Basic Policy on Customer Harassment

Date of Enactment: October 1, 2026

1. Introduction (Basic Philosophy and Background)

We sincerely appreciate the honest feedback and concerns shared by our customers, as they provide us with valuable insights for improving our services and building strong relationships. At the same time, we believe that ensuring a safe and secure working environment for our employees is an essential foundation for consistently providing high-quality service to our customers. Guided by our core principle of balancing “sincere service to our customers” with “the protection of our employees’ working environment,” we hereby declare that we will take a firm stand against customer harassment.

2. Definition of Customer Harassment

At our company, customer harassment is defined as conduct that meets all three of the following criteria in accordance with the guidelines of the Ministry of Health, Labour and Welfare and our internal regulations. This also includes words and actions taken over the telephone or on the internet, including social media.

The words or actions are those of a customer or other person (a supporter, a student at a school or academy and their parent or guardian, a business partner, or another related party):Words or actions by a customer, business partner, user of the facility, or other person related to our business (including those who may purchase products or use services in the future).

 

They exceed the scope of what is socially acceptable:The means, manner, or content of the demands are unreasonable in light of the nature of the business, etc.

 

They impair the working environment of employees:They cause employees physical or mental distress and interfere with their work.

3. Specific Examples of Covered Activities

This policy applies to conduct that exceeds the bounds of what is socially acceptable. The following examples are provided for illustrative purposes and are not intended to be exhaustive.

Physical and mental attacks

・Assault, injury, and intimidation.
・Slander, defamation, insults, and verbal abuse.
・Forced kowtowing.

Intimidating or coercive language and behavior

・Intimidating words or actions.
・Persistent and harassing words or actions.
・Restrictive words or actions, such as refusing to leave, loitering, or false imprisonment.

Excessive or unreasonable demands

・Requests without justification, or requests completely unrelated to the products or services.
・Requests that significantly exceed the scope of services under regulations or contracts, or requests that cannot be accommodated.
・Unreasonable demands for damages.
・Unjustified interference in training and coaching settings (requests or protests regarding participation in or selection for matches, etc., or selection criteria, made in an intimidating manner or through persistent repetition).
・Detaining staff at service counters, over the phone, at venues, etc. for extended periods; persistent words or actions; repeated inquiries about the same matter with excessive frequency or to an excessive degree; or unreasonable questioning.

Online Activities & Other

・Doxing personal information or employee information on social media, etc.
・Slander and defamation online.
・The aforementioned improper demands and conduct on social media, various inquiry forms, etc.
・Unauthorized audio or video recording of employees.

4. Policy for Handling Customer Harassment

In the event of an incident that constitutes customer harassment, our company will take the following measures as an organization.

Organizational Response and Evidence Collection: Employees will not be left to deal with the situation alone; instead, supervisors and relevant departments will coordinate an organizational response. Furthermore, to ensure the safety of our employees and record objective evidence, we will record audio or video as necessary, even if the other party does not consent.

 

Refusal of Service: If unreasonable demands or harassment continue even after a reasonable explanation has been provided, we will discontinue our response and refuse to provide services, ask the individual to leave the premises, or terminate the call.

 

Coordination with External Experts: In cases where unreasonable demands persist or the individual engages in conduct that may constitute a crime, such as assault or intimidation, we will report the matter to the police and coordinate with experts such as attorneys. We will take strict action on both criminal and civil grounds, including issuing warnings and pursuing legal measures (such as applying for provisional dispositions under the Civil Preservation Act).

5. Establishing Internal Systems and Supporting Employees

We have established the following system to protect our employees from customer harassment.

Policy Formulation and Training: We will conduct thorough training and awareness programs for employees based on the "Customer Harassment Response Manual," which outlines specific response procedures.

 

Establishment of a Consultation Desk: A dedicated consultation desk has been established within the HR Group so that affected employees can seek advice at any time.

 

Protection and Support for Victims: We will conduct a prompt investigation of the facts and provide immediate mental health support to affected employees. Furthermore, no employee will be subjected to any disadvantageous treatment for having consulted about harassment or cooperated with the fact-finding investigation.

6. Request to Customers

We wish to build a healthy relationship (an equal partnership) based on mutual respect with all our customers.

 

We ask for your understanding and cooperation regarding this policy on customer harassment. We will continue to do our utmost to provide even better service to many more customers in the future.