Export control policy
The Hitachi Construction Machinery Group shall stipulate compliance with related laws and ordinances when engaging in export and import in the Hitachi Construction Machinery Group Code of Conduct (2. Honest and fair business activities 2.1 Appropriate transactions) and aim to broadly contribute to the maintenance of international peace and safety through export control.
Export control system
Hitachi Construction Machinery has established export control rules and systems that comply with export control laws and regulations and has established an export control system under the chief export control officer appointed by the president from the representative executive officers. The organization designated by the Security Trade Control Department and the Export Control Committee Chair is responsible for the export control units, and management, supervision, and system construction shall be implemented for each export control item under its initiative. At the same time, we provide training and guidance to domestic and overseas group companies involved in exports.
Export control employee education
At Hitachi Construction Machinery, the Security Trade Control Department conducts education on export control for employees at the head office and factories, and educational items on export control are included in rank-based training for new employees and mid-career hires.
Also, the Security Trade Control Department and the Export Control Committee Secretariats of the group companies conduct equivalent employee education at domestic and overseas group companies.
In FY2021, we continued to conduct rank-based training and held basic export control courses and export control middle-level courses tailored to the level of proficiency for patients working at our factories in an effort to firmly establish basic knowledge of export control. In export control training for sales divisions, we also held an export control elementary course and held an education for export control practitioners. For domestic and overseas Group companies, we conducted export control regulation (basic version) education for U.S. export control regulations and worked to establish export control knowledge.
In addition, we held briefings on revisions to laws and regulations for export management practitioners and related divisions of Hitachi Construction Machinery and domestic and overseas Group companies.
In FY2022, we will continue to hold export control courses based on the export control level and rank of the employees taking course and continue to hold training as well. We will also enhance practical export control education for sales units and expand export control education by providing various educational and e-learning teaching materials to companies in cooperation with the company and domestic and overseas group company staff.
Conducting export control audits
At Hitachi Construction Machinery, the Security Trade Control Department conducts audits once a year as a rule for head office and factory departments. The Security Trade Control Department conducts audits of domestic and overseas group companies and attends business audits conducted by the Audit Section as necessary to inspect whether management is conducted in accordance with the provided export control rules.
Also, the Export Control Committee Secretariats of domestic and overseas group companies conduct self-audits at group companies, and the Security Trade Control Department that receives the report provides feedback on the results.
In FY2021, as in the previous fiscal year, due to the Corona crisis, we conducted a remote interview on the information of audited items, checked the current status and the status of improvement for the stakeholders. In addition, audits targeting departments working at the head office and factories are conducted to strengthen management functions by conducting risk assessments of each department and conducting audits based on the results of the assessments.
In FY2022, after confirming the risk assessment, we will continue internal unit audits based on the internal audit implementation standards. In addition, by systematically conducting audits of domestic and overseas group companies according to risk based on operational standards and risk assessments in cooperation with the Audit Section, we prevent accidents in export control and realize appropriate transactional control and supervision.