TOP > Investor Relations > Disclosure Policy
Last updated : 2010/10/19
Our corporate structure and procedures with regards to the timely disclosure of corporate information is as follows.
The Company has compiled the "Benesse Group Principle," a document that represents the over-riding concepts in the standards for behavior of every corporate officer and employee of the Benesse Group. The Group is an entity comprised of a holding company ("the Company") and the individual operating companies that fall within its scope. As a publicly listed enterprise, the Company strives to disclose corporate information appropriately in a timely manner.
| (1) | Basic Structures and Procedures as a Holding Company |
Under a holding company framework, the Company oversees management and business execution performed by Group companies in accordance with regulations for supervision of Group company management. At the same time, the Company has a system where the Company's Chief Financial Officer (CFO), Chief Human Officer (CHO), Chief Risk Management Officer (CRO) and Group Controller (GC) act as needed to offer advice and make requests regarding matters that need to be addressed on a Group-wide or cross-divisional basis. |
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| (2) | System for Reporting Important Information |
The types of important information that operating companies should report to the Company, and the system for reporting such information, are stipulated in the regulations for supervision of Group company management. Important information includes all insider information and all information requiring timely disclosure. Internal regulations stipulate that all important information is to be reported to the Company whenever such information occurs. |
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| (3) | System for Collecting Information for Disclosure |
For its own important information, the Company has made it the duty of the divisions that handle such information (namely the Secretariat of the Board of Directors, the Finance Division, the Accounting Division, and the Corporate Planning Division) to keep in constant contact with personnel at the Company specifically responsible for the handling of corporate information. The Company is developing an identical system for other information (including important information regarding operating companies), where personnel responsible for the handling of corporate information collect such data. |
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| (4) | Decision-making Process Regarding Disclosure |
The Company has a system for dealing with information that may be subject to timely disclosure. When such information emerges, the relevant divisions decide on a case-by-case basis whether actual disclosure of the information is warranted. If the information needs to be disclosed, personnel responsible for the handling of corporate information disclose the information following a decision by the necessary internal governance bodies. |
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| (5) | Company-wide Information Management and Training |
The Company's has a policy on handling of internal information, including matters subject to timely disclosure. This policy is stipulated in the Company's regulations for preventing insider trading, which apply across the entire Benesse Group. The CRO is responsible for preventing insider trading Group-wide, and makes decisions on handling of internal information. Furthermore, personnel responsible for information management are assigned at each operating company, and given responsibility for the development and operation of the respective information management systems of these companies. The Company is committed to further embedding awareness of the handling of important information throughout the Group. To this end the Company is running in-house training for corporate officers and employees, and posting information on laws regarding insider trading and internal regulations on the Company's intranet. |
