We, the officers and employees of the Mynavi Group, aim to achieve sustainable growth as a sound and dynamic corporate entity, and we will not only comply with laws, regulations, and social norms, but will also maintain high ethical standards, fulfill our social responsibilities as a corporate entity, and enhance the value of the entire Group by earning the trust and satisfaction of our users, customers, shareholders, business partners, local communities, employees, and other stakeholders. And we, all officers and employees, aware of being members of the Group, are determined to carry out our duties with pride and pledge to uphold and comply with this Charter of Corporate Behavior.

1. [Dissemination of better information and culture]
Mynavi Group will contribute to the creation of an affluent and prosperous society through the dissemination of better information and culture.
2. [Thorough enforcement of compliance]
We will comply with laws and regulations, social norms, and internal rules, and conduct our business with high ethical standards and pride.
3. [Fair and proper corporate activities]
We will engage in fair, transparent, and free competition as well as proper business transactions. We will also maintain sound and appropriate relationships with political and administrative authorities.
4. [Proper management of information]
We will comply with laws, regulations, and internal rules regarding the protection of information, including personal information, and will make utmost effort to prevent the leakage of confidential and information that is required to be kept confidential.
We will not engage in insider trading using inside information obtained in the course of our duties.
5. [Respect for intellectual property rights]
We will strictly protect the intellectual property rights of the company and will not engage in any act that infringes on the intellectual property rights of others.
6. [Distinction between public and private matters]
We will not use the Mynavi Group’s property or business authority or position for personal purposes.
7. [Healthy work environment]
We will create a safe, comfortable, and discrimination-free work environment where each employee’s personality and individuality are respected, and will eliminate harassment and other violations of human rights.
8. [Contribution to society and the global environment]
As a good corporate citizen, we will comply with laws and regulations and actively engage in social contribution activities with a deep awareness of our role as a member of society.
We will also reduce our impact on the global environment and contribute to the creation of a sustainable society.
9. [Efforts against antisocial forces]
We will take a firm stand against demands from antisocial forces and groups that threaten the order and safety of civic life.
10. [Thorough enforcement of corporate ethics]
The top management will recognize that it is their role to realize the spirit of this Charter, and lead by example to ensure that all concerned parties are fully aware of the Charter. In addition, the top management will always be aware of the opinions of those inside and outside of the Group, and will develop an effective system to ensure that corporate ethics are thoroughly upheld. Should a serious violation of this Charter occur, the top management will announce internally and externally its commitment to resolving the problem, strive to investigate the cause and to prevent recurrence, and take strict disciplinary action after prompt and accurate disclosure of information and clarification of accountability to the public.

Established on August 20, 2009

Revised on August 1, 2015