A. Development and Provision of High-Quality Products and Services

(1) Development and Provision of High-Quality Products and Services

The products and services provided to customers and consumers must comply with all applicable laws and regulations. Products and services must be planned and developed with legal requirements in mind, must be safe and of high quality and should reflect the age, intended use and specific circumstances of the people who will use them. The product development process must always include consideration of these characteristics, and production and distribution should reflect the same concern for safety and appropriateness for the intended use and the intended user. Every employee should be trained to consider it his or her mission to provide high-quality products and services that customers and consumers can trust and so they will perform their work being fully aware of the necessity and importance of maintaining and improving quality.

(2) Standards for Issuing Warnings and for Exchanging or Recalling Products

To be able to respond quickly when a serious defect materializes or an accident occurs, decision-making standards, response guidelines, and response procedures will be established beforehand for each product and service to specify when and in what situations warnings should be issued or information publicized to customers and consumers, or when measures such as exchanging or recalling a product should be taken. When such a situation occurs, to avoid recurrence, employees will take necessary actions such as informing customers and consumers appropriately and promptly about serious defects or incidents according to established standards, guidelines or procedures. Employees will thoroughly investigate causes; collect information, response examples, and know-how on causes and share such information internally; and they will implement prudent measures to prevent the reoccurrence of similar accidents.

Responding to Customers and Consumers

The comments of customers and consumers on products and services are the most effective and vital resource for providing better products and services. To maximize the use of this resource, a point of contact will be established so customers and consumers will readily know where and how to contact the Benesse Group when they have an opinion or complaint about a product or service and they may do so freely. This point of contact will be staffed by employees trained to respond sincerely, and a system will be established to reliably relay the specifics of these opinions and complaints to responsible departments.

When opinions are voiced or complaints are made about inferior or defective products or services, they should be reported immediately to the responsible administrator, and a suitable response should be made promptly after verifying the facts of the matter. When an inferior or defective product or service causes physical harm or death to a person or a financial loss or when there is risk of such an occurrence, it must be reported immediately to top management and a prompt response made to prevent the occurrence or expansion of injury or loss.

Representation, Provision of Information, and Publicity and Advertising

Employees must provide customers and consumers with adequate information on products and services through appropriate means. Product content, price, usage instructions, payment conditions, and cancellation terms of products or services represent extremely important information for customers and consumers in selecting and purchasing products and services. Understandable, accurate, and appropriate information must therefore be provided, taking into consideration the age and other conditions of the intended customers.. Employees must always endeavor to prevent customers and consumers from being disadvantaged by a failure to supply or explain important information on the Company's products and services.

The probability of any foreseeable hazards in the use of products and services must be explained in an understandable manner to customers and consumers, and appropriate warning labels such as "caution," "danger," and "warning" - must be provided in a readily visible manner. In the case of products or services for children, hazards must be eliminated to the full extent possible, and in the case of products and services that should be used only in the presence of an adult or other guardian, proper notices must be readily visible and clearly expressed.

The marketing and advertising of products and services must always be based on impartial data. Expressions likely to give the impression that products or services are better than they are, such as exaggerations, or any expressions causing overexpectations, are prohibited. In addition, expressions deliberately showing contempt for other companies or expressions that are inaccurate must be avoided. Publicity and advertising activities will be undertaken to provide information to support the decision-making of customers and consumers in selecting products and services but must never reflect a negative opinion of a competitor or its products or services.

Representation, Provision of Information, and Publicity and Advertising

Employees must provide customers and consumers with adequate information on products and services through appropriate means. Product content, price, usage instructions, payment conditions, and cancellation terms of products or services represent extremely important information for customers and consumers in selecting and purchasing products and services. Understandable, accurate, and appropriate information must therefore be provided, taking into consideration the age and other conditions of the intended customers.. Employees must always endeavor to prevent customers and consumers from being disadvantaged by a failure to supply or explain important information on the Company's products and services.

The probability of any foreseeable hazards in the use of products and services must be explained in an understandable manner to customers and consumers, and appropriate warning labels such as "caution," "danger," and "warning" - must be provided in a readily visible manner. In the case of products or services for children, hazards must be eliminated to the full extent possible, and in the case of products and services that should be used only in the presence of an adult or other guardian, proper notices must be readily visible and clearly expressed.

The marketing and advertising of products and services must always be based on impartial data. Expressions likely to give the impression that products or services are better than they are, such as exaggerations, or any expressions causing overexpectations, are prohibited. In addition, expressions deliberately showing contempt for other companies or expressions that are inaccurate must be avoided. Publicity and advertising activities will be undertaken to provide information to support the decision-making of customers and consumers in selecting products and services but must never reflect a negative opinion of a competitor or its products or services.

Upholding Fair and Free Competition

To maintain fair and free competition in the marketplace, employees should not attempt to achieve a monopoly position within any market and should engage in conduct that fully complies with all applicable fair trade laws. The Anti-Monopoly Law (in Japan) and similar or related laws, orders, and guidelines in all countries where the Company operates must be complied with, and fair business dealings must be practiced worldwide. When considering the sales prices of products or conditions for business transactions, the intent and specifics of related laws, orders, and guidelines must be understood, and transactions using unfair methods or with unfair specifics must be avoided.

PreambleII. Stance