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    Compliance

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    Basic Approach of Compliance

    The PERSOL Group views compliance as meeting the demands and expectations of society and conducting business activities with integrity.

    Based on this view, the PERSOL Group established the PERSOL Group Code of Conduct in November 2019.
    This Code of Conduct sets out the basic behaviors based on compliance required of all officers and employees of the PERSOL Group, both in Japan and abroad.
    We will act with high ethical standards and integrity based on the PERSOL Group Code of Conduct in order to continue to be trusted by our customers and society.

    Group Code of Conduct

    Compliance Execution Structure

    The PERSOL Group has established the Group GRC Division within PERSOL HOLDINGS to formulate basic compliance policies for the Group and to execute compliance to Group companies.
    In addition, the Internal Control Implementation Manager, who are designated at core companies of each SBU and FU, support Group companies to execute compliance and compliance measures.

     

    ※ SBU：Strategic Business Unit，FU：Function Unit，GRC：Governance,Risk,Compliance

    Efforts to Raise Employee Awareness

    The PERSOL Group implements the following measures to raise awareness toward compliance among Group employees and to educate and enlighten various compliance items.

    ■Publication of Compliance Handbook

    We have prepared a Compliance Handbook for 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 directors 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 Results for fiscal year ended March 31, 2020
    Compliance training for all employees raining for all employees of the PERSOL Group (once a year) Entire Group Number of employees who completed training during the period:
    25,811 employees
    Legal newsletter Dissemination of legal knowledge related to the business through the Intranet Entire Group Number of times distributed:
    3 times
    New graduate training Training for new graduates when they join the Group Entire Group Number of participants in the joint company joining ceremony: 978 participants
    Mid-career hire training Training for mid-career hires when they join the Group Entire Group Conducted at each Group company as necessary
    Newly appointed manager training Training for managers (section manager level) upon promotion Entire Group Number of participants: 227 participants
    Number of times conducted: 2 times
    Training for executives of PERSOL Holdings Training for PERSOL HOLDINGS Directors and executive officer PERSOL HOLDINGS

    ■Compliance Awareness Survey

    We prepare and conduct an annual compliance awareness survey on all Group employees in order to continuously monitor the instilling and establishment of compliance activities.
    The results of the survey are analyzed and evaluated by the Risk Compliance Division, and then reported to management and the Human Resources Planning Division, where they are used as a reference for executing compliance management by considering the introduction of new compliance execution measures for items that need to be improved, and aiming to further improve items that are outstanding.

    Establishment of the Corporate Ethics Hotline for Whistleblowing

    The PERSOL Group has established a Corporate Ethics Hotline operated by an external agency in order to receive whistleblowing and consultations from employees regarding activities that may constitute a violation of laws and regulations.
    The Corporate Ethics Hotline accepts anonymous reports. In addition, with an officer in charge of compliance of PERSOL HOLDINGS as the responsible personnel, Risk Compliance Office has implemented and operated a system for responding to whistleblowing, in order to appropriately conduct inspections, implement corrective measures, and formulate measures to prevent recurrence on a group-wide basis.

    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 Basic Policy on Information Security and the Policy on the Protection of Personal Information, and will disclose it on our website and other media in an effort to build a continuous relationship of trust with stakeholders.

    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

    At 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 Group GRC division will cooperate with external organizations to deal with it organizationally.