Compliance Reporting System
With the aim of ensuring thorough statutory compliance and contributing to the conduct business activities with high ethical standards by the Company and its consolidated subsidiaries, Hitachi Construction Machinery Group has established the “Compliance Reporting System Management Regulation” (hereinafter referred to as “Reporting Regulation”).
The Reporting Regulations set forth a system for reporting illegal or inappropriate acts by officers and employees of Hitachi Construction Machinery Group, and mechanisms for appropriately responding to these reports.
The Reporting Regulations stipulate the following items, including items to strongly protect whistle blowers, pursuant to the Whistle-Blower Protection Amendment Act in June 2022 and we operate this system according to the provisions in the Reporting Regulation so that we can enhance the effectiveness of the reporting system and self- purification.
Maintenance of the Internal Reporting System
The Secretariat shall carry out the following duties.
(1) Work to maintain and spread the system throughout the Group, in accordance with the Regulations, and appropriately manage the system by engaging in a series of operations, from receiving reports and fielding inquiries to completing the responses to these.
(2) Periodically report to the Executive Committee, the Board of Directors and the Audit Committee on the status of execution of duties concerning the Regulations.
Information obtained from reports from persons using the system must not be shared outside of the minimum range necessary for investigation and correction, unless explicitly agreed in advance.
Staff involved in handling reports shall be obliged to maintain confidentiality, in accordance with Whistleblower Protection Act.
Duty of Cooperation
Officers and employees of the Company have a duty to cooperate in investigations when so requested.
Corrective Measures, etc.
If it is determined that corrective measure is necessary, the head of the department involved in the reported incident, or other related persons, shall promptly take corrective measure in accordance with the correction instructions.
Disciplinary Measures, etc.
If, as the result of investigations, a reported incident becomes clear, those officers or employees involved shall be subject to appropriate disciplinary or other action.
Protection of Compliance Reporting System Users
Staff using the system must not be subject to any disadvantageous treatment as a result of their having reported something, and any Company officers or employees who have carried out such unfavorable treatment are to be subject to disciplinary action, and any victims of such treatment offered appropriate restitution.
Prohibition of Searching
Company officers and employees must not engage in searches for the identities of officers and employees who have reported incidents, or which officers and employees have cooperated in the investigation of the reported incident.
Company officers and employees must not disclose information regarding the reported incident, unless there is a valid reason such as when stipulated by the Regulation or required by law, and must keep said information confidential. Neither may they use said information for any purpose other than the reported incident.
Avoidance of Conflicts of Interest
Officers and employees may not be involved in the investigation of reported incidents in which they are involved, or discussions on corrective measures relating to the reported incident.
The Secretariat must promptly notify the person reporting an incident that their report or inquiry has been received, and must also notify that person appropriately as to what subsequent action is going to be taken.
Protection of Whistleblowers in the Official Reporting Line
Company officers and employees shall not treat whistleblowers or persons who have sought advice in the official reporting line disadvantageously because of their having reported an incident.
Handling of Voluntary Reporting of Matters
Even if officers and employees of the Company involved in the reported incident voluntarily report to Compliance Reporting System or via the official reporting report line, or cooperate with the investigation, they will not be exempted from liability. However, depending on the situation of each case, reduction of or exemption from disciplinary action may be considered.
Evaluation of Reports
The Company shall favorably evaluate whistleblowers and those who have cooperated in investigations contributing to the discovery and correction of serious incidents.
Awareness and Training
The secretariat will report the operational results of the reporting system to the Compliance and Risk Management Committee, and to the officers and employees of the Company, taking care to protect personal information, etc., and ensure that officers and employees are regularly informed and trained on the whistleblowing system.
In addition, persons wishing to report can make use of two reporting routes, the direct reporting system established by the Company, or the route via an external contractor. Reporting can be done by e-mail, telephone, mail, interview, etc., whatever is most convenient for the whistleblowers. Via the external contractor route, reports can be handled in 200 languages and responded to globally.
Reporting results for FY2022 are as follows.
Number of cases: 54 cases
Harassment-related: 27 cases
Labor-related (other than harassment): 6 cases
Violation of company rules: 14 cases
Law violations: 1 cases
Others: 6 cases