Recruit Group Code of Ethics

In the wake of the shares-for-favors Recruit scandal that first came to light in 1988, we realized that compliance does not refer to merely complying with laws and regulations. Rather, compliance refers to appropriate conduct by a company and its employees that satisfies the expectations of society. Following the Recruit scandal, we established our Management Philosophy, Three Management Principles, and Code of Ethics as universal guidelines that govern our conduct.

Recruit Group code of ethics

This Code of Ethics describes certain fundamental legal and ethical practices that all Recruit Affiliated Persons are required to follow.

Introduction

All Recruit Affiliated Persons have a responsibility to comply with the legal and ethical expectations of each region and society in which we do business and to help the Group earn the trust and respect of each such society.

1. Fulfilling Legal and Ethical Expectations

As part of the Recruit Group, we recognize our responsibility to fulfill the legal and ethical expectations of each society in which we do business. We must always behave in an ethical manner so that we can cultivate trust and respect in all places where we do business. To accomplish this, we consistently focus both on what is good for business and on what is good for the communities in which we live and work.

2. Complying with Laws and Regulations

We must comply with all laws, regulations, and ordinances that apply to us. This is one of the most fundamental responsibilities we have to the societies in which we do business and a key part of our ethical responsibilities.

3. Negotiating and Complying with Agreements

We believe that entering into fair agreements with our customers and other parties, and honoring those agreements, is an important element of ethical behavior. Our agreements must be negotiated and executed in accordance with our rules and processes and supervised by the Legal Department of the applicable company, and all our effective agreements must be securely retained and available to our management.

4. Complying with Fair Competition Laws and Observing Fair Trade Practices

We compete fairly and ethically and comply with antitrust and other laws and regulations regarding fair competition and fair trade practices.

5. Interacting Appropriately with Government Persons

A critical part of our commitment to the societies in which we do business is our compliance with all laws and regulations concerning our relationships with government officials and government offices. To ensure ethical behavior and protect our reputation, we carefully observe anti-corruption and other relevant laws and we avoid acts that may create even the appearance of misconduct or impropriety in connection with interactions with government officials.

6. Safeguarding Confidential and Sensitive Information

• 6.1

  We protect and safeguard confidential and sensitive information that we obtain in connection with our business, regardless of whether the information is obtained from customers, other third parties, or within the Group itself. We do not disclose or use such confidential or sensitive information except for its intended purpose, unless we receive consent from the applicable party.

• 6.2

  To cultivate and maintain trust in the societies in which we do business, it is crucial that we maintain the confidentiality of personal information we obtain in the course of our business. We do not disclose or use such personal information except for its intended purpose, unless we receive consent from the applicable party.

• 6.3

  We do not use non-public information for our personal benefit or any other improper purpose. Furthermore, we do not make improper use of any information produced by the Group that has not yet been publicly disclosed, regardless of whether such use is for our own benefit or the benefit of a third party.

7. Protecting Intellectual Property

Developing and protecting valuable intellectual property is key to the Group's success. We are careful to protect our own intellectual property and not to violate the intellectual property rights of other parties. We avoid actions that might damage the value of the Group's copyrights, trademarks, or other intellectual property. We do not use intellectual property that belongs to third parties without a proper license.

8. Communicating Effectively and Clarifying Responsibilities

We believe that effective communication with customers, business partners, and others with whom we do business is an important element of our success. To reduce the risk of disputes, we communicate clearly with the parties with whom we do business to clarify the scope and allocation of responsibilities in our business relationships. We do not interfere in disputes between third parties when we do not have a sufficient understanding of the dispute.

9. Fulfilling Our Disclosure Obligations as a Public Company

As a public company, it is critical that Recruit Holdings complies with rules and regulations concerning the timely disclosure of material information. Through Recruit Holdings, we publicly disclose material developments in respect of our business when required by applicable law. Furthermore, we immediately report the occurrence of events that are material or may become material to the appropriate department or function within the Group to ensure that Recruit Holdings is able to fulfill its disclosure obligations.

10. Respecting the Rights and Dignity of All People

We respect the human rights and dignity of all people and avoid abusive and discriminatory behavior. We carefully observe all laws regarding workplace harassment and discrimination and strictly prohibit behavior in violation of those laws.

11. Maintaining a Productive Working Environment

Cultivating and maintaining trust, sound judgment, and mutual respect within the Group is essential in creating a work environment where Recruit Affiliated Persons can be effective and efficient. We do not engage in violence, harassment, bullying, abuse of authority, or illegal discrimination in the workplace.

12. Avoiding Relationships with Organized Crime and Similar Parties

We do not do business or otherwise associate with organized crime, crime syndicates, or other anti-social organizations that promote illegal activity.

13. Protecting the Environment

Protection of the environment throughout the world is necessary for the sustainable stable growth of our business. Accordingly, as a Group, we are committed to activities in support of environmental protection such as recycling, and we support proactive participation of our employees in appropriate public affairs activities in their local communities.