Corporate Ethics Helpline

In accordance with the Recruit Group Code of Ethics, Recruit Holdings places the highest priority on compliance with laws and regulations in all of its business activities and is committed to upholding compliant and ethical business practices.

Violations of laws and regulations and other misconduct are serious matters that can jeopardize a company’s growth and even its continued existence. We believe that a whistleblowing mechanism plays an important role in promoting compliance and ethical conduct and maintaining a healthy organizational culture. Recognizing this, we have established the Corporate Ethics Helpline as a reporting and consultation channel to prevent such misconduct, detect it at an early stage, and take appropriate corrective action.

If you discover, have concerns about, or notice any signs of a compliance issue in the course of business with or transactions involving the Recruit Group, such as misconduct or a violation of laws and regulations or internal rules, please contact the Corporate Ethics Helpline.

To ensure everyone can report and consult with peace of mind, Recruit Holdings has engaged an external specialist firm, S.P. Network Co., Ltd., to receive reports and consultations.

1. Who Can Use the Helpline?

The Corporate Ethics Helpline is available to all officers, employees, temporary staff, and freelancers of the Recruit Group, as well as those of any business partners with an ongoing contractual relationship with a Recruit Group company.

You can report or seek advice even after leaving employment or the end of a contract, provided the matter occurred during your employment or contract period. We encourage you to raise any concerns as promptly as possible after becoming aware of them, as it may become more difficult to verify the facts and take appropriate action as time passes.

2. What Can Be Reported or Discussed?

The following conduct, or suspected conduct, related to the Recruit Group’s business activities may be reported or discussed through the Corporate Ethics Helpline:

• A “Reportable Fact”

  defined in Article 2, Paragraph 3 of Japan’s Whistleblower Protection Act that has occurred or is about to occur in relation to the Recruit Group or any of its officers or personnel.

  Examples include intentional leakage of personal information, acceptance of bribes in connection with one’s duties, unreasonable restraint of trade, disclosure of bidding prices, and copyright infringement.

• Any human rights violation or harassment

  by any of the officers or personnel of the Recruit Group committed against individuals described above in “1. Who Can Use the Helpline?”

• Any wrongdoing, violations of laws or regulations, or ethical misconduct.

3. Whistleblower Protection and Safeguards

You can use the Helpline with peace of mind. In accordance with the Whistleblower Protection Act of Japan and its Corporate Ethics Helpline Policy, Recruit Holdings implements the following safeguards to ensure that everyone can use the Helpline without fear of disadvantageous treatment:

• Prohibition of Disadvantageous Treatment:

  No one will face retaliation or any disadvantageous treatment solely for using the Helpline or cooperating with an investigation.

• Prohibition of Attempting to Identify Whistleblowers or Obstruct Reporting:

  We strictly prohibit any

  attempts to identify whistleblowers or obstruct reporting without a justifiable reason. Violations will be subject to appropriate disciplinary action.

• Strict Confidentiality:

  Personnel responsible for helpline operations and investigations will strictly manage all information relating to reports and consultations. Any information that may identify the whistleblower will never be disclosed or divulged beyond the extent necessary to resolve the matter, unless required by law or for another legitimate reason. Personnel designated to handle whistleblower reports are subject to confidentiality obligations under applicable law.

• Avoidance of Conflicts of Interest and Ensuring Impartiality:

  We conduct investigations and responses fairly and impartially. This includes ensuring that any individuals involved in the reported matter do not participate in handling or making decisions concerning that matter.

4. What Will Happen after Reporting or Consulting?

STEP 1: Receipt and Acknowledgment
Your report or consultation will be promptly acknowledged upon receipt.

STEP 2: Fact-Finding and Investigation
Unless there is a legitimate reason not to do so, personnel with no conflict of interest in the matter will coordinate with relevant departments to conduct an appropriate investigation, respecting the privacy of those involved.

STEP 3: Corrective and Preventive Measures
If the investigation identifies an issue, we will promptly take appropriate corrective and preventive measures, as well as disciplinary action.

STEP 4: Notification of Results
We will inform individuals who submitted reports or consultations of the investigation results and actions taken to the extent possible, while respecting the privacy of other individuals involved.

STEP 5: Follow-Up
We will assess the effectiveness of corrective and preventive measures taken, and implement additional measures where necessary.

All those involved are asked to cooperate fully with any investigations conducted by our teams and to refrain from any conduct that may obstruct them.

5. Other Information

When handling whistleblower reports, we create records and retain them for an appropriate period.

Recruit Holdings periodically evaluates and reviews its whistleblowing system, making improvements as necessary. Operational data, including the number of reports and consultations received, is disclosed in the Sustainability Databook. Such disclosures are made with due consideration for personal information and privacy.

For more information, please refer to the “Whistleblower System and Protection” section on our “Corporate Ethics and Compliance” page.