Supplier Code of Conduct

As a global solutions company, Hitachi Consulting Corporation (“Hitachi Consulting” or the “Company”) is committed to maintaining the highest standards of ethics and integrity throughout its business practices and relationships. To encourage and facilitate ethical conduct, Hitachi Consulting has established company standards of business practices and regulatory compliance called the Hitachi Global Compliance Program (“HGCP”) which applies to all Hitachi Consulting employees, directors, and officers.

Hitachi Consulting expects that its suppliers will similarly share and embrace the letter and spirit of our commitment to integrity. We understand that suppliers are independent entities; however, the business practices and actions of a supplier may impact and/or reflect upon Hitachi Consulting. This Supplier Code of Conduct (the “Code”) contains the standards of ethical and professional practices with which we expect our suppliers to comply and which operate as an extension of our corporate values.

Hitachi Consulting expects all suppliers and their employees, agents, and subcontractors (suppliers’ employees, agents, and subcontractors shall hereinafter be referred to collectively as “Representatives”) to adhere to the Code while they are conducting business with and/or on behalf of Hitachi Consulting. All Hitachi Consulting suppliers should educate their Representatives to ensure they understand and comply with the Code.

Our relationship with our suppliers is an integral part of our business. We strive to build good working relationships with our suppliers and will choose products or services based on their overall merit. This is comprised of a number of components, including but not limited to reputation for service and corporate integrity, socially responsible practices, competitiveness of price, quality of products and services, and responsiveness.

Thank you for adhering to our Supplier Code of Conduct in your business with us. If you have any questions about anything contained herein, please direct them to:

SupplierCodeQuestions@hitachiconsulting.com.

Anti-Discrimination: Hitachi Consulting suppliers may not engage in discriminatory personnel practices, including practices related, but not limited, to hiring, promotion, demotion, evaluation, transfer, recruitment, advertisement, lay-off, termination, compensation, selection for training, and employee benefits. Suppliers must not discriminate on the basis of race, color, ancestry, place of origin, ethnic origin, religion, citizenship, gender, gender identity/expression, sexual orientation, age, marital status, handicap, or any other category protected by law.

Harassment-Free and Bully-Free Workplace: Hitachi Consulting suppliers must maintain a zero- tolerance position toward workplace violence and threats, sexual harassment and any other form of workplace conduct that is prohibited by applicable law. Hitachi Consulting suppliers must prohibit personnel in supervisory roles from threatening or insinuating, either explicitly or implicitly, that an employee’s submission to or rejection of sexual advances will in any way influence any personnel decision regarding that employee’s employment, wages, assigned duties, advancement, career development, or any other condition of employment. Suppliers must comply with Hitachi Consulting’s commitment to maintain work environments free of intimidation, hostility, degradation and humiliation. Hitachi Consulting suppliers must not subject any of their employees to any form of retaliation as a result of making a complaint or report of bullying, harassment, or other form of discrimination or assisting or cooperating with an investigation into such matters.

Freedom of Association and Collective Bargaining: Hitachi Consulting suppliers must respect and recognize the rights of employees to freely join or refrain from joining worker organizations of their choosing and entering into collective bargaining as permitted by law applicable to the suppliers.

Forced Labor: Hitachi Consulting suppliers may not use chattel slaves, forced or bonded labor, coerced prison labor, or impermissible child labor in the performance of their business with Hitachi Consulting. Suppliers must allow their employees the freedom to terminate their employment with reasonable notice and without unlawful penalty.

Wage and Hour: Hitachi Consulting suppliers must adhere to all applicable wage and hour laws. If applicable, supplier employees must not be required to work more than the maximum work week hours as provided by local law, including overtime. Our suppliers’ employees must be paid at least minimum wage as set by local and applicable laws and regulations, and must be compensated for overtime hours at the rate required by applicable local laws and regulations. Our suppliers must keep employee records in accordance with local and national laws or regulations and provide in a timely manner, via pay stub or similar documentation, the basis on which employees are being paid.

Health and Safety: Hitachi Consulting suppliers must comply with all applicable safety regulations, including governmental requirements, operations- and facility-specific safety requirements, and contractual requirements, and consult with employees as necessary on matters affecting their health and safety. Suppliers must also take the necessary precautions to protect against workplace injuries and occupational disease, and provide a safe and healthy working environment free of the effects of alcohol and drug use.

Immigration: Hitachi Consulting suppliers must comply with all applicable immigration laws in the countries in which their employees work. Our suppliers’ employees must possess valid and current authorization to work in their country of employment or the appropriate visas and work permits to work outside their home country as necessary in support of the supplier’s supply of goods or services to Hitachi Consulting.

Required Training and/or Policy Acknowledgement: Employees of Hitachi Consulting suppliers must take all Hitachi Consulting training and/or acknowledge their understanding of and compliance with Hitachi Consulting’s policies regarding employment practices and conduct where required by the nature of the supplier’s services provided to the Company.

Hitachi Consulting suppliers must comply with all applicable environmental laws, standards and regulations, and use reasonable efforts to limit negative impact on the environment.

Legal and Regulatory Compliance: Hitachi Consulting suppliers must comply with all laws applicable to their business with Hitachi Consulting and must be honest, direct, and truthful in discussions with regulatory agency representatives and government officials in connection with such business.

Anti-Bribery: Hitachi Consulting suppliers must comply with the US Foreign Corrupt Practices Act (the “Act”) and all other applicable anti-bribery laws in the jurisdictions in which business is conducted. The Act prohibits giving money or other things of value to government officials or government representatives (which also includes political parties, party officials and any candidate for political office) for the purpose of obtaining or retaining business or gaining an improper advantage. Suppliers must not offer, authorize, promise, demand, give or accept any impermissible gift, fee, reward, loan or other advantage to or from any person for any such purpose, and must not offer bribes, kickbacks, or any other kinds of improper payment to government/public officials or others, for, in the name of, on behalf of or in any other way related to their business with Hitachi Consulting.

Competition and Fair Trading Laws: Hitachi Consulting suppliers must comply with all applicable antitrust, competition and fair trading laws wherever they do business.

Export Laws: Hitachi Consulting suppliers must comply with any and all applicable export laws and regulations in their interaction with the Company. Suppliers must not transfer technical information or products, including software, to particular named countries or to nationals of those countries, when it is prohibited by export laws to do so, or to prohibited parties. Suppliers must not sell, transfer or otherwise use any technical information or products in violation of U.S. or other applicable export laws or regulations, or make any such information or products available to or for any entity or end use that is engaged in the design, development, production, stockpiling or use of nuclear, biological or chemical weapons or missile technology or to any entity with a specific end use related to conventional weapons or any other military activities. Hitachi Consulting suppliers must not participate in international boycotts that are not sanctioned by the U.S. government.

Data Privacy and Confidentiality: Hitachi Consulting suppliers must comply with applicable privacy and data protections laws and regulations in the respective countries of operation, as well as secure Company and personal data and prohibit its unauthorized access, disclosure or use. Suppliers shall receive confidential information only as authorized by a Non-Disclosure Agreement with Hitachi Consulting, and must comply with the obligations therein. Hitachi Consulting suppliers must avoid insider trading by buying or selling Hitachi, Ltd.’s or another company’s stock when in possession of information about Hitachi, Ltd. or such other company that is not available to the investing public and that could influence an investor’s decision to buy or sell stock.

Conflicts of Interest: Hitachi Consulting suppliers must avoid the appearance of or actual improprieties and/or conflicts of interests. Suppliers and/or their Representatives shall not deal directly with any Hitachi Consulting employee whose spouse, domestic partner, or other family member or relative holds a significant financial interest in the supplier. Dealing directly in the course of negotiating the supplier agreement or performing the supplier’s obligations with a spouse, domestic partner, or other family member or relative who is employed by Hitachi Consulting is also prohibited.

Authorized IT Use: Hitachi Consulting suppliers must use Hitachi Consulting-provided information technology and systems (including e-mail), if any, only for authorized Hitachi Consulting business-related purposes. Hitachi Consulting strictly prohibits suppliers and their Representatives from using Hitachi Consulting-provided technology and systems to create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise illegal, offensive or inappropriate and/or to send any false, derogatory, or malicious communications.

Authorized Software and Hardware Use: Hitachi Consulting suppliers must use software, hardware and content only in accordance with their associated license or terms of use and applicable copyright laws.

IT Security: Hitachi Consulting suppliers must comply with all Hitachi Consulting requirements for maintenance of passwords, confidentiality, security, cybersecurity, and privacy procedures as a condition of providing Hitachi Consulting with goods or services or receiving access, if any, to Hitachi Consulting’s internal corporate network, systems and offices. All data stored or transmitted on Hitachi Consulting owned or leased equipment is to be considered private and is the property of Hitachi Consulting. Hitachi Consulting may monitor all use of its corporate networks and all systems (including e-mail) and/or access all data stored or transmitted using the Hitachi Consulting network, subject to applicable law.

Communication with the Press: Hitachi Consulting suppliers must not speak to the press on Hitachi Consulting’s behalf unless the supplier and/or Representative(s) is expressly authorized in writing to do so by Hitachi Consulting.

Compliance with Terms and Conditions of Hitachi Consulting contracts: Hitachi Consulting suppliers must comply with all terms and conditions, specifications and requirements as provided in their agreement with Hitachi Consulting.

Accuracy of Proposals and Invoices: Hitachi Consulting suppliers must take care to submit truthful and accurate proposals, bids, and invoices, and be certain that their communications, including statements and representations, are truthful and accurate to the best of their knowledge. Suppliers must promptly correct errors in invoices.

Record Retention: Hitachi Consulting suppliers must create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements.

It is crucial that each Hitachi Consulting supplier engaged with the Company fully understands and complies with this Code during the course of its business with the Company. This Code cannot anticipate every possible situation or cover every topic in detail; suppliers should behave in an ethical manner and use sound judgment in all of their business operations and decisions. Each supplier’s commitment to ethical behavior and this Code is essential in order for the Company to maintain the highest degree of honesty and integrity in its supplier relations and in its operations.

Hitachi Consulting reserves the right to terminate business with any supplier that fails to comply with these standards or with applicable laws and regulations. Hitachi Consulting may also refer acts and omissions in violation of applicable laws and regulations to local authorities.

The existence of this Code, and the standards contained herein, do not render Hitachi Consulting liable for any violation of laws and regulations or other act or omission by the supplier. The terms and conditions of the employment of supplier employees shall continue to be the sole responsibility of the supplier. Access to this Code or to other Company policies, and receipt of any Company training, in no way implies that supplier employees are employees of Hitachi Consulting or that Hitachi Consulting is responsible for the conduct of suppliers or their employees or representatives.

If you wish to report questionable behavior or possible violation of the Supplier Code of Conduct, Hitachi Consulting has a variety of resources available to assist you. You are encouraged to work first with your primary Hitachi Consulting contact in resolving a business practice or compliance concern.

Hitachi Consulting will not tolerate any retribution or retaliation taken against any individual who has, in good faith, sought out advice or reported questionable behavior and/or a possible violation.