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    Group Code of Conduct

    Group Code of Conduct

    Employees will act with fairness, honesty, respect, integrity and good faith in their dealings with the group’s employees, shareholder(s), customers and the wider community.

    • 1.Working Together
    • 2.Conflicts
    • 3.Best Business Practices
    • 4.Society and Us
    • 5.Keep it Legal
    • 1.Working Together
      • Employees
      • Employment Practices
      • No Hostile Conduct
      • Healthy Balance between Personal Life and Work
      • Health, Safety and Environment
    • 2.Conflicts
      • Conflict of Interest
      • Related Party Transactions
      • Giving or Accepting Gifts, Gratitudes or other Benefits
      • Insider Trading
    • 3.Best Business Practices
      • Conducting Business Overseas
      • Human Trafficking and Modern Slavery
      • Competition
      • Confidential Information
      • Financial controls
    • 4.Society and Us
      • Shareholder(s)
      • Customers
      • No Relationships with Antisocial Forces
      • Electronic Communications and Social Media
    • 5.Keep it Legal
      • Compliance with Laws and Regulations
      • Whistleblower Policy
      • Compliance and Breaches of the Code of Conduct

    1.Working Together

    • Employees
    • Employment Practices
    • No Hostile Conduct
    • Healthy Balance between Personal Life and Work
    • Health, Safety and Environment

    Employees

    The PERSOL group of companies will respect the rights of our employees, encourage their input and suggestions, and ensure they are treated in a fair and honest manner, free from harassment, hostility and offensive behaviour.

    The PERSOL group of companies expects our employees to:

    • a)perform their duties with skill, honesty, care and diligence, using authority in a fair and equitable manner;
    • b)abide by policies and procedures, instructions and lawful directions that relate to their employment and duties;
    • c)ensure they take all reasonable care to secure their own safety and health while at work and to avoid jeopardising the safety and health of others;
    • d)provide accurate information, give prompt attention and not discriminate on any unlawful grounds when dealing with people in the course of their duties;
    • e)treat all people they deal with in the course of their employment with sensitivity and courtesy;
    • f)behave in a manner that maintains or enhances the companies’ reputation; and
    • g)comply at all times with the laws and regulations that govern our business and activities.

    Employment Practices

    The PERSOL group of companies will maintain employment procedures and policies that accord with best practice, including those that relate to equal opportunity, selection on merit, anti-discrimination and conflict of interest.

    Employees must respect “differences” (gender, sexual orientation, race, nationality, creed, religion, disabilities etc.) and believe it is important to actively leverage those differences. All employees must be aware of equal opportunity and diversity policies and the responsibility this places on them to respect the rights of individuals.
    By maintaining workplace environments where it is easy for individuals to work, new concepts and value are generated which enables us to provide flexible approaches towards changing business environments and diversification of customer needs.

    No Hostile Conduct

    Any hostile conduct directed at an individual based on his or her race, age, religion, nationality or disability is expressly prohibited. Sexual advances, requests for sexual favours, other unwanted verbal or physical conduct or communication of a sexual nature is considered inappropriate behavior in the workplace and it will not be tolerated.

    All employees are responsible for upholding this policy and eliminating any practices or behaviour which are discriminatory or could lead to discrimination, workplace bullying or harassment.

    Healthy Balance between Personal Life and Work

    Achieving a balance between personal life and work life is indispensable to all of us enjoying full and rewarding lives. For that reason, it is important that all employees maintain healthy workplace environments, and foster a culture of mutually helping and supporting each other.

    Health, Safety and Environment

    The PERSOL group of companies is committed to the goal of a zero harm workplace. Accordingly, all employees must be committed to continuously improving our workplace health, safety and environmental performance.
    Safety is an integral part of our everyday activities. This requires both our organisation and all employees to behave safely at all times.

    2.Conflicts

    • Conflict of Interest
    • Related Party Transactions
    • Giving or Accepting Gifts, Gratitudes or other Benefits
    • Insider Trading

    Conflict of Interest

    Potential for conflict of interest arises when an employee could be influenced, or could be perceived to be influenced, by a personal interest when carrying out his or her duties. A conflict of interest that leads to biased decision-making may constitute illegal or unethical conduct.

    Situations that may give rise to a conflict of interest include where an employee has:

    • a)a financial interest in a transaction or a matter with which a PERSOL group company is involved;
    • b)friends or relatives who have a financial interest in a transaction or a matter with which a PERSOL group company is involved;
    • c)directorship/management/ownership or part ownership/shareholding greater than 5% of an external enterprise that a PERSOL group company engages or contracts with;
    • d)engaging a contractor or supplier to PERSOL group company on non-commercial terms for a personal job or under circumstances where you are a decision maker or influencer in the award of work by a PERSOL group company to this supplier or contractor;
    • e)personal relationships with people a PERSOL group company is dealing with, which go beyond the level of a professional working relationship;
    • f)secondary employment, business, commercial, or other activities outside the workplace which impact on an employee's duty and obligations to a PERSOL group company;
    • g)access to information that can be used for personal gain; and
    • h)received, or is aware of, an offer of an inducement.

    If employees are in a situation where they may be the only person aware of the potential for conflict it is their responsibility to avoid any conflict that could compromise their ability to perform their duties impartially, and to attempt to resolve any conflict that may exist.

    If an employee becomes aware of any potential or actual conflict of interest, or if the employee is uncertain whether a conflict exists, or if they become aware that a bribe or improper inducement has been offered, the employee must report the matter in accordance with each company’s policy.

    Related Party Transactions

    Hiring, promoting or directly supervising a family member or close friend or participating decision-making regarding potential or existing business relationships that involve a family member or close friend, may be a conflict of interest and we must report the matter in accordance with each company’s policy.

    Giving or Accepting Gifts, Gratitudes or other Benefits

    Employees are prohibited from giving or receiving any sort of improper gift, gratuity or payment, loan or benefit, directly or indirectly, in order to give or obtain an advantage, or improperly influencing a decision to secure an advantage, be it personal or business. Employees must not submit or accept any bribe or other improper inducement.

    Insider Trading

    Sometimes employees may have access to material non-public confidential information relating to the PERSOL group of companies or their clients/partners. In those circumstances, the employees are not permitted to use or share the information for securities trading purposes or for any other purpose except the conduct of the companies’ business.

    It is always illegal to trade in the securities of PERSOL Holdings Co. Ltd or any related options or other rights while in possession of material non-public information of PERSOL group, and it is also illegal to communicate or “tip” such information to others.

    3.Best Business Practices

    • Conducting Business Overseas
    • Human Trafficking and Modern Slavery
    • Competition
    • Confidential Information
    • Financial controls

    Conducting Business Overseas

    At all times, the PERSOL group of companies’ business affairs and operations should be conducted legally, ethically, and in accordance with community standards of integrity and propriety.
    The PERSOL group of companies recognise that business practices differ in different countries.
    As a responsible corporate citizen, PERSOL and its employees and representatives will comply with this Code and the standards of conduct recognised by Japanese law and international protocols, no matter what country they are in or what local practices may be.

    Human Trafficking and Modern Slavery

    The PERSOL group of companies has a zero-tolerance policy against all forms of human trafficking, modern slavery and related activities. The PERSOL group of companies is committed to protecting against trafficking of any person, including employees and candidates.

    Competition

    All employees have a responsibility to deal fairly with each other and their customers, employees, applicants, candidates and suppliers. No one must take unfair advantage of anyone else through manipulation, concealment, abuse of confidential information, misrepresentation of material facts or any other unfair dealing practices.

    Confidential Information

    All information which is obtained by and/or is disclosed to employees of the PERSOL group companies relating to the business of PERSOL group (including strategic business, trade, commercial information, personal data or personal information) is confidential and is the property of that PERSOL group company unless agreed otherwise.

    All employees must make sure that such information cannot be accessed by unauthorized persons, and it should be stored securely so that it is protected against risks of loss, destruction, modification, or improper disclosure.

    All employees must ensure that information obtained at work or held in a company’s records must not be used to obtain personal financial reward or to gain any other benefit.
    On termination of an employee's employment, no documentation or information relating to the employee's work or to a PERSOL Group company’s business or affairs are to be removed by that employee for any reason, unless otherwise agreed by a manager in advance.
    Releasing confidential documents or information to unauthorised persons is considered misconduct and a breach of this Code.

    Financial controls

    The PERSOL group of companies has established various financial and accounting controls to ensure that assets are protected and used properly. All employees share responsibility for maintaining and complying with these controls and are required to maintain accurate and reliable financial records and reports.

    4.Society and Us

    • Shareholder(s)
    • Customers
    • No Relationships with Antisocial Forces
    • Electronic Communications and Social Media

    Shareholder(s)

    The PERSOL group of companies is committed to reporting the companies’ progress truthfully and accurately. All employees will comply with the spirit as well as the letter of all laws and regulations that govern shareholders’ rights, including the company's disclosure and financial reporting.

    All employees engaged in financial reporting are required to exercise diligence and good faith to maintain accurate and reliable financial records and reports.

    Customers

    All employees have an obligation to use their best efforts to deal with the companies’ customers in a fair and responsible manner and to deliver outstanding service. The PERSOL Group of companies must be committed to providing value its customers and expect to be remunerated fairly for the services they provide.

    No Relationships with Antisocial Forces

    Employees will maintain absolutely no relationships with organized crime etc. or antisocial forces, and shall confront any such elements in a resolute manner.

    Electronic Communications and Social Media

    All employees must ensure that any reference to the company that they include on any non-company, electronic communications (including email or sms) or social media (including, but not limited to, Facebook, LinkedIn, Twitter, blogs or personal websites), must be restricted to factual details of the employee’s position and must not include comments about company or about current or former customers, employees or associates of the company or any PERSOL Group’s confidential information.
    All employees must not send or post material which may cause reputational or detrimental harm to the company or any current or former customers, employees or associates of the company.

    All employees must not send or post material which pose a risk to the health, safety or wellbeing of any current or former employee or breach any bullying policy.

    All employees when using the companies’ electronic communication services (e.g. email, Facebook or other services hosted by a PERSOL group company) must comply with each company’s electronic communications and social media policy.

    5.Keep it Legal

    • Compliance with Laws and Regulations
    • Whistleblower Policy
    • Compliance and Breaches of the Code of Conduct

    Compliance with Laws and Regulations

    All employees must comply with all laws, rules, regulations applicable to the Company including all employment and labour laws, personal data protection laws, anti-bribery laws, insider trading laws, health, safety and environmental laws, and all policies established by the Company.

    Whistleblower Policy

    All employees must raise matters of concern with their supervisors or managers. However, each jurisdiction has a whistleblower policy in the event that an employee should require the legislative protection of a whistleblower regime. In that instance employees must refer to the whistleblower policy as there are measures to provide protection and support for employees who make complaints or disclosures are included in the policy. A copy of the policy is available at on the intranet and/or company website.

    Compliance and Breaches of the Code of Conduct

    All employees are responsible for observing this Code and for ensuring it is not breached.

    The PERSOL Group of companies promotes an open working environment in which all employees are able to report instances of unethical, improper, unlawful or undesirable conduct without fear of intimidation or reprisal. Any employee who, in good faith, makes a complaint or disclosure about an alleged breach of the Code and follows the reporting procedure will not be disadvantaged or prejudiced making the disclosure. Any report made by an employee in good faith will be acted upon; a prompt investigation will take place and the employee will be informed of the outcome. The particular circumstances of each case will determine the level of detail reported to the employee.

    If an employee breaches the Code or any of the policies and procedures (or gives permission or allows another employee to breach them) they may be subject to disciplinary action which may include termination of employment.

    If an employees is in doubt, or if an employee has any questions about their responsibilities or the Code, it is the employee’s responsibility to seek clarification from their relevant manager or each company’s compliance team. Employees may discuss a matter, or seek advice on how to proceed with a matter, at any time.

    This Code operates in conjunction with all other applicable company policies, standards and procedures.