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Benesse Group Code of Conduct

This document sets out the fundamental principles that define the Benesse Group's approach and behavior vis-a-vis customers, consumers, and society in general.

Established on November 5, 2001
Revised on January 28, 2005
Revised on April 1, 2008
Revised on October 1, 2009

For everyone working in the Benesse Group

In order to fulfill our duties to our shareholders, to customers to the public and to our employees, and to provide an ethical foundation for the realization of our company name, Benesse, as "well being", we present you with this "Benesse Group Code of Conduct".

As companies engaged in business in the areas of education, lifestyle, welfare, and language, we are required not only to comply with laws and regulations but also to maintain a high level of business ethics.

Accordingly, every corporate officer and employee must recognize the importance of integrity, and endeavor to act in accordance with the highest ethical standards.

The Benesse Group Code of Conduct provides the criteria for judgment regarding our individual actions. It embodies the ideals that govern all company rules and regulations: it is our Constitution.

We Benesse group members shall adhere to this Code of Conduct and continuously endeavor to be a business group that is trusted by society.

Benesse Holdings, Inc
Director, Chairman
Soichiro Fukutake