A strong set of internal controls
Our Hitachi Energy corporate regulations reinforce the following areas:
- Bribery and corruption is prohibited in all business dealings, whether with public officials or private sector business partners. As a rule, facilitation payments are not permitted.
- Substance-based due diligence is mandatory prior to the appointment of Hitachi Energy representatives, such as third party local agents and distributors. Centralized and transparent approval processes with appropriate controls over performance, is mandatory prior to any remuneration payments.
- Donations (incl. political and charitable contributions) and Sponsorships are subject to detailed internal policy and controls
- The Gifts, Entertainment and Expenses policy defines thresholds, approval processes and their documentation, with additional controls for public officials.
- Agreements with subcontractors and consortium partners are aligned with Hitachi Energy’s commitment to integrity in the performance of the contract, including commitments not to violate anti-bribery laws. Suppliers must also maintain integrity standards which are satisfactory to Hitachi Energy and agree to the Hitachi Energy Supplier Code of Conduct.
- Gifts, Entertainment, and Expenses
- Sponsorships & Donations
- Appointment of representatives
Our success as a company is based on the quality and reliability of our products and services. To protect our reputation, our customers and stakeholders can trust us to only give or receive legitimate and reasonable business Gifts and Entertainment.
Our corporate regulation on Gifts, Entertainment and Expenses covers both giving and receiving. As a company, we respect global thresholds and approval processes, taking into consideration local standards in the various regions in which we do business.
We also recognize that other companies and customers often have their own code of conduct to abide by, and we are committed to never putting anyone in a position to violate their commitments. Our controlled and transparent approval process for Gifts, Entertainment and Expenses, serves to support our employees so that they can feel confident they are not crossing the line.
Furthermore, additional controls have been developed for public officials. Employees of government owned or controlled companies are subject to these heightened standards.
In order to determine whether Gifts, Entertainment or Expenses are appropriate, each employee should consider the following criteria:
- Made for the right reason: The Gift, Entertainment or Expense should be given as an act of appreciation, friendship, hospitality or mandated by contract and made in good faith;
- No obligation: The Gift, Entertainment or Expense does not place the recipient under any obligation;
- No expectations: Expectations are not created in the giver or an associate of the giver or have a higher importance attached to it by the giver than the recipient would place on such a transaction;
- Made openly: If made secretly then the purpose will be suspect;
- No misuse of Expenses: Payment or reimbursement of Expenses shall not be misused to hide inappropriate Gifts or Entertainment;
- Appropriate: The nature of the Gift, Entertainment or Expenses is appropriate and is in line with both general business practices as well as local cultural and ethical standards;
- Legality: It conforms to the laws of the country where it is made and any other applicable laws;
- Conforms to the recipient's rules: The Gift, Entertainment or Expense meets the rules or code of conduct of the company or organization where the receiving person is employed;
- Infrequent: Such giving or receiving is not a regular happening between the giver and the recipient;
- No Cash: The Gift shall not be in the form of cash or a loan, nor a check or shopping voucher, gift cards, coupons or cash equivalent;
- No Conflict of Interest: Avoid any conflict of interest situations when giving or receiving Gift, Entertainment or Expenses;
- Health and Safety: When accepting or inviting for Entertainment always consider the health and safety aspects;
- Documentation: GEE must be documented completely and accurately in GEE Compliance Desktop, in books and records and any other systems or tools.