Following in the footsteps of Hitachi, Ltd., HCM revised its regulations related to the prevention of bribery in 2017 to address global risk. The revisions clarify issues including the prevention of facilitation payments*, compliance due diligence of business partners, and procedures for compliance screening when hiring of currently active or former public officers. In FY 2019, we introduced a new supplier examination tool by an external company, and strengthened the examination for preventing bribery and anti-social transactions before transactions at Hitachi Construction Machinery and domestic group companies. At the same time, we reviewed the procedure so that the examination record remains.
These regulations are in accordance with the HCM Group Codes of Conduct. The goal is to execute business operations in a lawful and proper manner in relation to laws and regulations in Japan and abroad to prevent bribery, and conduct ourselves in accordance with the law and correct corporate ethics. Moreover, overseas group companies that have newly become members of the HCM Group are also adopting the revised set of regulations so that they employ the same standards as the HCM Group.
Also, the HCM Group will obey laws and regulations in each country and region that prohibit fraudulent business transactions, involvement in such, and money laundering (laundering of money obtained through criminal or other illegal means), pursuant to the HCM Group Codes of Conduct. Furthermore, suppliers are given the Hitachi Group Sustainable Procurement Guidelines and required to prevent improper benefits as part of the business ethics clearly stipulated therein.
The HCM Group is working to prevent all forms of bribery by utilizing Hitachi’s e-learning program (global edition) on the basics of bribery prevention in order to increase knowledge about corrupt practices, including bribery.
In FY2020, there were no incidents involving bribery-related violations or sanctions. As a result, there were no instances of related disciplinary action, fines, or penalties levied against employees.
*Facilitation payment: Funds paid to public servants to ensure that operations, including approvals, immigration control, and customs, are carried out smoothly.
Hitachi Group Sustainable Procurement Guidelines