Basic Approach of Compliance
The PERSOL Group views compliance as meeting the demands and expectations of society and conducting business activities with integrity.
To make this idea a reality, we have formulated the PERSOL Group Code of Conduct to be observed by all officers and employees of the PERSOL Group in Japan and overseas.
This Code of Conduct sets out basic behaviors based on compliance.
To remain trusted by customers and society, we will act with integrity and high ethical standards based on this Code of Conduct.
Compliance Promotion Structure
The PERSOL Group has established the Compliance Control Department within PERSOL HOLDINGS to promote and monitor compliance for the entire Group.
Additionally, each SBU and FU core company’s appointed Internal Control Implementation Managers support the full understanding and practice of compliance across all Group companies.
Efforts to Raise Compliance Awareness of Officers and Employees
The PERSOL Group implements the following measures to raise the compliance awareness of officers and employees and to educate and enlighten them on various legal compliance items.
Publication of Compliance Handbook
We have prepared a Compliance Handbook for officers and employees as a guide to clarify how they should behave from the perspective of corporate ethics and compliance, and we utilize the Handbook to educate our employees about compliance.
Education and Training
Various compliance training sessions are held for officers and employees.
In addition to the following, we also conduct education and training programs at each Group company tailored to each business and region to raise awareness of compliance across the Group.
| Name | Details | Scope | FY2023 Result |
|---|---|---|---|
| Compliance training for all officers and employees | Training for all officers and employees of the PERSOL Group(once a year) | Group companies in Japan | Number of people who received training: 37,231 |
| Legal newsletter | Dissemination of legal knowledge related to the business through the Intranet | Group companies in Japan | Number of times distributed: 3 times |
| New graduate training | Onboarding training to educate new graduates on the importance of compliance and what to do when faced with a compliance violation | Group companies in Japan | Number of people who received training: 1,942 |
| Mid-career hire training | Training for mid-career hires to educate them on the PERSOL Group's compliance policy and what to do when faced with a compliance violation | Group companies in Japan | Conducted at each Group company as necessary |
| Newly appointed manager training | Training to educate managers on the concept and attitude of compliance management required of them when they start their managerial positions※ | Group companies in Japan | Number of people who received training: 432 |
Compliance Awareness Survey
We conduct an annual compliance awareness survey of all Group officers and employees in order to continuously monitor the instilling and establishment of compliance activities.
The Compliance Control Department analyzes and evaluates the survey results before reporting them to the Board of Directors, the Headquarters Management Committee (HMC), and the Internal Control Implementation Managers.
We are using the results of the survey as a reference to improve our compliance management, which includes considering the introduction of new compliance promotion measures for areas that require improvement.
Introduction of Whistleblowing System
The PERSOL Group has implemented a whistleblowing system both in Japan and overseas to ensure early detection of compliance violations and prompt corrective action. To raise awareness of the whistleblowing hotline established under this system, we are implementing various measures, including posting notices on the company intranet and conducting training sessions.
In FY2023, awareness of the whistleblowing system reached 83%, and we received 77 whistleblowing reports (including cases that do not fall under whistleblowing under the Whistleblower Protection Act), many of which dealt with labor issues and information handling. By providing training for the whistleblowing officers at each company, we have been able to conduct appropriate investigations and respond effectively to reports received through the whistleblowing system.
Overseas, there has also been progress in reviewing the mechanisms and awareness-raising measures related to whistleblowing systems. We are working to create an environment where officers and employees can use the whistleblowing hotline with even greater confidence than before.
Efforts to Protect Personal Information and Strengthen Our Information Security System
The PERSOL Group properly handles all personal information we keep in accordance with relevant laws, regulations, and codes.
Also, the PERSOL Group has established the PERSOL Group Basic Policy on Information Security and the Personal Data Policy※, Information Security Basic Policy, and will disclose it on our website and other media in an effort to build a continuous relationship of trust with stakeholders.
※The PERSOL Group refers to all information entrusted to us by individuals as "personal data," and our approach to the utilization of personal data based on the "Personal Data Policy," as well as our privacy protection system and initiatives, are explained on our Privacy Center.
In addition, we established CSIRT "PERSOL-SIRT" to protect information assets within the Group from increasingly sophisticated risks of cyber-attacks and information leaks, and to strengthen measures to prevent damage from information security incidents as well as contingency systems. In April 2016, we were registered as a member of the Japan CSIRT Association.
Efforts to Strengthen Our Compliance System
The PERSOL Group is striving to strengthen our compliance system. Legal affairs departments have been established within the Company and at major Group companies to collect, analyze, and disseminate information so that the Company can respond appropriately to revisions of business laws and important related laws and regulations while coordinating and exchanging information.
Efforts to Prevent Corruption
The PERSOL Group, we are actively committed to preventing corruption, such as bribery and conflicts of interest, to promote business operations compliant with the 'PERSOL Group Code of Conduct' and to meet the expectations of our stakeholders. The progress of these efforts is regularly reported to our Board.
We also encourage our business partners to join us in these anti-corruption initiatives.
(1) Compliance with Laws and Regulations
At PERSOL Group, we strictly adhere to laws related to the prevention of corruption, including the Unfair Competition Prevention Act.
We also strive to understand the spirit of these regulations, including the National Public Service Ethics Act and the National Public Service Ethics Code,
ethical regulations set by local governments, as well as the laws and regulations of each region that apply to overseas subsidiaries, ensuring no violation of these laws and regulations.
(2) Proper Accounting Procedures and Documentation
At PERSOL Group, based on a reliable internal control system, we adhere to our responsibility to accurately document expenditures and maintain appropriate accounting records.
This is done in accordance with our commitment to complying with laws and regulations, and our Code of Conduct related to anti-corruption.
(3) Raising Awareness and Enhancing Education and Training
At PERSOL Group, we work diligently to disseminate our Code of Conduct, this policy, and other relevant internal rules by making them accessible at all times through our intranet and other notification materials. Additionally, we continually undertake regular training sessions aimed at further instilling an ethos of ethical conduct and maintaining a strong anti-corruption framework.
(4) Establishment and Operation of Reporting Mechanisms
At PERSOL Group, we take actions that might violate our Code of Conduct, this policy, relevant internal rules, or the laws and regulations seriously. To this end,
we have an established internal reporting mechanism (our Whistleblowing Hotline) that handles every report earnestly, verifying facts and addressing concerns with whistleblowers while taking necessary corrective actions when required.
(5) Disciplinary Action for Violations
If executive officers or employees in the PERSOL Group are found to violate any relevant laws and regulations, our Code of Conduct, or this policy, they are quickly and sternly disciplined in accordance with the Group’s internal rules.
Additionally, any such violations are reported to our Board.
Furthermore, if we discover instances of corruption involving our business partners or agents, we immediately suspend any ongoing transactions with them.
Response to ‘Anti-Social’ Forces
The PERSOL Group responds to ‘Anti-Social’ forces (defined as groups/individuals who commit illegal activities on a continuous basis) with a resolute attitude and will block all these relationships. We will collect related information from the police station in charge and the regional council on the prevention of special violence to prepare for unforeseen circumstances, and in the event of such a situation, the Compliance Control Department will cooperate with external organizations to deal with it organizationally.