Our Commitment
Lifetime Empowerment

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INDEX
●First of all

3●To Our employees, faculty and staff

19

Introduction

4

Question

Purpose of this Code of Conduct/Our Leadership5

Our responsibility - for The working environment of employees,

How to make the right decision

6

faculty and staff

21

What it means/Why it matters

227

How we do it

23

Question8

Our responsibility - for Employee skill development25

Our responsibility - for Learners

9What it means/Why it matters

26

What it means/Why it matters

10

How we do it27

How we do it11

Our responsibility - for Senior leaders28

Our responsibility - for Educational partners

13

What it means/Why it matters

29

What it means/Why it matters

14

How we do it30

How we do it15

Our responsibility - for Alumni

16● To Our Community

31

What it means/Why it matters

17

Question

32

How we do it18

Our responsibility - for Community

33

What it means/Why it matters

34

How we do it

35●To Those who gather in our learning community● To Our Stockholders

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20

36

Question37

Our responsibility - for Stockholders

38

What it means/Why it matters

39

How we do it40

3First of all

Copyright © Aoba-BBT, Inc. All rights reserved.

First of all

1. Introduction

This Code of Conduct is based on "Our Commitment"
to ensure that Aoba-BBT Group ("ABG") conducts its
business with integrity towards all stakeholders,
including learners, parents or sponsors, alumni,
educational partners, board members and employees.
The Code of Conduct provides guidelines for making
decisions and acting in accordance with Our
Commitment. Adherence to this Code of Conduct will
help us to perform our business optimally in anenvironment of fairness.

If you become aware of a violation or potential
violation of this Code, you must promptly report to theappropriate authorities to ensure that corrective
actions can be applied to prevent a recurrence of theissue.

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First of all

2. Purpose of this Code of Conduct

3. Our Leadership

The Code of Conduct is intended to guide us in making sounddecisions and acting with leadership and problem-solving skills inorder to achieve better learnings for our learners and to create
global leaders.

Our leadership means that all of us act as leaders in the following
perspectives:(1) Focus on learners and customers(2) Promote innovation(3) Build better mutual/trusting relationships(4) Demonstrate authority and influence in challenging situations(5) Develop organization and human resources(6) Strengthen education programs

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First of all

4. How to make the right decision

Ask yourself how you would behave:a.

Does the conduct potentially violate ABG's Code of Conduct, Company
Policy, or Legal Regulations?

b.

Does the action align with the responsibilities of the “OurCommitment”?

c.

Could external stakeholders perceive the conduct as unethical?

d.

Does the conduct have the potential to harm you or ABG's reputation?

You may seek assistance if any of these situations apply to you.

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To Those who gather in ourlearning community
Our first commitment is to all those who gather tolearn in our community including students, guardians,sponsors, educational and business partners, andalumni.

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To Those who gather in our learning community

What is important toyou when dealing withlearners?

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To Those who gather in our learning community

Our responsibility - for Learnersl Together, we help students to develop a lifelong ability to survive in a world
where there arenʼt always easy answers.
l We develop human resources with an international perspective and apioneering spirit who can create and innovate solutions for local and global
issues.
l The school provides education through interaction and collaboration that
respects learners' spirit of inquiry in an environment that incorporates
state-of-the-art instructional design and technology.
l Responsible for ensuring that the learners achieve their goals and that theclients receive the expected results.
l We will do our utmost support to learners who are willing to put forth theeffort to realize their aspirations.

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To Those who gather in our learning community

Why it matters
There are numerous factors that contribute to the customerʼ
success, and it demands continuous attention and effort.
Customers receive support from their parents, sponsoredcompanies and more. Itʼs essential to strike a balance between
the success of the customer and the success of their sponsors.

What it means
Our primary stakeholders are students (hereinafter referred as“customer”) aspiring better learnings, as well as clients
anticipating expected outcomes.
We highly value customer feedback or requests and promptly
respond to it with respect and appropriateness. Valuing
customerʼs voice means ensuring that their inputs are justlyreflected in the improvement and expansion of our services.

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Listening to our customers and sponsors feedback andresponding in a timely manner leads to an increase in learners'
satisfaction, loyalty, growth, and trust.

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To Those who gather in our learning community

How we do it

1. We are committed to high standard and quality service delivery.
1-1 Select and retain faculty members who are highly knowledgeable,
ethical, and capable of providing optimal learning opportunities.
1-2 We understand our duty to provide accurate information and to handle
it with modesty and integrity in the development, marketing anddelivery of our services.
1-3 We adhere to laws and regulations and establish proper relationships
with external accreditation(International Baccalaureate Association,
Cambridge CP, CLS, A-Levels, CIS, NEASC, JIHEE, JUAA), and ensurecompliance with required regulations.
While it is essential to do our utmost to assist our customerʼs' success, it's
equally vital to select customers who are open to and capable of realizing
the full potential of our support. To assist them in this process, we've put
in place an evaluation and feedback system.
2. To improve the educational experience, we create a respectful,collaborative atmosphere and maintain appropriate professional
relationships between customers and faculty. It fosters an attitude ofcooperation, mutual learning and it encourages open and healthy
communication between customers, faculty and sponsors
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To Those who gather in our learning community

How we do it

3. We guarantee a secure learning environment that is free fromharassment and discrimination, prioritizing the well-being and trust of
everyone involved.
3-1 We value diversity, fairness, inclusivity and non-discrimination. We
treat people's opinions with respect and courtesy. Discrimination or
bullying in any form is not tolerable. We actively promote
education and prevention programs against discrimination topromptly address any issues.
3-2 We understand the importance of having a health and safety policy
in place for the learning environment. We establish and implement
the following guidelines;l Safety initiatives in accordance with the various guidelines set
forth by law
l Communicating and facilitating communication with parents
regarding health and safety issuesl Confirmation of the safety of classrooms, school buildings,
gymnasiums,
and other facilities and equipmentl Conducting evacuation drills on a regular basisl Creation of checklists for student safetyl Prevention of harassment.
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4. We aim to foster a suitable relationship with our customers. Should any
issues or conflicts of interest arise, the company proactively addresses
them as a collective rather than on an individual basis.
5. The implementation of technology will be carried out in accordance withethical considerations, laws and regulations, and after consultation withthe appropriate departments. We uphold cyber security measures,
respect privacy and adhere to guidelines for responsible usage.
6. We recognize the significance and potential risks associated with usingsocial media as an educational communication tool. We manage its
capabilities to improve learning and advance our educational mission
while also upholding ethical and responsible social conduct.
7. We understand the importance of privacy in our business operations.
We commit to using the personal information we collect solely for lawful
purposes and ensuring compliance with applicable laws in our private
policy.

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To Those who gather in our learning community

Our responsibility- for Educational partnersl We provide an environment in which our educational partners candeliver quality education.
l We work together with all our business partners to maintainsustainable relationships.

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To Those who gather in our learning community

Why it matters
Our utmost priority is our customers, which includes our
educational and business partners who support them.

What it means
Our services cannot be delivered by our employees and teachers
alone. Working with our educational and business partners isessential, as we need them to realize their full potential.

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To Those who gather in our learning community

How we do it

1. We respect our educational and business partners.
2. The selection of a partner will determine his skills and suitability forthe client's objectives as well as the establishment of the terms andconditions, including compensation, to allow a lasting and sustainable
relationship.
3. We create an environment that allows our education partners to fully
utilize their skills through regular evaluation and, and by providing thenecessary resources to support their growth and program
development.
4. We adhere to applicable laws and regulations to ensure fair sales andpurchasing practices. We do not engage in business with partners who
fail to comply with these laws and regulations.
5. We dialogue with partners on how the Code of Conduct and ourpolicies should be applied to their day-to-day work and listen to theirconcerns and questions.

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To Those who gather in our learning community

Our responsibility - for Alumni

l We support learners to develop lifetime empowerment for resilienceand success.
l We will maintain and continue to develop strong ties with the Alumni.

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To Those who gather in our learning community

Why it matters
Alumni not only have the opportunity to retake the course,
but also to become educational partners themselves.
Therefore, it is important to establish a strong and positive
relationship with them.

What it means
Alumni are part of our family and they are our achievements.
It is our responsibility to maintain a long-term good
relationship with them.

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To Those who gather in our learning community

How we do it1.

We maintain communication with Alumni and provide a platform forreceiving their feedback and input.

2.

We consistently provide them with up-to-date information andvaluable suggestions from our side.

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19

To Our employees, faculty and staff
The second commitment is to all of our employee,
faculty and staff who work with us around the world.

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To Our employees, faculty and staff

What kind of work
environment would you
like to have in order tomake the most of yourabilities?

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To Our employees, faculty and staff

Our responsibility- for The working environment of
employees, faculty and staff
l We create a workplace where employees, faculty and staff takeresponsibility for their actions and work efficiently as a team.
l We create a working environment where every employee, faculty and staff
is valued and respected as an individual.
l We ensure a working environment in which employees, faculty and staff
are encouraged to freely offer suggestions and opinions.
l We will create an environment in which employees, faculty and staff are
fairly evaluated and rewarded for their efforts and achievements.
l We provide equal opportunities for employment, development, andpromotion to those who are capable.

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To Our employees, faculty and staff

Why it matters
To optimize value for customers, it is the duty of the company
to provide an equitable and dynamic work environment where
employees, as service providers, can harness their full potential.
Working in a secure environment will enable us to deliver topquality services.

What it means
The company will focus on creating an environment in which
employees, faculty, and staff can reach their full potential. Specifically,
the company fosters a culture that recognizes individual effort andachievement by providing opportunities for employees to freely
express their opinions and suggestions, and through regular feedback
and fair evaluation.
While it's crucial for employees, faculty and staff to be well-preparedand efficient in delivering maximum value to customers, the company
must also create the best possible environment to facilitate this.
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To Our employees, faculty and staff

How we do it

1.

All employees, faculty, staff, and educational partners are encouraged to operate in a cleanand secure work setting and to lead wholesome lives, both in terms of physical and mental
well-being.
1-1. We will give top priority to health and well-being, striving to establish a safe and hygienic
working environment.
1-2. We promote a safety-oriented culture by adhering to occupational health and safety
regulations, addressing potential hazards, implementing preventive measures, anddelivering relevant training.
1-3. We encourage the timely reporting of safety concerns, near misses, or accidents. All
reports will be treated confidentially, and we will conduct thorough investigations,
implementing appropriate corrective actions as needed.
1-4. We promote a healthy work-life balance, offer access to medical and other support
services, and ensure employee well-being by implementing tools such as stressassessments.
1-5. We establish communication procedures by formulating an emergency response strategy
and regular training to ensure an efficient response to any crisis or emergency situation.

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To Our employees, faculty and staff

How we do it
2. We do not tolerate any type of harassment, whether it's sexual harassment, power
harassment, bullying, intimidation, or any behavior that disrupts a suitable work environment.
2-1. Any such behavior, whether by employees, faculty, staff, educational partners, clients, or
any other individuals connected to our organization, is completely prohibited.
2-2. If you encounter or witness such behavior, please report it immediately.
2-3. The person making the report will be kept confidential and the reported issue will behandled appropriately.
2-4. We are responsible for our personal behavior and actions. Failure to address harassment
may result in disciplinary action, including termination of employment or business
relationship, when necessary.

3. We equally recognize people and provide opportunities to work in roles that align with theirunique skills and abilities, regardless of attributes like gender, age, or nationality.
3-1. Discrimination based on characteristics like age, gender, race, ethnicity, sexual
orientation, gender identity, place of birth, or religion is strictly prohibited in ourorganization.
3-2. We prohibit any form of illegal, abusive, or forced labor among our employees, faculty,
staff, educational partners, and business partners.
3-3. The evaluation of employees, faculty, and staff will be based on the judgment of theappropriate evaluator, following the defined evaluation criteria.
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To Our employees, faculty and staff

Our responsibility- for Employee skill developmentl The company is committed to improving its employees' problemsolving, leadership, and entrepreneurial skills, as well as their ability
to work independently. We will work towards enhancing thesecapabilities.

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To Our employees, faculty and staff

Why it matters
To deliver maximum value to our customers, our employees, we
as service providers must maximize their abilities andcontinually grow. This will enable us to provide high quality
services and strengthen our competitiveness as a company.

What it means
We will put this into action by fully utilizing the training and work
opportunities provided by the company to enhance our problem-solving,leadership, and entrepreneurial skills to a higher standard. We will also
promote self-improvement and create an environment where employees
can proactively enhance their skills. This entails allocating time for self-study
and offering support for participation in professional training and seminars.
We are accountable for honing our skills to deliver optimal value to ourclients. This not only fosters our personal development but also reinforces
the organization's overall performance.
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To Our employees, faculty and staff

How we do it1.

We make the most of the training and work opportunities provided
to employees, faculty, and staff. We will provide constructive
feedback on their learning, work outcomes, and the methods
they've employed, supporting their individual growth anddevelopment.

2.

We provide opportunities for self-study and encourage
participation in professional training and seminars.

3.

We encourage and provide support for independent activities
related to educational projects, including writing and presenting
research papers and books, as well as participating in conferences.

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To Our employees, faculty and staff

Our responsibility - for Senior leadersl We appoint leaders who demonstrate exceptional abilities and upholdfair and principled conduct.

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To Our employees, faculty and staff

Why it matters
In management policy decisions and emergency situations,consensus-driven decision-making is crucial and important. It isnecessary to have leaders who can effectively facilitate theprocess. During emergencies, quick and effective decisionmaking is essential. Therefore, we need leaders who can makethe best decisions swiftly and efficiently in such situations.

What it means
Our approach is not to rely solely on the extraordinary abilities ofa single individual to manage our company. Instead, each of us
acts independently to support the management. However, forcrucial decisions related to management policies or during
emergencies like disasters, we need capable senior leaders tooversee the organization and projects.

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To Our employees, faculty and staff

How we do it

1.

Each of us must demonstrate autonomous leadership and support theoverall management of the organization.

2.

In times of emergency, such as during management policy decisions
or disasters, we appoint exceptional leaders to supervise both theorganization and projects.

3.

Leaders are expected to set an example, consistently upholding
ethical standards and make operational decisions in accordance with
the Code of Conduct.

4.

This responsibility should be fulfilled by regularly assessing thequalifications and conduct of leaders and, if necessary, facilitating
their development or considering replacements.

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31

To Our Community

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To Our Community

How do you view thecommunity that extends
beyond your work?

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To Our Community

Our responsibility - for Community

The third commitment is to the communities and the environment in which
we live and work, as well as to the global community as a whole.
l We will contribute to the sustainable development of both local andglobal communities by nurturing individuals capable of addressing global
challenges and by spreading awareness of Lifetime Empowerment.
l As responsible citizens, we will actively support valuable social andwelfare programs, enhance educational opportunities, and fulfill our tax
obligations.

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To Our Community

Why it matters
As expected, contributing to community through education is ofutmost importance. It's a fundamental requirement for gaining
acceptance within the communities we serve.

What it means
Active employee involvement
ABG prioritizes diversity and inclusion, aiming to cultivate aworkplace where every employee actively practices ethical andpositive conduct to address challenges and cater the needs ofparticipants and the community.
Our business cannot stand on its own; it relies on understanding
the local community and the social contributions that form thebasis of our business.
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To Our Community

How we do it1.

We are aware of our strong connection with the local community, as
well as our broader environment.

2.

We will fulfill our responsibilities by maintaining a constant dialogue,
assessing what is feasible and necessary for both parties, createplans based on mutual agreement, and executing these plansaccordingly.

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36

To Our Stockholders

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To Our Stockholders

What economic activities
do you think areimportant to provide thebest environment forcustomers?

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To Our Stockholders

Our responsibility - for Stockholders

The fourth commitment is to our stockholders. We believe that byimplementing all of these principles, stockholders will receive fairreturns.
l As an educational institution, we will strive for sustainable profits.
l We build up reserves for times of adversity.
l We will explore creative concepts, create innovative learning services,
and invest in the future.
l If we encounter setbacks, we will take corrective actions.
1.

We must conduct our business activities in a transparent manner

2.

We must make the necessary investments for development

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To Our Stockholders

Why it matters
While capital accumulation and investment are important, it's also
crucial to fulfill the natural obligation of returning profits to thestockholders. Ensuring sustainable returns to stockholders while
accumulating and investing appropriately is of utmost importance.

What it means
We operate as both an educational institution and a stockcompany school, receiving only partial public subsidies.
Therefore, financial independence is crucial, and we mustbuild our own funds to prepare for any future challenges.
Moreover, investing our own funds is essential to create thebest possible environment for our customers.

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1.

We build trust with stakeholders, including stockholders, bypromptly disclosing information about our business activities
and financial performance.

2.

We make necessary investments in system development,
facility maintenance and upgrades, M&A, and other areas toensure the company's sustainable growth and healthy profits.

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To Our Stockholders

How we do it

From a sustainable management standpoint, we will continuously monitor ouroperations to ensure profitability while delivering the best possible services. This
will be achieved by timely selection and emphasis on effective businessstrategies.
1.

We establish trust-based relationships with stakeholders.

2.

We allocate the required resources for investments, including themaintenance and enhancement of systems and facilities, as well as potential
mergers and acquisitions, to secure sustainable and steady growth, alongwith health profits.

3.

Employees, faculty, and staff are expected to keep the confidentiality ofimportant non-public information before it is made available to the public. In
addition, they are refrained from trading the company's shares outside thedesignated share trading period and should avoid disclosing suchinformation to third parties.

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41

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