Anti-Corruption Policy
Mynavi Group Anti-Corruption Policy
Based on its purpose of “To create a world that envisions the future by engaging individual potential,” the Mynavi Group has established the following Anti-Corruption Policy (hereinafter referred to as “this Policy”) with the aim of ensuring trust from stakeholders and society at large by clearly articulating and promoting the policies that officers and employees (hereinafter referred to as “officers and employees”) should use as a foothold regarding anti-corruption initiatives in order to conduct free and fair transactions with business partners.
The Mynavi Group also requests its business partners and other parties to advance these initiatives concerning the prevention of corrupt practices.
Compliance with Laws, Regulations and Internal Rules
The Mynavi Group complies with the Unfair Competition Prevention Act of Japan, together with laws and regulations related to the prevention of corrupt practices, including bribery, that may apply in the countries and regions where it conducts business activities, as well as related internal regulations. We also strive to understand the intent of the laws and regulations applicable to our overseas subsidiaries in each region and to prevent any circumstances that would conflict with such laws and related rules.
Creation and Retention of Records
The Mynavi Group accurately records all of its transactions in its accounting books based on facts and retains these records appropriately.
Prohibition of Corrupt Practices
The Mynavi Group will not engage in any form of corrupt practices (including bribery, corruption, money laundering, embezzlement and fraud) or be complicit in any such practices, whether directly or indirectly, with public officials, persons in equivalent positions, or other business operators, whether in Japan or overseas. We also require our agents, contractors, business partners, and others (hereinafter referred to as “business partners, etc.”) to comply with this Policy, and we will not tolerate or condone corrupt practices.
In addition, we will not instruct corrupt practices through business partners, etc.
Lawful Entertainment and Gifts, etc.
The Mynavi Group appropriately manages entertainment, gifts, travel expenses, donations, support or sponsorships between stakeholders that are for legitimate business purposes and offered lawfully, in accordance with relevant rules, etc.
Enhancement of Awareness, Education and Training
In addition, to further instill ethical awareness for preventing corruption and to maintain and improve our anti-corruption system, we conduct regular educational training programs and related initiatives.
Establishment and Operation of an Internal Reporting Hotline
In the event that the Mynavi Group becomes aware of acts or suspected acts in violation of this Policy, relevant regulations, or relevant laws and regulations, it will make use of the internal reporting hotline and other mechanisms, confirm the facts in good faith while confirming with the reporter, and implement necessary corrective measures.
Measures for Violations, etc.
Additionally, in the event a violation is identified, an investigation will be conducted promptly, and corrective measures and recurrence prevention measures will be taken before reporting it to the Board of Directors. In addition, if fraudulent activity by a business partner or agent, etc. is confirmed, transactions will be suspended as appropriate to the circumstances.