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Resolving issues

Hitachi ABB Power Grids applies zero tolerance and takes the appropriate disciplinary action

Hitachi ABB Power Grids is focused on preventing, detecting and remediating integrity concerns. We enforce a strict zero tolerance policy for violations of the law or the Hitachi ABB Power Grids Code of Conduct, and we will take the appropriate disciplinary action – including termination of employment – against employees who violate the law or the Hitachi ABB Power Grids Code of Conduct.

Anti-bribery reviews of business units and countries globally are conducted frequently throughout the year. Each review includes examination of business processes, accounts and balances, and tests transactions to assess robustness of controls and identify possible violations. The anti-fraud program is also monitored by internal audit who regularly evaluates fraud risk exposure and developing trends. This is a cross functional analysis of 21 program elements and the response plan to prevent and detect potential fraud.

Remediation

Resolving any potential integrity concerns.

All reports come into the Office of Special Investigations, a function of the integrity team reporting to Head of Integrity Hitachi ABB Power Grids. OSI has dedicated investigators working in multiple regions.

All allegations / reported issues are appropriately investigated, exposures mitigated and disciplinary actions taken as applicable and appropriate. The special investigation officers work in a coordinated effort with functions such as internal audit and Legal and Integrity in delivering a wide-range of investigation support on all aspects of conducting investigations at Hitachi ABB Power Grids.

The Hitachi ABB Power Grids Code of Conduct is enforced through systematic disciplinary actions.

The Disciplinary Protocol is Hitachi ABB Power Grids’s formal process for dealing with the individual consequences of integrity and compliance matters. The process was institutionalised in 2004 with the creation of the Human Resources Disciplinary Committee (HRDC) at headquarters. Additional committees have been established at the regional level since 2008. Hitachi ABB Power Grids employs Human Resources Disciplinary Committees at headquarters and in the regions to implement disciplinary decisions based on investigative results.

Hitachi ABB Power Grids is committed to preventing reoccurring problems through enhanced processes and controls, training and communications.

Remediation is an important part of the global Hitachi ABB Power Grids integrity program and a key aspect of preventing reoccurrence of potential issues. Hitachi ABB Power Grids seeks to identify risk early on so that each situation can be assessed and sustainable remediation measures applied quickly. Hitachi ABB Power Grids conducts periodic review and testing of the implementation of the code of conduct, standards, and procedures designed to evaluate and improve their effectiveness in preventing and detecting violations of the Code of Conduct, local laws and Hitachi ABB Power Grids's integrity program, taking into account relevant developments in the field and evolving international and industry standards.

Following detection of an integrity concern, Hitachi ABB Power Grids takes the appropriate steps to resolve the situation and to help prevent the reoccurrence of such an event. Lessons learnt and ongoing improvements in order to anticipate future trends allows Hitachi ABB Power Grids to initiate proactive action plans designed to mitigate risks for Hitachi ABB Power Grids on a long-term basis.