Compliance

Recognizing that compliance requires that all activities must be carried out in accordance with corporate ethics and laws and regulations, the Hitachi Construction Machinery Group established a Compliance Division in May 2002. We have striven to make all employees fully and constantly aware of the importance of compliance by a repeated process of surveying employees' level of awareness and conducting training and education based on the results of those surveys.

Since 2009, we have made October every year "Corporate Ethics Month," and members of the newly established Compliance and Risk Management Division go around to all branch offices and plants to hold discussions on compliance and provide other awareness training. In fiscal 2011, compliance officials visited domestic Group companies to hold discussions on identifying compliance issues at the companies and finding solutions for them.

■ Instilling the Hitachi Construction Machinery Group's Code of Conduct
We established the Hitachi Construction Machinery Group Code of Conduct to ensure that all Group executives and employees adhere to all laws and regulations and our corporate ethics in their activities.

The Code of Conduct stipulates specific rules regarding business activities, activities for protecting the environment, respect for human rights, and so on. To make the code widely known within the Group, we have been conducting e-learning and training about the code to all Group employees since fiscal 2010, when the code was established. Since fiscal 2011, we have been providing similar training to our overseas Group employees in addition to continuing training at domestic Group companies.

Through these efforts, we are aiming to make this Groupwide Code of Conduct globally known to ensure that our Group employees around the world carry out their activities with a commonly shared awareness and knowledge of compliance.

* HGB is a training program aiming at the human resources development of the national staff at our overseas Group companies. The training focuses on three themes: "Kenkijin Spirit," "compliance," and "CSR."

■ Strengthening the functions of the compliance hotline
The Hitachi Construction Machinery Group set up a "compliance hotline" in May 2004 to find out problems related to compliance as quickly as possible and to solve them properly. Our Compliance Promotion Department receives the initial information from the hotline users, who are completely protected. The information in the signed report is then confirmed and acted upon, and the hotline user is provided with feedback on the action taken.

In fiscal 2011, over 20 cases were reported, including a number related to workplace communication problems, the cases of which have been tending to increase in recent years. Contact was made with the relevant offices as necessary, and the problems in question were resolved. In addition to this hotline, in fiscal 2012, we are planning to set up an overseas hotline that can respond in multiple languages to problems occurring at our global operations. This will serve to further strengthen compliance in our overseas Group companies.

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