What can be reported?
All Hitachi Energy Code of Conduct and Supplier Code of Conduct violations shall be reported, including but not limited to:
- Ethics and compliance issues, misconduct, fraud, corruption, financial record violation, facilitation payments, conflicts of interest, insider trading or antitrust regulations, theft, embezzlement.
- Workplace Discrimination, (Sexual) Harassment, Retaliation/ Retribution, Improper Employment/ Disciplinary actions.
- Workplace Health and Safety violations, Threats and physical Violence, Alcohol and Substance Abuse, and Environmental issues.
Hitachi Energy employees and stakeholders (hereafter “Reporters”) should report suspected or observed violations of the law, the CoC, or of company policies.
As a first step, and if not harming the matter at hand, reporters could contact their direct management or functions (e.g. integrity, legal, HR) for an initial check. Remaining suspected or observed violations of the law, the CoC, or of company policies should be reported by the initial reporter or their business management via one of the following channels:
- (preferred) the Ethics Web Portal and Ethics Hotline
- (not preferred) alternatively employees can also report their concerns directly to the Office of Special Investigations, which is a corporate function within Hitachi Energy via mailbox email@example.com; or
- (not preferred) send correspondence by post to the Office of Special Investigations: George Hintzenweg 81 - 3068 AX Rotterdam, The Netherlands.
Additionally, all stakeholders that have a business relationship with Hitachi Energy can file a report by using the same Hitachi Energy Ethics Web Portal or Ethics Hotline as described above.
The Ethics Web Portal and the Ethics Hotline
Reports via the Ethics Hotline and the Ethics Web Portal are received and processed by an independent service provider and this provider is available 24 hours a day, 7 days a week. At the end of your report, you will be given a report identification number and PIN so that you can follow the progress of your report online or by telephone. The independent third party forwards the report to the Office of Special Investigations within the Headquarters of Hitachi Energy.
The Ethics Hotline is available for each country and the hotline numbers are available on the external service provider’s website.
Limitations on reporting for some EU countries
On account of direction from certain European Data Protection Authorities, reporters based in 10 EU countries (Belgium; Denmark; France; Germany; Greece; Luxembourg; Netherlands; Portugal; Spain; Sweden) will be allowed to report only on permissible subject matters and have an exhaustive list of reportable categories available to them on the Ethics Hotline and the Ethics Web Portal.
What kind of information do I need to provide?
When making your report, please be aware that the information you provide or the allegations that you make could result in decisions that affect employees of Hitachi Energy and other third parties involved in the matter. We therefore kindly ask you to provide us only with accurate information to the best of your knowledge.
We ask you to provide as much detailed information as possible, all relevant facts (including dates, what happened, who is involved), details and explanations in relation to your report so that the Office of Special Investigations (OSI) can investigate your report fairly and thoroughly. Reports which lack details or cannot be substantiated will not justify further investigation or review.
Hitachi Energy strongly encourages reporters to provide their contact details so that contact can be maintained throughout the investigation. Having the contact details of the reporter also benefits the investigation in case OSI requires further information and assistance from you. However, reports can be made anonymously.
Hitachi Energy will take all reasonable steps to ensure confidentiality throughout the reporting process, so individuals filing reports should not fear that their identity or issue will be improperly disclosed or abused. Complaints made in good faith will not expose any reporter to sanctions.
Next steps after reporting
All reports come into the Hitachi Energy’s Office of Special Investigations (OSI), which reports directly to the Head of Integrity of Hitachi Energy. OSI will decide on conducting the investigation or referring the report to another function to investigate, if appropriate.
The Office of Special Investigations will collect all relevant facts and oversee the management of any integrity reports that are referred out. OSI has dedicated investigators working in multiple regions.
All reports are subject to appropriate investigation and are brought to full closure.
Hitachi Energy has a protocol to implement disciplinary decisions based on investigative results.
What not to report
The Reporting Channels described above are available for integrity concerns. Individual employee grievances / complaints relating to job performance, and complaints related to the terms and conditions of employment should be channeled through the HR function directly and are not considered integrity concerns by nature.