Whistleblower Protection Policy

The whistleblower protection policy offers protection from retaliation to the whistleblower, with respect to matters that are, or could give rise to a breach of the laws, regulations, rules, other legal requirement, applicable Hitachi Energy’s policy, the Hitachi Energy’s Code of Conduct, or any ethical code or applicable industry standard, provided the complaint is made:

• In good faith and in a manner that is consistent with Hitachi Energy’s values, particularly respect for others; and
• In the reasonable belief of the whistleblower that the conduct or matter covered by the complaint constitutes, or has the potential to constitute, a serious violation.

No complaint that satisfies these conditions shall result in any retaliation or threat of retaliation against the whistleblower. This means that Hitachi Energy and its directors, officers, employees and agents shall not penalize, discharge, demote, suspend, threaten, harass, transfer to an undesirable assignment or location, or otherwise discriminate (collectively “retaliate” or “retaliations”) against any whistleblower for calling attention to suspend illegal or unethical acts.

Any act of retaliation shall itself be treated by Hitachi Energy as a violation of Hitachi Energy's policy and could result in disciplinary action up to and including discharge. This protection also extends to anyone providing information in relation to an investigation.