The Group provides training for persons responsible for preventing unreasonable demands to persons in charge of job sites at Group companies to enable them to deal resolutely with such demands made by antisocial forces. Participants in the training watch videos and attend lectures by officials from the Metropolitan Police Department and the Tokyo Center for Removal of Criminal Organizations, and commissioned instructors. They receive a certificate of course completion and practice what they learned after training completion.
Number of persons who underwent the training
The Group has established Group Hotline Rules to promptly recognize unfair actions and the like, and to make improvements in such cases. It has prepared an internal whistleblowing system called the Group Hotline to enable all Group employees to report the occurrence of such actions to an internal division in charge of whistleblowing and external law offices.
MI Card Co., Ltd. received an order to take measures based on the Act against Unjustifiable Premiums and Misleading Representations (misleading representation of superiority and greater advantages) from the Consumer Affairs Agency on July 8, 2019, for having made partially improper representation in its membership campaigns for the MI Card and the Gold Card.
In response, the company is working on initiatives to prevent the recurrence company-wide, in addition to providing training and education to all employees.
Other companies in the Group are also making efforts to provide proper and accurate representation (information) to customers, in other words, to strengthen and fully enforce compliance by applying internal rules and manuals to representation in the media used for appeals and the like.
Compliance Guidebook posted on the Companys intranet
The Isetan Mitsukoshi Group includes compliance-related content at training sessions for new employees and newly appointed managers, etc. Furthermore, the Compliance Guidebook, which is a booklet that lays out laws and social norms to be observed by all employees in a manner that is easy to understand, has been posted on the Companys intranet.
[Examples of content]
To fully ensure compliance, the Isetan Mitsukoshi Group is taking measures against bribery, and does not permit any benefits gained through bribery nor any other dishonest means.
This Policy stipulates that no monetary amounts, rewards, advantages or other kinds of benefits shall be supplied to public servants or private executives or employees for the purpose of gaining unfair benefit either inside or outside of Japan.
In addition to the stipulations of the Japanese Criminal Code and the Unfair Competition Prevention Act of Japan, and in consideration of the tightening of restrictions, in both Japan and other countries, on regulatory measures against corruption, such as the US Foreign Corrupt Practices Act and the UK Bribery Act 2010, the Isetan Mitsukoshi Group broadly prohibits the supplying of dishonest benefits to public servants and other individuals of proportionate standing either inside or outside of Japan.
President and CEO
April 1, 2018
We, the Isetan Mitsukoshi Group, and our staff must properly recognize that our group companies are in a superior position in transactions with many of our trading partners, and must also bear the responsibility of allowing our customers to purchase products, etc., in reliance with the information that we provide.
Under this understanding, and with the objectives of the group adhering to fair and free competition, as well as a fair existence that continues to contribute broadly to society, we shall comply with the following Basic Policy on Fair Trade as well as the 11 Principles of Fair Trade Compliance.
(Conducting fair and transparent transactions)
(Provision of appropriate information on products and services)
(Compliance with laws and regulations, and social ethical codes）
1 Prohibition of unfair returns
With the exception of where there is a defect in a purchased product, where a product was not ordered, or where conditions for return were agreed with the trading partner beforehand, we shall not return the products that we have purchased from our trading partners.
2 Prohibition of unfair discounting
With the exception of where there is a defect in a product, or where a product was not ordered, we shall not ask our trading partners to reduce the price of the products we have purchased.
3 Prohibition of refusal of receipt of private brand (PB) products, etc.
With the exception of where there is a defect in a product, or where a product is different to the one ordered, etc., we shall not refuse receipt of products we have ordered from our trading partners with special standards, designs, or models, etc., including private brand (PB) products and manufacturing consignment products.
4 Prohibition of inertia selling
We shall not ask trading partners to purchase the products or to use the services that we have specified contrary to the desire of the trading partner, including having a person involved in the purchase of products at the purchasing department or sales department, or a person engaged in the purchase of miscellaneous goods, etc., recommend a trading partner to purchase our company's products.
5 Prohibition of unfair requesting and use of dispatched sales personnel
If we make a request to send a member of our sales personnel to a trading partner, we shall provide a comprehensive explanation and hold sufficient discussions beforehand.
We shall not send personnel without the prior consent of the trading partner, and shall not make unfair use of the employees, etc., of a trading partner, such as have them perform business outside of that relating to the sale of the product that they are purchasing.
6 Prohibition of unfair requests for funding, etc.
If we ask a trading partner for funding, we shall provide a detailed explanation and hold sufficient discussion beforehand on the amount, use, and calculation basis, etc., based on our prescribed proposal document.
We must not request funding that is not in the direct interest of the trading partner, and we shall not ask for funding in excess of a reasonable range.
Outside of such funding, we shall not request any economic benefits, such as money from our trading partners, which would not normally be borne by them.
7 Prohibition of disadvantageous handling
We must not provide disadvantageous handing to trading partners, such as stopping transactions or delaying payments, on the grounds of a trading partner not having complied with an unfair request made by a group company such as that prescribed in these Principles, or on the grounds of a trading partner having notified a government agency such as the Fair Trade Commission of the fact of the performance of an unjust act by a group company.
8 Prohibition of other unfair trading conditions
We must not conduct transactions under conditions that are significantly disadvantageous to our trading partners, and must not unilaterally change trading conditions.
9 Prohibition of the provision of unfair gifts
We must not provide excessive gifts that exceed the legally prescribed maximum amount and total amount prescribed by law as a means for soliciting customers.
10 Provision of appropriate information and prohibition of misrepresentation
We shall provide the appropriate information on our products and services so that our customers are able to make accurate decisions.
We shall not make displays that mislead customers as a means to solicit customers.
11 Prohibition of unfair trading restrictions
We must not perform any act that restricts regular competition, such as agreeing with a competitor on the price, quantity, trading partner, and contractor, etc., for products and services.