Recurrence Prevention Initiatives (mindset and behavior reform)

Regarding the case related to Tokyo 2020 Olympic and Paralympic Games (Tokyo Olympic and Paralympic Games), the Group has established the dentsu Japan Reform Committee on May 15, 2023 and has been working to reform mindset and behavior. And, as of December 18, 2024, all 17 initiatives to prevent recurrence that have been promoted under the dentsu Japan Reform Committee have been completed.

From January 2025, dentsu is promoting Mindset and Behavior Reform Project to develop our previous efforts with the aim of establishing an organizational culture that prioritizes integrity and ensuring a high level of compliance.

Policy on Recurrence Prevention Mindset and Behavior Reform
dentsu Japan Mindset and Behavior Reform Project
Employee survey
The monitoring evaluation by the outside advisors
Efforts of Mindset and Behavior Reform by 2024
Reference: Investigation Report by the Investigation and Review Committee
Reference: ESG Briefing
Reference: News Releases

Policy on Recurrence Prevention

The policies on recurrence prevention that has been in place since the launch of the dentsu Japan Reform Committee are as follows.

Overall Policy: We will enhance our sense of responsibility and transparency toward society, and clarify the rules and processes that must be followed.

• (i)
  Establish a system to reflect the knowledge gained from analyzing, considering and reflecting past cases in our business operations by reviewing business processes to ensure fair transactions, formulating and revising guidelines for the sports domain and public sector, etc., where the aforementioned case originated, introducing information management measures to prevent conflicts of interest with the organizations to which employees are seconded, etc.
• (ii)
  Reexamine established policies and internal reporting systems periodically and improve the effectiveness of internal controls. In particular, strengthen the checking and monitoring functions by establishing an executive meeting body and a person in charge of governance to promote compliance for each project per organizational unit.
• (iii)
  Once again conduct entire dentsu Japan- compliance education, involving everyone from management to those in charge of practical operations, in order to acquire knowledge and raise compliance awareness. Additionally, ensure the enrichment of the compliance initiatives and continuity of efforts by implementing Antimonopoly Act compliance training, establishing a consultation service, and expanding the organization in charge of compliance within dentsu Japan.
• (iv)
  Ensure that all employees are familiar with the Dentsu Group Code of Conduct in order to define and settle an appropriate corporate culture and strengthen entire dentsu Japan activities to foster such a corporate culture. Additionally, review the personnel system to ensure governance is functioning appropriately.

dentsu Japan Mindset and Behavior Reform Project

In fiscal 2026, following on from the previous year, the project continues to be led by the COO, dentsu Japan, with the Chief Branding/Culture Officer, dentsu Japan, as sub-leader, and with the relevant departments of Dentsu Group Inc. and Dentsu Corporate One Inc. serving as members. The project is being promoted in close alignment with the challenges faced by business sites, with the aim of establishing an organizational culture that prioritizes integrity and ensuring a high level of compliance.
The dentsu Japan Mindset and Behavior Reform was triggered by the case related to the Tokyo 2020 Olympic and Paralympic Games. However, it is positioned not only to prevent recurrence of such cases but also as an initiative undertaken by the entire dentsu Japan to solidify the foundation for sound corporate activities that will enable dentsu Japan to grow further.
The progress of the initiative and the issues identified are continuously reviewed through employee surveys, monitoring by outside advisors, and other measures, and necessary revisions are made accordingly.

Project Promotion structure

● Initiatives for Fiscal Year 2025

Leveraging the results of the 17 initiatives completed by the end of the 2024 fiscal year, we are continuously implementing initiatives for Mindset and Behavior Reform across three themes: ❶ Organizational Culture, ❷ Systems, and ❸ Legal Knowledge and Compliance Awareness.

● Key Initiatives for Fiscal Year 2025

・Dialogue between management and employees to establish an organizational culture prioritizing integrity

Leader of the Mindset and Behavior Reform Project regularly hold roundtable discussions with employees across dentsu Japan companies, focusing on themes such as the importance of integrity in business operations. The content of these discussions is distributed to all dentsu Japan employees and utilized as initiatives to deepen their understanding of integrity.

・Development and utilization of tools to foster employee understanding of integrity
To support concerns related to integrity arising in business operations, a tool (Integrity Hint Book) has been created with the cooperation of executives and employees from all dentsu Japan companies. This tool compiles guidance and approaches for reference when facing uncertainties or anxieties in business activities. It has been shared with all dentsu Japan employees, and it is used in each organization.

・Workshops for Dentsu Inc. compliance managers, and their assistants

Workshops are held for Dentsu Inc.compliance managers, and their assistants stationed across each organization. With the support of external experts, these workshops focus on learning how to handle compliance issues, thereby enhancing compliance-related knowledge. We plan to expand the scope of this initiative to include compliance officers, managers, and their assistants at dentsu Japan companies other than Dentsu Inc. in the future.

・Re-acknowledgement of the Dentsu Group Code of Conduct
We continued training since last fiscal year where all employees, including those outside Japan, reviewed the content of the “Dentsu Group Code of Conduct” and agreed to it. This Code is required to be understood and practiced by everyone belonging to dentsu.

Dentsu Group Code of Conduct

Employee survey
（the first survey was conducted in November 2023, the second was in February 2024, the third was in May 2024, the fourth was in November 2024, and the fifth was in November 2025）

The results of the surveys to date are as follows:

• Overall trend:
  Awareness and understanding of the mindset and behavior reform, along with other related measures, have continued to take root through ongoing initiatives and remain at a high level in the latest survey.
• Items showing the greatest increase:
  Improvement was seen in such items as “awareness and understanding of integrity,” “specific understanding of integrity in daily work,” and “establishment of organizational culture.” In addition, a trend was also observed in which employees increasingly felt that risk management and legal/compliance functions had been strengthened.
• Items showing a flat trend:
  Since the first survey, there has been no significant change in the degree to which “working with integrity as a basic premise” has become established, and this remains an area that requires continued focus.

Based on these survey results, the Group will further enhance support to help employees avoid uncertainty in their work and will continue its efforts to ensure that decision-making and actions based on integrity take root throughout the organization.

Monitoring evaluation by the outside advisors

The monitoring evaluation of the Mindset and Behavior Reform by the three outside members (currently the outside advisors) is as follows (as of February 12, 2026)

●Mr. Itami
The dentsu Japan Mindset and Behavior Reform Project has maintained a high level of commitment to reform initiatives while leading the project as a whole, and it can be positively assessed that, across the dentsu Japan group companies, understanding of the need for organizational culture reform is deepening and a sense of progress in the reform is beginning to be felt. However, there remain a certain number of people who are struggling because the criteria for giving priority to integrity are not yet firmly established, and who believe that they will not be properly evaluated unless they prioritize results. Going forward, through the continued strengthening of training and other initiatives, as well as through the activities of compliance managers and others, it will be important to stay close to employees’ concerns and clearly indicate the direction that should be taken, while ensuring that integrity becomes embedded in day-to-day business activities and serves as their foundation. To that end, not only further reforms to the necessary business processes but also additional improvements to the personnel evaluation system will likely be required.

●Mr. Yoshino
The results of the dentsu Japan Mindset and Behavior Reform Survey indicate that integrity has become even more deeply embedded. Going forward, rather than limiting efforts to trend surveys such as those measuring the level of understanding of integrity, it would be worth considering more specific surveys and measures that focus on the weaknesses identified through the survey results. In addition, it can be seen that compliance officers and managers are earnestly addressing cases in the workplace where integrity becomes an issue, and the system appears to be effective and indeed ideal. As time passes and new colleagues join, I hope that careful thought will be given to how best to share not only why integrity matters, but also the circumstances and background that existed at the time the reform commenced, so that the baton may be passed on.

●Mr. Daito
It can be positively assessed that a variety of well-considered initiatives are being steadily implemented to promote integrity. In particular, I highly value the introduction of comments from new employees in the form of roundtable discussion articles shared internally, as this helps foster a sense of ownership among a wide range of employees. On the other hand, the survey results suggest that employees are struggling with how to pursue results while taking compliance with integrity as a given premise. I hope that efforts will continue, on an organized basis within each company and each department, to bridge the gap between understanding integrity and putting it into practice.

Reference to the monitoring evaluation

Mindset and Behavior Reform by 2024

dentsu Japan Reform Committee Members

(as of January 1, 2024)

Progress of the recurrence prevention initiatives (Completed by December 2024)

(as of December 18, 2024)

Reference to the previous status of progress.

Reference: Investigation Report by the Investigation and Review Committee

The details of the Investigation Report by the Investigation and Review Committee consisting of three outside experts are as follows.

Investigation Report by the Investigation and Review Committee

Reference: ESG Briefing

Latest Presentation and Conference Materials

• ESG Briefing 2024 Presentation（3.16 MB）
• Questions and Answers of ESG Briefing 2024 （231 KB）
• ESG Briefing 2024 Recorded Video

Previous Briefings

Reference: News Releases

• 2023.07.21

  Implementing the “Mindset and Behavior Reform” Promoted by the dentsu Japan Reform Committee

• 2023.06.09

  Notice concerning the receipt of the Investigation Report by the Investigation and Review Committee and recurrence prevention efforts

• 2023.02.28

  Establishment of the Investigation and Review Committee of Outside Experts

• 2023.02.14

  Establishment of a Special Committee of Independent Outside Directors