Hitachi Rail STS promotes the fight against corruption in all its different forms at all levels and within the scope of its business, whether active or passive, direct or indirect, involving subjects related to the public or private sectors. Hitachi Rail STS has implemented a corruption risk management system based on several control tools. The most important tools are:
The Code of Ethics serves as a tool to control and mitigate corruption risk. Compliance with the principles and rules of conduct contained therein enable Hitachi Rail STS and the STS companies, worldwide, to prevent certain illegal conduct or offences – including those that are corruption-related and as required by the regulations of the various countries in which Hitachi Rail STS operates – from being committed by corporate representatives. In particular, through the Code of Ethics, the company promotes and applies a corporate culture inspired by responsibility, correctness and integrity in the conduct of daily activities, paying maximum attention to the professional conduct of its recipients.
The Code of Ethics is complemented by the Organisation, Management and Control Model pursuant to Italian Legislative Decree 231/01 approved by the Board of Directors of Hitachi Rail STS, which contains specific principles of conduct and control aimed at preventing and mitigating the risk of committing corruption-related offences as set out by Italian Legislation and specifically referred to in Articles 25 and 25-ter of Legislative Decree 231/01.
The main risk areas, including direct risks and the areas that could potentially facilitate acts of corruption subject to the requirements of the Model, are mainly sales, contract management, procurement, sites, administration, finance and control, Human Resources and soft loans.
In order to ensure the comprehensive acknowledgement of the Organisation, Management and Control Model pursuant to Italian Legislative Decree 231/01 by all personnel, all employees receive a report whenever updates are made to the Model. In addition, a new e-learning training programme was recently offered to nearly all employees of Hitachi Rail STS S.p.A. Employees working in at-risk areas, as well as executives and middle managers, sign periodic statements to certify compliance with the Model and, when needed, are required to describe the most significant relationships with customers and representatives of the public authorities.
The prevention and fight against corruption-related conduct is also supported by a well-structured and comprehensive body of corporate procedures, applicable in agreement with the special national provisions regarding the individual group companies. These procedures govern the conduct of company transactions and operations, so as to ensure the identification of the persons responsible for the decision-making and authorisation process, and to provide traceability, enabling the identification of the reasons for the decisions made and the persons to be held accountable for them. The corporate body of procedures specifically governs and defines those which, due to their very nature or to the type of parties involved, including external parties, are potentially vulnerable to the risk of corruption.
In order to mitigate the risk of corruption, Hitachi Rail STS has developed a tool to combat this problem and a process to assess the various types of third parties with whom it deals, both within the scope of business activities and for ordinary corporate operations. This process includes, a clear view of the internal areas that can be associated with external third parties where such risks could occur, as well as a range of assessment tools for verifying, inter alia, the existence of potential indicators of a high risk of corruption.
In order to further equip itself with effective prevention tools against the occurrence of potential corruption-related events, Hitachi Rail STS has launched a global process aimed at analysing its own corruption risk management system and to identify possible areas for improvement. This activity was carried out in compliance with the company’s international work and took into consideration the best practices in this area and the main international Guidelines and Conventions concerning the prevention and fight against corruption. To ensure the uniformity and completeness of the risk management systems adopted by the company, the activity was carried out in a fully integrated manner and in full coordination with the risk management tools defined pursuant to Italian Legislative Decree 231/01.
The improvement initiatives identified at the end of the aforesaid analysis will further refine the current corporate corruption risk management system, with a view to increasing the effectiveness of the mitigation instruments that concern combating and preventing corruptive phenomena, including those at an international level.
Hitachi Rail STS has a defined global Anti-Corruption Policy that determines the principles of reference, defines the roles and responsibilities, and also identifies the key measures necessary to achieve effective anti-corruption management throughout STS. This Anti-Corruption Policy was approved by the Board of Directors on 31 July 2018.
The Hitachi Rail STS Code of Ethics and the corresponding Code of Ethics adopted by each legal entity of STS company was updated, bringing them all into alignment with the principles set out in the aforementioned policy.
The Anti-Corruption Policy also provided for an Anti-Corruption training programme required for all STS company employees, globally, to widely share the policy and related knowledge. In order to strengthen the monitoring tools and control mechanisms designed to control the corruption risk, and as provided for by the policy, a quarterly reporting system is currently being implemented.
The purpose of this reporting activity is to analyse the areas at potential risk of corruption at the global STS level. Furthermore, an annual report is presented to the Board of Directors, the Board of Statutory Auditors and the Risk and Control Committee of Hitachi Rail STS S.p.A. concerning the effectiveness, adequacy and state of implementation of the Anti-Corruption Policy.
For Hitachi Rail STS, social responsibility translates into the daily focus and care of its relations with stakeholders. Understanding their needs and expectations is achieved through the definition and implementation of specific tools for dialogue and interaction.
Hitachi Rail STS interacts in the different ways with its stakeholders, distinguishing between:
With personnel having increased as at 31/03/2019 by 2.4% compared to 31/03/2018, the percentage of employees hired on open-ended contracts remained high and constant at 98.1%, demonstrating the importance that Hitachi Rail STS places on the provision of stable employment.
98.1%
employees hired with open-ended contracts
At Group level, Hitachi Rail STS has reached formal agreements with the trade unions in the various countries concerned. In Central Europe and Western Europe, the agreements relate to, inter alia, work hours, remuneration and health and safety conditions in the workplace.
In Australia, trade union relations are extremely positive and the next 3-year Company contract is due to be negotiated soon.
In Malaysia there are no formal agreements and employees must only comply with the Employment Act of 1955 (which establishes that the number of hours worked per week may not exceed 48) and specific Acts passed by the Government with respect to health and safety.
In Italy, Hitachi Rail STS’s system for trade unions relationships is based on two levels of participation, given the fact that the Company has various operating sites scattered throughout Italy: 1. Strategic Observation; 2. National Coordination.
On 18 December 2018, after one year of union negotiations, the second level supplementary agreement for the three-year period 2019-2021 was renewed in Italy. The agreement was signed by the union representatives after being approved by a vast majority in a referendum voted on by the company employees. The agreement comprises improvements in various institutions regulated by the national contract and introduced agile work methods and the possibility to allocate a part of the performance bonus to company welfare for the first time in Italy.
Each month, in France, staff representatives may present individual or collective issues to their employers, in relation to the application of the law, regulations and collective agreements.
The system of trade union relationships at Hitachi Rail STS in Spain is based on the following: 1. Strategic lines; 2. National coordination.
100%
the percentage of employees covered by national labour agreements
97%
the percentage of employees covered by national labour agreements
The percentage is minimal in the Asia Pacific due to Hitachi Rail STS’s ongoing efforts to invest in a fair work Environment with respect to the market. The economic-social context in the Americas and China has no national labour agreements. In view of these considerations, 64% of STS employees are covered by collective agreements
The adjustment of the organisational structure, along with the operating procedures that support it, is an ongoing and continuously evolving process that meets the similarly ongoing and continuously evolving scenario in markets where Hitachi Rail STS operates. In the event of particularly significant organisational changes, specific communications initiatives targeting broad categories of employees are envisaged to explain the reasons for the changes.
Although not having an obligation relating to the number of weeks of prior notice, the company issues the organisation chart specifying the inclusions and assignment of each employee every six months on average.
Furthermore, in Italy the currently applicable national labour agreement provides for a specific meeting to inform the trade unions of decisions that have a material impact on labour organisation. A similar procedure is provided for in France, requiring a mandatory document to be sent to the work council explaining the reasons for the organisational change, followed by a meeting with work council representatives no later than 15 days after the document is sent.
Hitachi Rail STS acts in full compliance with current legislation, with the Code of Ethics, the Organisation and Management Model relating to Italian Legislative Decree no. 231/01, the Policies and all regulations on Health, Safety and Environment (HSE), pursuing a sustainable management of environmental issues related to its services in all its business areas.
Hitachi Rail STS has considered it strategic to include its Quality, Safety, and Environment System (IMS – Integrated Management System) within its governance framework and, in particular, to create strategic synergies with the Internal Auditing and Risk Management system: the Integrated Management System is thus considered a reference architecture to integrate systems and to implement principles and values within the organisation.
The Integrated Management System has been established at the corporate level, by implementing global policies and procedures in order to guarantee a controlled management of processes. In this context, the assessment of business risks and their proper management requires the correct identification of the processes and their interpretation from a systemic perspective.
Subsequently, each company established local environmental and safety policies, on the basis of the local legislative requirements and the corporate policies and procedures.
To ensure enhanced usability of documents, a Company Intranet was implemented. It allows all employees to more easily consult the corporate and local IMS documentation.
| COUNTRY | PRODUCTION SITES | ISO 9001 | ISO 14001 | OHSAS 18001 |
|---|---|---|---|---|
| USA | Batesburg | ✓ | ✓ | ✓ |
| FRANCE | Riom | ✓ | ✓ | ✓ |
| ITALY | Tito Scalo | ✓ | ✓+ EMAS | ✓ |
| COUNTRY | OFFICES (NON-PRODUCTION SITES) | ISO 9001 | ISO 14001 | OHSAS 18001 | |
|---|---|---|---|---|---|
| Europe | UNITED KINGDOM | London | ✓ | ✓ | ✓ |
| FRANCE | Les Ulis | ✓ | ✓ | ✓ | |
| SPAIN | Madrid | ✓ | ✓ | ✓ | |
| Zaragoza | ✓ | ✓ | ✓ | ||
| SWEDEN | Stockholm | ✓ | ✓ | ✓ | |
| DENMARK | Copenhagen | ✓ | ✓ | ✓ | |
| ITALY | Genoa | ✓ | ✓ | ✓ | |
| Naples | ✓ | ✓ | ✓ | ||
| Piossasco | ✓ | ✓ | ✓ | ||
| SAUDI ARABIA | Riyadh | ✓ | ✓ | ✓ | |
| PERU | Lima | ✓ | ✓ | ✓ | |
| TAIWAN | Taipei | ✓ | ✓ | ✓ | |
| MALAYSIA | Kuala Lumpur | ✓ | ✓ | ✓ | |
| USA | Pittsburgh | ✓ | ✓ | ✓ | |
| AUSTRALIA | Brisbane | ✓ | ✓ | AS/ZNS 4801:01 | |
| Newcastle | ✓ | ✓ | AS/ZNS 4801:01 | ||
| Perth | ✓ | ✓ | AS/ZNS 4801:01 | ||
| Sidney | ✓ | ✓ | AS/ZNS 4801:01 | ||
| Karratha | ✓ | ✓ | AS/ZNS 4801:01 | ||
| INDIA | Kolkata | ✓ | ✓ | ✓ | |
| Noida | ✓ | ✓ | ✓ | ||
| Bangalore | ✓ | ✓ | ✓ | ||
| CANADA | Toronto | ✓ | ✓ | ✓ | |
The 3 production sites and the 23 offices listed in the tables represent, in terms of employees, around 91% of Hitachi Rail STS, which is composed of a total of 3 production sites and 29 offices.
The production sites of Tito Scalo, Riom and Batesburg and the offices of Genoa, Les Ulis, Pittsburgh and Beijing have obtained the IRIS (International Railway Industry Standard) certification.
The IRIS standard is promoted by UNIFE, the Association of European Railway Industries, which guarantees its supervision and control. The IRIS standard was developed starting from the ISO 9001 standard, integrating it with specific railway sector requirements.
Hitachi Rail STS is part of the IRIS Steering Committee that rules the IRIS activities and of the Advisory Board which manages the interface between IRIS and the main European railway operators.
Hitachi Rail STS’s training path has been implemented with the cooperation of Training Needs Managers (TNM). This initiative aims to identify personnel who can serve as contacts for Human Resources in the definition of specific training and development plans for operational structures, in order to facilitate understanding of the specific needs of each operational unit and make it possible to define projects that more accurately target their actual needs. Training Needs Management is distinguished by the concept of “Community”, which translates into encouraging the creation of a network to reduce geographical distances.
Hitachi Rail STS carries out training and information sessions to draw attention to:
The training sessions were held by personnel competent in the relevant field. The specialised technical focus of the training demonstrates Hitachi Rail STS’s aim of targeting operating positions involved in duties and activities that are potentially critical in terms of environment, health and safety.