Code of Conduct

Code of Conduct

The “Code of Conduct” elaborates on matters to be complied with by employees and executive officers of Square Enix group (the “Group”) through their duties in relation with customers for the Group’s products and services, shareholders, business partners, and the society, bearing in mind the spirit of “Purpose” and “Values.”

By publicizing this “Code of Conduct,” the Group wishes to pursue business operations and management putting importance on relations with the Group’s stakeholders.

1. General Principles

(1) Ethics
The Group shall offer employees and executive officers with educational and training opportunities so that they conduct fair and equitable businesses with a high level of professional ethics.

(2) Compliance
The Group’s conduct of business shall be fair and lawful strictly in compliance with laws and regulations in the countries, regions and provinces where the Group is doing business, rules of the stock exchange, internal regulations, common law, and custom of trade.

(3) Respect for Human Rights
The Group believes that its business activities must be based on respect for human rights. It therefore strives to fulfill its responsibilities in this regard by promoting Group-wide efforts to respect human rights.
The Group considers this Code of Conduct to be the supreme document governing human rights initiatives within the Group.

(4) Diversity
The Group shall respect and foster diversities of nationality, race, religion, thought and creed, age, gender, sexual orientation, physical condition and so forth through organizational operation and human resource management. The Group shall never discriminate against people based on such traits nor use such traits as the basis of personnel evaluations.

2. Customer Relations

(1) The Best Entertainment
The Group shall make every effort to meet or even exceed customer’s expectations through creation and offering of the best entertainment content.

(2) Personal Data Protection
The Group shall collect customers’ personal data to the minimum extent necessary for provision of respective product or service, store and manage the collected personal data, and use it only for the purposes to which each customer gives prior consent.

(3) Improvement of Customer Satisfaction
The Group shall make sustained efforts to maximize customer satisfaction through content, quality and price of products and services offered to customers. The Group shall also make fair disclosures and representation concerning its products and services so that customers may make a satisfactorily informed choice.

3. Shareholder/Investor Relations

(1) Enhancement of Corporate Governance
The Group shall maintain an optimal and clear allocation of decision-making power among the general shareholders’ meeting, board of directors and management pursuant to laws and regulations, the Articles of Incorporation and internal rules in order to continue corporate management with a focus on shareholder satisfaction as well as effectiveness.

(2) Appropriate Accounting and Fair Disclosure
The Group shall prepare financial statements in accordance with generally-accepted accounting principles in Japan. Square Enix Holdings Co., Ltd. (the “Company”) shall disclose significant managerial information including financial data timely and appropriately in accordance with regulations prescribed by the Tokyo Stock Exchange. Based on such disclosed information, the Company shall promote active dialogue with shareholders and investors.

(3) Shareholder Return
The Company shall attach weight to return to shareholders in order to reward their continuous support to the Company. The Company shall implement appropriate shareholder return such as dividend of surplus that is suitable for the Company’s managerial situation and stock market conditions.

4. Business Partner Relations

(1) Fair Trade
The Group shall apply fair trade conditions to procurement or purchase from third-party vendors based on objective criteria such as price, quality, delivery time, etc. The Group shall pay due attention to vendors’ management conditions and track record.

(2) No Bribery
Employees and executive officers of the Group shall never give nor receive any money and goods, offer nor accept excessive entertainment in relation to transaction under any circumstances. In addition, the Group shall never offer bribes to public officials in any countries and regions.

(3) Prevention of Forced Labor, Child Labor and Slavery
The Group shall prevent forced labor, child labor or slavery in every part of its businesses and supply chains. The Group shall immediately terminate its transactions with any supplier that is found to engage in such unacceptable practices.

5. Employee Relations

(1) Good Working Environment
The Group shall endeavor to maintain a wholesome and comfortable working environment, and also implement measures to maintain the safety and health of its employees. The Group shall never tolerate any harassing behaviors including so-called power harassment in the workplace. Furthermore, the Group shall appropriately manage employees’ working hours giving consideration to employees’ work-life balance.

(2) Fair Assessment and Treatment
The Group has established a personnel system to promote the growth and satisfaction of its employees. Under the personnel system, employees are evaluated and treated in accordance with clear rules, objective appraisal standards and fair process.

(3) Whistle-blowing System
The Group has introduced the whistle-blowing system. The system provides independent and neutral contact channels for employees who are aware of any conduct against laws or internal rules (including this Code) or any other misconduct, or are subject to such wrongdoing. The system has established a rule that the whistle-blowing employee shall not be treated disadvantageously.

6. Society Relations

(1) Respect for Intellectual Properties
The Group considers intellectual properties as a source of value of a content provider. In this light, the Group shall pay respect to third parties’ intellectual properties. The Group shall provide appropriate protection for its own intellectual properties in accordance with laws and contracts. The Group shall also offer reasonable incentive to employees for their creations and inventions in order to enrich own intellectual properties.

(2) No Insider Trading
Employees and executive officers of the Group shall never engage in trading of listed stocks that may fall under the category of insider trading under laws and regulations in any countries and regions. To this end, the Group shall strictly store and manage its own undisclosed significant information as well as third parties’ such information to which the Group has access through business operations.

(3) No Deal with Antisocial Forces
The Group shall never have relations with antisocial forces or any party under their influence nor enter into transaction with them. The Group shall never respond to their unwarranted demand.

(4) Contribution to Society through Sustained Growth
The Group shall strive to achieve sustainable growth of the enterprise while delivering appropriate profits. The Group wishes to make an active contribution to the stability and prosperity of the world through the provision of products and services, shareholder returns, employment, tax payments, and so forth. Furthermore, the Group shall strive to save energy and resources in operating its businesses in order to minimize any negative effects on the global environment.

(5) Respect for Human Rights

  • The Group and its employees (all employees including directors, auditors, executive officers, outside directors, part-time staff, contract employees, and temporary staff) shall take steps to ensure respect for human rights as set forth in this Code of Conduct. The Group expects all parties concerned, including the Group's customers, shareholders, investors, and business partners, to understand and cooperate in respecting human rights.
  • The Group respects the human rights enumerated in the United Nations' International Bill of Human Rights (the Universal Declaration of Human Rights and the International Covenants on Human Rights) and in the International Labour Organization's ILO Declaration on Fundamental Principles and Rights at Work.
  • The Group complies with applicable laws in the countries and regions in which it operates. However, in cases where there is conflict between national or regional laws and international human rights principles, the Group shall seek ways to respect internationally recognized human rights.
  • The Group shall continue to provide appropriate education to Group employees to effectively implement this Code.
  • The Group shall establish and maintain a human rights due diligence process to identify and prevent or mitigate adverse human rights impacts. In addition, the Group shall continue to examine its human rights due diligence methods and their outcomes in order to ensure adverse human rights impacts are effectively addressed. The Group shall also continue to objectively assess potential adverse human rights impacts arising from its business activities, taking into consideration the views of external experts. It shall undertake appropriate actions in response, including revising this Code when necessary.
  • The Group has established a contact point for customers to share their opinions and requests, as well as a contact point for other external stakeholders.
  • In the event that the Group's business activities cause or exacerbate adverse human rights impacts, the Group shall strive to seek resolution by engaging in appropriate corrective and remedial procedures and dialogue aimed at preventing or mitigating such impacts. The Group urges appropriate action to be taken to prevent or mitigate adverse human rights impacts directly linked to the Group's business, products, or services as a result of a business relationship with a partner, supplier, or otherwise.
  • The Group strives to respond appropriately to any human rights issues relating to its business activities by engaging in ongoing dialogue and discussion with relevant stakeholders to address actual or potential adverse human rights impacts.
  • The Group reports on the progress and results of its human rights efforts on the Company website and through other media.

  • January 25, 2008: Implemented "Code of Conduct."
  • November 6, 2015: Released fully revised version of its "Code of Conduct" placing greater emphasis on relations with its stakeholders in conjunction with the June 2015 introduction of the Corporate Governance Code.
  • April 1, 2017: Released partially revised version of "Code of Conduct" in response to recent social conditions and needs.
  • May 13, 2024: Released partially revised version of "Code of Conduct" in order to promote respect for Human Rights within the Group.