Basic Stance and Implementation of Internal Control System

The Company ensures that the Group’s operations are conducted appropriately and ethically by having established the Benesse Group Code of Conduct, which presents conduct guidelines for the individual officers and employees of the Group, based on the Benesse Group Principles. The guidelines provide a reference point for Benesse Group officers and employees for understanding the values they should uphold and for making judgements. Group companies work to conduct their activities in accordance with these guidelines by formulating their own more specific conducts standards and other rules tailored to their specific format, business characteristics, business scale, workplace environment, and other factors. Through these rules, Group companies ensure that operations are appropriate and that compliance is rigorously observed. The Company has also established and operates the “Speak Up Line” as a system for reporting breaches of the law, misconduct, or breaches of the Company's Articles of Incorporation or internal rules. By thus complying with social norms, management ethics, laws and regulations, and the like, the Group aims to be a company that continues to provide value to society.

To formulate the basic policy of the Group’s internal control system based on this code of conduct and the general features required for establishing a system pursuant to the Ordinance for Enforcement of the Companies Act, the Company’s Board of Directors passed a resolution based on Article 362, Paragraph 4, Item 6, of the Companies Act.

In risk management, the Company has established persons in charge of administrative divisions to assess and respond to the risks faced by the Group from a specialist perspective. Furthermore, based on the management guidelines for the entire Group, the Group has established a simple and clear response system for communicating information quickly to top management when a crisis occurs.

The Company’s information management system requires that important information be retained for at least 10 years, as stipulated in the document management rules.

As an internal control for the corporate group, the Company has established operating company management and administration rules together with other rules, thereby clarifying the matters that subsidiaries should submit to the Company for consideration when making decisions, and the method for doing so.

Last updated : 2017/09/25