To support "Benesse = well-being" for each individual To sustain the provision of value to society

As members of the Benesse Group, we will always act in a way that provides sustained support for the Company to act so that "Benesse = well-being" for all stakeholders including customers.

By offering high-quality products and services, we will provide value to society by pursuing and presenting advanced and innovative efforts to influence lifestyles and support the well-being of each individual.

By giving our customers distinctive and innovative products and services, we demonstrate our commitment to becoming an essential presence for society today and tomorrow. The corporate social responsibility we aim to fulfill is to grow as a company together with society. Being fully aware of the importance of contributing to solving social issues, we will broadly invest management resources and specialized knowledge, particularly for research activity in the educational field, to contribute to the solution of problems and the enhancement of life experiences.

In the organization of business management, we will construct and operate an internal control system which is necessary to promote efforts in reforming corporate governance as well as in compliance, risk management, human resources development, and the environment to become a company worthy of the trust of customers, consumers, shareholders, employees, local communities, and society.

As a member of the Benesse Group, each one of us without exception must conduct ourselves appropriately and fairly in order to sustain our obligation to society and to be worthy of society's trust. To achieve these objectives, the "Benesse Group Code of Conduct" specifies in practical terms the nature of conduct, standards, and regulations to be observed.

All board members and executive officers, as well as employees at all levels of the management are required to have a deep and complete understanding of ethics, and of the need for compliance and leadership in accordance with this Code.

• Scope of Application This Code of Conduct applies to all corporate officers (board members, corporate auditors, and executive officers) and employees (all employees including regular, part-time, and contract employees) of the Benesse Group of companies (Benesse Holdings, Inc and companies controlled by Benesse Holdings, Inc, including Berlitz International, Inc. and its subsidiaries around the world.
• Institution, Effectuation and Revision This Code of Conduct was prepared under the supervision of the Board of Directors of Benesse Holdings, Inc, and the Board has enacted a resolution requiring that this Code be put into effect by all member companies of the Benesse Group. No substantive revision of this Code will be effected without the approval of the Board of Directors of Benesse Holdings, Inc. Each Group Company is authorized to implement a Code if Conduct that reflects the specific nature of its business, but in no case can a Group Company Code of Conduct contain any provisions that conflict with those contained in this Code.
• Compliancen All employees have the obligation to conduct themselves in accordance with the requirements of this Code of Conduct. They must understand the objectives, intent, and specifics of the Code of Conduct, always be conscious of their need to comply with the Code of Conduct, and improve their conduct when necessary.
• Management Responsibility All employees in positions of management must comply at all times with this Code of Conduct and are responsible for directing and, when necessary, counseling and assisting employees under their supervision to conduct themselves likewise.
• Penalties Conduct in violation of the provisions of this Code of Conduct may be the subject of disciplinary action as required by the internal regulations and employee policies and procedures of each group company.
• Consultation and Reporting When uncertain about the propriety of any action, employees should discuss their concerns with their supervisor or the responsible department within their company. When corporate officers and employees of Benesse Group corporations which have offices in Japan discover that inappropriate activities are taking place or are about to take place by consulting this Code of Conduct, they should report the matter to the responsible department of their company, or through the "Speak Up Line", a confidential reporting system, which are the internal points of contact for reporting such matters.
  
  Confidential internal reporting systems such as the Speak Up Line have been or will be put into effect in all group companies outside of Japan. If the matter concerns the conduct of a senior manager and corporate officer, the Speak Up Line of Benesse Corporation should be used. Berlitz Japan will participate in the Berlitz International, Inc. ethics hotline.
  
  The department or entity receiving a report should respond promptly.

Benesse Group Code of ConductI. Commitment