Compliance
Our approach to compliance
The Recruit Group views compliance as a fundamental prerequisite for our business activities, and defines it as "Meeting society's expectations and demands through appropriate action, by both the company and individuals, beyond the framework of legal compliance."
To this end, we put in place the Recruit Group Code of Ethics, which describes certain fundamental legal and ethical practices that all our officers and employees must follow.
We also have the "Recruit Group Compliance Policy" in place as a guideline for our compliance activities.
Systems and mechanisms
Compliance Committee
Recruit Holding's Compliance Committee, chaired by the President and CEO, determines the Recruit Group's compliance strategies, evaluates the effectiveness of group-wide compliance practices, and monitors compliance action plans across the Group.
The Compliance Committee's deliberations and decisions are reported to the Board of Directors.
Whistleblower system
Recruit Holdings and its subsidiaries have whistleblower systems in place.
Hotlines are available for the employees, temporary workers, and full-time partners working in the Group to report that they are 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, and harassment.
All of the hotlines are confidential reporting channels. The Recruit Group Compliance Policy ensures the anonymity of whistleblowers and non-retaliation.
Recruit Holdings and its subsidiaries take various initiatives to ensure all our people know these hotlines are readily available for them.
Recruit Holdings' whistleblower system also offers hotlines for those outside the Group, including a third-party-operated external hotline and a reporting channel for our partners and clients (the 'Contact' page on this official website). When requested by a whistleblower, the contents of their report filed via external hotline are shared directly with Recruit Holding's Audit & Supervisory Board members.
Compliance education for employees
It is Recruit Holdings' policy to provide education for all of our employees across our group and ask each subsidiary's leadership to deliver compliance messages to their employees.
Recruit Holdings and its subsidiaries in Japan have comprehension tests and other employee training programs in place. They cover the areas of misconduct and unjust treatment, such as bribery, corruption, unfair competition, data leakage, conflict of interest, insider trading, bullying, and harassment. Also covered to educate employees with social and company rules are potential situations that employees are prone to encounter, explaining how to handle such situations. We also provide compliance training for particular positions, such as the training on handling of reports or instances of bullying or harassment for newly appointed managers.
Each subsidiary also has necessary company-level compliance training in place that best fits its business.
Other compliance initiatives
Prevention of bribery
Our Board of Directors is responsible for resolving and overseeing the Recruit Group Compliance Policy that includes anti-bribery and anti-corruption. We aim to prevent bribery by maintaining proper relationships with politicians, public officials, and others. These regulations also apply to public officials in other countries.
Insider Trading Prevention Rules
We have the Recruit Group Insider Trading Prevention Policy for all officers and employees across the Group to ensure they would 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
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 force, as defined by the Japanese government, including business relations, develop regulations regarding what steps to take if a case should arise, and 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.