Transparency Information

Anti-Modern Slavery

1 Introduction

This statement is made pursuant to Section 54(1) of the Modern Slavery Act (MSA) 2015 for the fiscal year ending March 31, 2025 and articulates the steps that Hitachi Solutions Europe Limited has taken to minimise the risk of slavery and/or human trafficking in our supply chains or in any part of our business.

2 Description of the Company

Hitachi Solutions Europe Limited headquartered in London, United Kingdom, with subsidiaries in Europe, is a recognised leader in delivering proven business and IT strategies and solutions to companies across many industries within Europe. The company provides value-driven services throughout the IT life cycle from systems planning to systems integration, operation and maintenance. Hitachi Solutions Europe Limited delivers products and services of superior value to customers based around the Microsoft D365 offering. Additional services also including Transformation and Adoption as well as Business Analysis & Lifetime Services.

2.1 Our Business Organisation

Hitachi Solutions Europe Ltd operates in Europe through two subsidiaries in Germany (one holding/investment vehicle subsidiary & one operational subsidiary) & a branch single office structure in each of the following countries: France, Portugal & Bulgaria.

3 Information on the Supply Chain

Hitachi Solutions Europe Limited purchases principally services from dedicated labour agencies to support peak delivery demand in Europe. Product purchases are in comparison very low in volume from both a financial value & frequency basis. Hitachi Solutions Europe Limited has approximately 325 suppliers (as at 06.04.23).

Figure 1 Total spend activity by jurisdiction, year ending 31.03.23

Our analysis indicates that the majority of our spend activity for the year ending 31.03.2023 was in the United Kingdom.

It is the opinion of Hitachi Solutions Europe Ltd that modern slavery & or human trafficking, whilst not normally considered high risk in the professional services sector, can still occur. We remain vigilant to its occurrence & have the following controls in place to address this potentiality:

• ISO 9001 documented & certified processes that detail the controls in place These certified & documented processes include all aspects of the employee lifecycle.
  • We have Procurement, Finance & Service Delivery/Governance processes that document the full Supplier & Project lifecycle with specific steps to validate the degree of modern slavery & human trafficking prevention, detection & reporting applied in our service delivery & within our supply chains
  • We have a Group Global Whistle Blowing Third Party provided service available to any resource (internal or external) for the submission of any concerns, as detailed below: By phone on 0800 086 9859

• • • By internet: hitachi.ethicspoint.com 24 hours a day / 7 days a week
    • Toll free
    • Calls are not recorded or traced

• • These controls are evidenced as being effective as substantively evidenced by our ISO 9001 certification
  • Hitachi Solutions Europe Ltd is of the opinion that these provisions evidence due diligence in our processes in relation to slavery & human trafficking in our business & supply chains
• A full time professional qualified Human Resources (HR) & Project Governance function that is trained to detect, mitigate & report any known or reasonably foreseeable risk of modern slavery & or human trafficking
• Our Information Security Board (ISB) performs Risk Assessments for the prevention detection & reporting of modern slavery and human trafficking

• • These Risk Assessments are reviewed by our ISO auditors as well as being available to a dedicated Group Internal Audit function on demand
  • Hitachi Solutions Europe Ltd is of the opinion that these provisions evidence substantive steps to assess and manage the risks modern slavery and human trafficking pose

• Hitachi Solutions Europe Ltd runs an Information Security Board (ISB) that documents any & all concerns & the action(s) taken

  • These minutes are available to our ISO auditors as well as being available to a dedicated Group Internal Audit function on demand
  • In these minutes, our modern slavery and human trafficking metrics will be captured
  • Our metrics include the number of any known or suspected slavery & or human trafficking incidents reported Our experience to date is that this number has been nil (zero), however we remain alive to the potential incidence

    • • Our experience to date is that this number has been nil (zero), however we remain alive to the potential incidence

  • If any known or suspected incident were to be detected or suspected in our business, our partners, our clients or our supply chain, the appropriate corrective action(s) would be executed
    • For the avoidance of doubt this is likely to include report(s) to the appropriate statutory bodies / law enforcement
    • Hitachi Solutions Europe Ltd is of the opinion that these provisions evidence substantive steps to ensure that modern slavery and human trafficking is not taking place in our business or supply chains as measured against performance indicators Hitachi Solutions Europe Ltd considers adequate to evidence this responsibility

  • Hitachi Solutions Europe Ltd & its subsidiaries run regular modern slavery & human trafficking awareness training that is mandatory for all staff.

    • Completion metrics are tracked, reconciled & reported to Hitachi Group to evidence staff awareness & understanding
    • These metrics are reviewed by our ISO auditors as well as being available to a dedicated Group Internal Audit function on demand
    • Hitachi Solutions Europe Ltd is of the opinion that this evidences the appropriate training & capacity building for modern slavery and human trafficking awareness, detection & reporting for our staff, our partners & our clients

• Our Compliance function works with our Human Resources (HR) function & other functions to undertake a monthly Information Security Board (ISB) review of all compliance related matters on a scheduled monthly & on demand basis

  • It is the opinion of Hitachi Solutions Europe Ltd that the Information Security Board (ISB) evidences we are actively & demonstrably considering risks of modern slavery & human trafficking
  • If any known or suspected incident were to be detected or suspected in our business, our partners, our clients or our supply chain, the appropriate corrective action(s) would be executed
    • For the avoidance of doubt this is likely to include report(s) to the appropriate statutory bodies / law enforcement

• Our Human Resources (HR) function, perform specific checks throughout entire employee/associate lifecycle to consider if there is any known or reasonably foreseeable modern slavery or human trafficking risk is/are evidenced or suspected

▪ We actively screen proposed new suppliers for modern slavery and human trafficking awareness & compliance.

▪ We review our Accounts Payable Supplier Master & in concert with input from our Procurement, Finance and Human Resources (HR), functions for any concerns

Hitachi Solutions Europe Ltd undertakes an active dialogue with our recruitment partners to clearly confirm & evidence that they:

▪ Have active & effective anti modern slavery and human trafficking prevention detection & reporting mechanisms in place

▪ They have the appropriate awareness and clearly identified contacts to enable the controls detailed above to be meaningful

Reporting our Gender Pay Gap

April 2023

The value of Diversity and Inclusion within Hitachi

Diversity is the wellspring of our innovation and our growth engine. Hitachi regards personal differences – gender, nationality, work history, age, sexual orientation, and philosophy – as facets of people’s individuality. By respecting our employees’ individualities and positioning them as an advantage, Hitachi frames its diversity and inclusion as conducive to both the individual’s and the company’s sustainable growth. With strong teamwork and broad experience in the global market, we will meet our customers’ needs.

Diversity at Hitachi Solutions Europe Ltd.

Diversity at Hitachi Solutions means that we appreciate and value differences. It also means seeking to achieve a mix of people that reflects society today. We seek to promote diversity at all levels of the company and will focus on gender diversity as our first goal in the area. However, we seek to ensure that nobody is discriminated against and all are provided equal opportunities notwithstanding their age, race, disability, gender reassignment, marriage and civil partnership, sexual orientation (LGBTQ+), pregnancy or maternity, religion or belief (including none).

Inclusion at Hitachi Solutions Europe Ltd.

Inclusion means that our whole workforce is engaged and enabled to work in a way that is beneficial to both the business and individual employees. A workplace environment is created so that all people are involved, feel a sense of belonging, and are respected, regardless of their diversity characteristics. Leaders encourage this environment to allow all employees to contribute and collaborate to the best of their ability.

The Business Case

Hitachi’s business case for workplace diversity demonstrates why diversity is fundamental to maintaining a successful business. It outlines the key benefits of having a diverse and inclusive workforce: increased creativity, better outcomes, workplace happiness, being ahead of the game, wider talent pools, and support from stakeholders.

Hitachi is supportive of the Government’s requirement for organisations to publish their gender pay gap results annually, as a means of recognising where a gender pay gap persists, and remains committed to working towards closing its gaps.

 

Hitachi Solutions Europe Ltd’s gender pay gap data

The data for our report was collected on 5 April 2022. 356 employees were classified as “full-pay relevant employees” for the purpose of reporting of hourly pay gap statistics. Of these 356 employees, 258 were male and 98 were female.

Our calculations for this period show that Hitachi Solutions Europe has a mean gender pay gap in hourly pay of 20.21% and a median gender pay gap in hourly pay of 15.79%.

In terms of demographics, Hitachi Solutions Europe’s UK workforce overall is more male dominated, with 72.47% of full-pay relevant employees being male and 27.53% female at the time of reporting. This is slightly ahead of industry standards, with most organisations in the hi-tech sector reporting an average 15% to 20% female workforce. In line with most organisations in our sector, males dominate the top pay quartile.  This is due to the higher proportion of males in senior management positions and highly technical (STEM) roles.  This can clearly be seen in our quartile gender ratios and has a significant impact on our gender pay gap and gender bonus gap.

On receiving our GPG results, we completed further analysis to better understand any pay gaps within segments of the workforce (the pay quartiles) and within Hitachi’s job grades. This confirmed that, while there are minimal pay gaps within all quartiles, we have a high proportion of males in our senior job grades, which significantly impacts our gender pay results.

We have carried out analysis to compare employee salaries within roles, and the results of this confirmed that pay for males and females in the same positions is equal.  This is an important distinction as gender pay gaps are not the same as unequal pay.  Equal pay relates to paying males and females fairly for work that is similar or of equal value. Gender pay reflects the underlying workforce demographics within an organisation.

 

Band	Description	Males	Females
A	Includes all employees whose standard hourly rate places them at or below the lower quartile	60.67%	39.33%
B	Includes all employees whose standard hourly rate places them above the lower quartile but at or below the median	69.32%	30.68%
C	Includes all employees whose standard hourly rate places them above the median but at or below the upper quartile	77.27%	22.73%
D	Includes all employees whose standard hourly rate places them above the upper quartile	84.09%	15.91%

 

Bonus Gap

The calculations indicate a difference in mean bonus payments of 43.01% and a difference in median bonus payments of 26.57%. The proportion of females that received a bonus is 63.27%, and the proportion of males that received a bonus is 73.64%.

Our gender bonus gap is impacted in two ways: the first is that we have a predominance of men in senior positions, therefore earning higher bonuses, and the second is that we have a predominance of men in sales positions, and commissions earned throughout the year are required to be reported alongside annual bonus payments.

Every role at Hitachi Solutions Europe is eligible for an annual bonus payment, however bonus payments are subject to start dates. Our bonus pay gap numbers reflect bonuses awarded during the reporting period of the 12 months prior to the snapshot date of 5 April 2022. The company’s annual bonus period runs from 1 April to 31 March every year, with payments being made to employees in May to employees who join by the 31^st December. Because we must look at the 12 months prior to the snapshot date, this means that the reporting period does not include any bonus for new joiners who started with the company after 31^st December and therefore a high number of employees cannot be included in our bonus gap calculation.

Our bonus pay gap figures were impacted by Covid for the snapshot period. Bonus earnings for all employees eligible for a bonus were reduced for the FY2020 bonus year (April 2020 to March 2021, paid in May 2021) in exchange for reduced targets. Sales commissions, however, were not reduced because commission rates are linked to new business revenue only. This would negatively impact our bonus gap numbers due to the predominance of men in sales positions.

Driving change

Hitachi Solutions participates in several Hitachi initiatives designed to support the ongoing and increasing awareness and understanding of diversity and inclusion across the global business.

In June 2020, Hitachi Ltd announced the appointment of Lorena Dellagiovanna as Chief Diversity & Inclusion Officer for Hitachi Ltd, the first time this position has been held within the global business.

Lorena frames the Hitachi Ltd. strategy for Diversity and Inclusion by explaining “Over 350,000 employees who are working at Hitachi are unique and diverse, with each of us carrying a huge asset of skills, capabilities, ideas, experience, and values. It is therefore very important to leverage this diversity by implementing a process for behavior change and by creating an environment where people can be themselves. That will bring a huge opportunity for Hitachi to bring innovation, to tackle new markets, to better serve our customer, and to attract new talents.”

In our talent hub locations (Bulgaria and Portugal), where we recruit a high number of graduates each year, the ratio of women to men is much greater. In Bulgaria, the employee population is 70% women and in Portugal the employee population is nearly 50% female. We believe this is reflective of a societal shift whereby young women are seeking education (and careers) in the STEM subjects. Although our talent hub locations are not included in our UK Gender Pay Gap results, we are proud to be growing the next generation of talent in a more balanced way and we are committed to closing the gap in the UK.

Improving the sharing of talent

Hitachi Solutions Europe facilitates a regular recruitment and resourcing forum to share talent between all regions within Europe, and from other Hitachi Solutions companies outside of Europe. This involves activities such as communicating vacancies between group companies (including roles in senior grades), sharing details of ‘must move’ talent to avoid losing valuable employees from the Hitachi Solutions family, increasing awareness of the careers site among employees, enabling peer networking among Hitachi graduates and apprentices and encouraging employees to learn about the wider Hitachi group.

Developing Talent

We run several internal processes to ensure all colleagues are supported and encouraged to develop professionally. We built our Career Development Manager programme to give each employee access to an internal mentor, responsible for providing advice and guidance on their career development, and for supporting their advancement and visibility. For many, the next stage of their professional development is becoming a Career Development Manager themselves, and we provide training and guidance on this throughout the process.

We run a transparent promotion process, always considering both male and female employees for promotion at each level, as well as aiming to ensure candidates are interviewed by both male and female interviewers. Senior level promotions are subject to a panel-style interview to ensure a consistent process.

Our ongoing commitment

At Hitachi Solutions, we have created an internal Diversity & Inclusion Committee, independent of the leadership team and with the mandate to raise ideas for action and provide feedback. This committee also operates as an open forum where anyone in the business can raise ideas and issues related to Diversity and Inclusion.

The global Hitachi, Ltd. business is also working proactively to accelerate its activities aimed at promoting diversity, with the ambitious goal of achieving a target 30% females in management positions by financial year 2030.  It has positioned diversity as an important management strategy and is advocating this approach throughout the worldwide group, based on strong commitment by senior management.

In Europe, Hitachi measures the impact of diversity and inclusion using an ‘Inclusion Index’ based on responses to its Global Employee Survey.  Questions about being treated with respect by managers and other colleagues, as well as seeing diversity and inclusion role-modelled by senior managers, give the company a measure of employees’ sense of inclusion and Hitachi’s continuing progress on diversity and inclusion.

With the following information, we give you an overview of the processing of personal data by us and the rights that data subjects can assert against us. Which data are processed in detail and how they are used depends largely on the object or purpose of our contact. Therefore not all parts of this information will apply to you.

1. Responsibility and contact

Responsible in accordance with Art. 4 (7) of the General Data Protection Regulation (GDPR) is

Hitachi Solutions Europe Limited

23rd Floor, 110 Bishopsgate, London, United Kingdom, EC2N 4AY

Telephone: +44 (0)204 526 8510
Email: [email protected]

The contact details of our Data Protection Officer are:

Bryan Coley
Hitachi Solutions Europe Limited

Telephone: +44 (0)204 526 8510
Email: [email protected]

 

2. Sources and data

We process personal data that we receive from our customers or their authorised representatives or interested parties within the scope of our business relationship. These data can be:

• Personal data (name, contact details, address, telephone, fax, email, date and place of birth, gender)
• Data from the fulfilment of our obligations (name, contact details, address, telephone, fax, email, if applicable others – depending on the respective obligation)
• Data advertising and sales (name, contact details, address, telephone, fax, e-mail)
• Order data (name, contact details, address, telephone, fax, e-mail, if applicable others – depending on the project)
• Other data comparable with the above species

In addition, we process personal data that we have obtained from publicly accessible sources (e.g. commercial register, press, media or Internet) in a permissible manner and whose processing complies with the law.

 

3. Purpose and legal basis

We process personal data in accordance with the provisions of the GDPR (General Data Protection Regulation) and the DPA (Data Protection Act 2018) and all other relevant laws:

1. to implement our contractual relationships (Art. 6 (1) letter b GDPR)

The processing of data is carried out to provide our services and commercial transactions within the framework of customer contracts or to carry out pre-contractual measures which are carried out on request. The purposes of the data processing are generally based on the subject matter of the contract and may also include, among other things, demand analyses and consultation.

2. as part of the balancing of interests (Art. 6 (1) letter f GDPR)

As far as necessary, we process data to protect legitimate interests. Examples of this are the assertion of legal claims and defence in the event of legal disputes, guaranteeing IT security and our IT system, checking and optimising procedures for analysing requirements for the purpose of directly addressing customers, measures for building and plant security (e.g. access controls) or measures for business management and the further development of services and products.

3. on the basis of legal requirements (Art. 6 (1) letter c GDPR)

We are subject to various legal obligations. These include in particular the fulfilment of fiscal control and reporting obligations

4. on the basis of consent (Article 6 (1) letter a GDPR)

As far as we have received consent to process personal data for specific purposes, the lawfulness of the processing on this basis is given. A given consent can be revoked at any time for the future. The declaration is possible informally.

 

4. Data receiver

Within our company, those departments receive access to personal data which they need to fulfil our contractual and legal obligations. Service providers and vicarious agents employed by us may also receive data for these purposes, provided they maintain confidentiality and comply with our data protection instructions.

With regard to the passing on of data outside our company, we strictly observe the secrecy law regarding all data of our customers and interested parties. We are allowed to pass on information if we are obliged to provide information by legal regulations or if we have consented to this. Service providers commissioned by us must also ensure compliance with confidentiality and the provisions of the GDPR. These are above all service providers for data medium destruction, EDP/IT support and maintenance service providers, legal advisers, payment transaction service providers and tax consultants.

 

5. Transmission to Third Countries / international Organisations

A data transfer to countries outside the European Union or the European Economic Area – so-called third countries – takes place only within the group and/or as far as this is necessary or legally prescribed for the execution of our orders (e.g. tax reporting obligations), if we have your consent or in the context of an order processing.

If necessary, in individual cases, personal data will be transferred to an IT service provider in a third country to guarantee our IT operations. If the service provider is used in a third country, the appropriate level of data protection is guaranteed by the conclusion of the EU standard contract clauses.

When processing incoming messages, access may also be required under certain circumstances by such employees of the relevant specialist department who are organisationally located in Germany, Hitachi Solutions Germany GmbH. The employees concerned have their line manager at Hitachi Solutions Germany GmbH. In particular, access may be necessary in order to ensure that the other employees can continue to process the messages received in an orderly manner in the event of illness.

 

6. Customer relationship management

Our customer relationship processes are software-supported. All European units of Hitachi Solutions use a common tool: Microsoft Dynamics 365 Sales. Data processing within the meaning of section 4.1 takes place here (pre-contractual measures).

Access by our European units (including access from third countries as defined in the GDPR) is controlled by an authorization concept.

For Great Britain applies:

We use Microsoft Dynamics 365 Sales in conjunction with the following tools:

• Userlane: Training tool that simulates use cases in the production environment. The personal data mentioned in point 2 can be processed in this context.
• ClickDimension: Marketing tool that processes the personal data mentioned in number 2 in order to send newsletters. It also serves as a campaign tool
• Introhive: A software solution that helps to visualise customer relationship information across the company. The personal data mentioned in point 2 can be processed in this context.

Microsoft Co-sell opportunities: Part of a Microsoft portal where sales opportunities are entered in order to provide customers with the best possible advice This portal is used to make agreements on sales opportunities directly with the manufacturer Microsoft. First name, surname, e-mail address and telephone number are processed.

 

7. Storage duration

We process and store data as long as it is necessary for the fulfilment of our contractual or legal obligations.

If the data is no longer necessary for the fulfilment of contractual or legal obligations, it is regularly deleted, unless its temporary further processing is necessary to fulfil commercial or tax law storage obligations. The periods of retention or documentation are usually between 2 and 10 years. In these cases, after the end of the processing purpose, the processing as such will be restricted in such a way that only the purpose of storage from the laws mentioned as examples can be achieved.

 

8. Data protection rights of data subjects

Every data subject has the right of

• Information (Art. 15 GDPR)
• Correction or deletion (Art. 16 and 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Opposition to processing (Art. 21 GDPR)
• Data transferability (Art. 20 GDPR)

In addition, there is a right of appeal to the Information Commissioner. Should a data subject make use of these rights, we will check whether the legal requirements for this are fulfilled.

Consent to the processing of personal data can be revoked at any time. This also applies to declarations of consent issued to us prior to the validity of the GDPR – i.e. prior to 25.05.2018. It should be noted here that a revocation is only effective for the future. Processing that took place before the revocation remains unaffected.

 

9. Obligation to provide

Within the framework of a business relationship with our company, those personal data are to be provided which are necessary for the initiation, execution and termination of a business relationship and for the fulfilment of the associated obligations or which we are legally obliged to collect. Without this data, it is generally not possible for us to conclude, execute or terminate a contract.

Final Information

Our business operations require that data be collected and processed. Data protection and data security must be guaranteed wherever data is collected and processed. This is more than just a legal requirement for us.

If you require information that is not included in this transparency information, we can be reached via the contact information mentioned at the beginning.

Information on your right of objection under Art. 21 GDPR

• Right of objection in individual cases

You have the right to object at any time, for reasons arising from your individual situation, to the processing of personal data concerning you, which is carried out on the basis of Art. 6 (1) letter f of the GDPR (data processing based on a balancing of interests).

If you object, we will no longer process your personal data, unless we can prove that there are compelling, justified reasons for processing that outweigh your interests, rights and freedoms, or if the processing serves to assert, exercise or defend legal claims

• Right to object to processing for the purpose of direct marketing

In individual cases we process your personal data in order to carry out direct advertising. You have the right to object at any time to the processing of your personal data for the purpose of such advertising.

If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.

• Addressee of an objection

The objection can be made in any form with the subject “Objection”, stating your name and address, and should be sent to

Hitachi Solutions Europe Limited

110 Bishopsgate
23rd Floor
London
United Kingdom
EC2N 4AY

Email: [email protected]