To ensure that work done by the Benesse Group is carried out justly and ethically, we established the Benesse Group Principles, which are based on our corporate philosophy and present our policies for conduct taken by each executive and employee in the Group. These Principles list the policies that form the basis for our values and decisions that are to be upheld by the executives and employees of the Group. We have also established the Benesse Group Risk Management and Compliance Regulations as a set of common regulations across the Group, aiming to create systems (internal regulation systems) to ensure compliance and fairness in our business affairs and to prevent and manage damages before they occur. These regulations also aim to realize appropriate and effective operations. Group companies observe these regulations and establish company-specific codes of conduct and other regulations with more specific details depending on the company's type of work, project characteristics, project regulations, and work environment. This ensures adequacy and allows for complete compliance.

Risk Management

We installed a Risk and Compliance Committee to promote risk management and compliance across the entire Benesse Group. The Committee is chaired by a management department supervisor who regulates risk management and compliance. Other members include executives who oversee business affairs, supervisors from the management department, and project supervisors working in the Group's strategic business areas. The committee consolidates the results of compliance risk assessments in Benesse Group companies, formulates Group-wide countermeasures and manages their promotion. The results are regularly reported to and supervised by the CLRO and the Board of Directors. The results of the supervision are communicated to Group companies and a PDCA cycle is operated to promote important compliance risk measures such as improvement activities (including corrective and preventive measures, education and training). At the same time, negative information is also shared to promote risk management and thorough compliance during normal times. When emergencies occur, the incident is quickly reported to management through the Emergency Case Reporting Office, and depending on the severity, an emergency response headquarters may be established to create systems that promote emergency responses.

Complete Compliance

In addition to promoting risk management and compliance action in ordinary times, the Risk and Compliance Committee performs checks by the management department supervisors from a variety of expert viewpoints. The committee also promotes compliance by implementing consultations about the important business affairs of each Benesse Group company with the respective company in advance based on operating company management regulations that are shared across the Group. For these activities, a compliance supervisor is installed at each Group company and on-site systems are strengthened by dispatching supervisors as needed in close collaboration with the management department supervising the compliance of each company. The status of compliance in each workplace is also monitored by the internal audit department.

The Benesse Group Speak Up Line was set up as an internal hotline to be used when illegal or unjust actions or actions that violate articles of incorporation or internal regulations are discovered, and the Direct Auditor Hotline was set up to be used when there is a possibility of these discovered actions involving management. These hotlines are set up externally and can be used anonymously, ensuring both operations can be used safely and effectively in auditing performance. For emergencies, information can reach management quickly through the Emergency Case Reporting Office.

In addition to holding compliance training annually for new employees, new section chiefs, and new departmental heads, we also hold training for compliance and to prevent insider trading for all employees through our internal intranet. we also provide training on the company intranet for all employees, including contractors, on the Code of Conduct, including compliance and insider trading prevention.

Based on the Benesse Group Corporate Philosophy and the Benesse Group Principles, Group companies build and develop relationships of trust with our diverse inhouse and outside stakeholders. They also completely establish systems for legal compliance to carry out business activities with honesty and credibility. To prevent corruption, the Risk Management and Compliance Regulations have established legal compliance for fair trading and competition, a prohibition on trading with anti-social forces, a prohibition on providing or receiving profits or benefits, and a prohibition on actions that lead to a conflict of interest. Employees are definitely notified of these regulations through training and other means.