the content of “Hitachi Group Human Rights
Policy”.

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