Corporate Ethics and Compliance

Policy on Corporate Ethics and Compliance

Corporate Ethics and Compliance is positioned as one of our Material Foundations for Corporate Activities to increase corporate value in a sustainable manner by prospering together with all stakeholders. The Company views corporate ethics and compliance as a fundamental prerequisite for our corporate activities, and defines it as meeting society’s expectations and demands through appropriate action both as a company and as individuals, beyond the framework of solely legal compliance.

The Board of Directors of the Company established the "Recruit Group Code of Ethics" as universal guidelines that govern our conduct. The Code of Ethics describes certain fundamental legal and ethical practices that all senior management, employees, including contract employees, and temporary staff of the Company are required to follow. All of these employees are informed of the Code of Ethics, and the Company plans and conducts necessary training for them to ensure compliance with the Code of Ethics and internal policies.

The Board of Directors also has the "Recruit Group Compliance Policy" in place as a basic policy regarding the Company’s compliance activities, and monitors their effectiveness.

Systems and mechanisms for Corporate Ethics and Compliance

Compliance Committee

An advisory body to the Board of Directors chaired by the President, CEO, and Representative Director of the Board. The Committee deliberates on compliance themes and measures of the Company. The Committee decides and evaluates action plans based on the information collected from the Holding Company’s administrative departments and subsidiaries. The Compliance Committee’s deliberations and decisions are reported to the Board of Directors to promote compliance mindset within the Company.

Whistleblower System and Protection

Recruit Holdings and its subsidiaries have whistleblower systems in place.

The whistleblower system is available for all employees including contract employees, temporary staff, and full-time partners working in Recruit Group to report if they are being unfairly treated during work or in the workplace. They can also use the hotlines when they, from a third-party perspective, find or sense misconduct or unjust treatment, such as bribery, corruption, unfair competition, data leakage, conflict of interest, insider trading, bullying, or harassment.

Recruit Holdings and its subsidiaries take various initiatives to ensure all of our people know these hotlines are readily available for them.

All of the hotlines are confidential reporting channels. The Recruit Group Compliance Policy, resolved by the Board of Directors, ensures the anonymity and protection of all whistleblowers by prohibiting any retaliation including dismissal or unfair transfer, against any whistleblower for making a good-faith compliance report. The policy also stipulates respect for the privacy of whistleblowers, and ensures that the information of the whistleblower and the details of the report will not be disclosed to anyone beyond the extent necessary to handle the matter without the prior permission of the whistleblower in question, so that they will not suffer any disadvantage because of reporting under this system.

Recruit Holdings also provides access to a third-party operated external hotline as a whistleblower system for all employees including contract employees and temporary staff, so that more people can easily access the whistleblower system. Only upon approval by the whistleblower, the contents of their report filed via the external hotline are shared directly with Recruit Holdings’ Audit & Supervisory Board members.

Our whistleblower system also offers hotlines for those outside the Recruit Group, including our partners and clients, on our official website.

Employee Training on Ethical Standards and Compliance

The Company has policies of providing education to all employees based on the Code of Ethics and to convey the importance of compliance directly from the management of subsidiaries to their employees.

For example, Recruit Holdings and its main subsidiaries in Japan have comprehension tests and other employee training programs in place for all employees including contract workers and temporary staff. They cover areas of misconduct and unjust treatment, such as bribery, corruption, unfair competition, data security & privacy, conflict of interest, insider trading and human rights to avoid bullying and harassment. To educate employees on social and company rules, we include training on potential situations that employees are likely to encounter and how to handle them. We also provide compliance training for particular positions, such as training on the handling of instances of bullying or harassment or reports thereof for newly appointed managers.

Each subsidiary also has necessary company-level compliance training in place that best fits its business.

Initiatives to Improve Corporate Ethics and Compliance

Prevention of Bribery

The Company prevents bribery according to the Recruit Group Compliance Policy resolved by the Board of Directors. The Policy stipulates compliance with relevant laws and regulations to maintain proper relationships with politicians and public officers, specifically setting forth prohibited acts. The prohibited acts include providing, either directly or indirectly, offering or promising to provide, or accepting any money or other things of value to acquire a wrongful gain in business.

Insider Trading Prevention Rules

The Company has the Recruit Group Insider Trading Prevention Policy for all officers and employees across the Group to ensure they never communicate matters that may amount to material nonpublic information or recommend trades of specific investment securities to third parties. Our compliance initiatives promote social and ethical responsibility among officers and employees, ensuring trust in our group.

Exclusion of Antisocial Forces

The Recruit Group Code of Ethics clearly states our policy of having no involvement whatsoever with organized crime, crime syndicates, and other antisocial organizations. The Recruit Group Compliance Policy further stipulates that the Company will not maintain any connection with antisocial forces, as defined by the Japanese government, including business relations, will develop regulations regarding what steps to take if a case should arise, and will act resolutely against unreasonable demands in accordance with the law, designating a department to oversee such responses and cooperating with outside expert organizations. These principles are upheld by all our officers and employees.

For more details, please refer to “Corporate Ethics and Compliance” in the ESG Data Book.