Purpose and scope
This policy sets out how mtc protects the health and safety of people affected by its work and manages the environmental impact of its operations. It applies to our office, client premises and construction sites, and to our employees, subcontractors and visitors.
Effective 1 October 2026. Last reviewed 19 September 2026. Policy owner: Leon Appleby, Representative Director, mtc K.K. (株式会社エム・ティー・シー).
1. Our commitment
mtc designs, installs and supports IT, audiovisual and physical security systems, much of it on client premises and shared construction sites. Our work involves ladders, work at height, electrical cabling, ceiling spaces and hot conditions, so safety is part of how we plan and carry out every job.
We are committed to preventing injury and ill health, meeting our legal obligations in Japan, reducing our environmental impact and improving our practices over time. Our approach is aligned with ISO 45001 (occupational health and safety) and ISO 14001 (environmental management). mtc does not currently hold certification to either standard.
2. Scope
This policy applies to everyone working on mtc business or mtc projects, including employees, officers, temporary staff and subcontractors, and to visitors to our office and work areas.
It covers our Tokyo office, client offices and facilities, and construction sites where we work alongside a main contractor and other trades.
3. Legal framework
We work to meet the laws and regulations that apply to our activities in Japan. The main ones are listed below. Where a client or main contractor sets stricter site rules, we follow those as well.
- Industrial Safety and Health Act (労働安全衛生法) and the Ordinance on Industrial Safety and Health (労働安全衛生規則), including the heatstroke prevention measures that became mandatory in June 2025.
- Construction Business Act (建設業法). mtc holds a Telecommunications Construction licence, Kanagawa Governor Permit (General-6) No. 92487, and assigns a qualified chief engineer (主任技術者) to construction work as the Act requires.
- Electricians Act (電気工事士法): electrical work that the Act reserves for qualified electricians is carried out only by people holding the required qualification.
- Fire Service Act (消防法): relevant where our security or access control systems interface with fire alarm and fire safety equipment.
- Waste Management and Public Cleansing Act (廃棄物の処理及び清掃に関する法律), including the industrial waste manifest system (産業廃棄物管理票).
- Act on the Promotion of Effective Utilization of Resources (資源の有効な利用の促進に関する法律), which governs manufacturer recycling of business-use PCs.
4. Roles and responsibilities
Health, safety and the environment are a shared responsibility.
- The Representative Director owns this policy and is responsible for making sure that resources, safe systems of work, risk assessment and training are in place.
- Project leads plan work safely, brief the team before work starts and coordinate with the client or main contractor.
- Employees and subcontractors take reasonable care of their own health and safety and that of others, follow safe work procedures and site rules, and stop work if they believe it is unsafe.
- Subcontractors must provide competent, properly trained people and follow this policy and our Supplier Code of Conduct.
5. Working on shared construction sites
On mixed sites, the main contractor (元方事業者) leads overall safety coordination. We take part in site safety meetings, induction and daily briefings, follow the main contractor’s rules and permits, and share information about hazards our work may create for others.
Recent amendments to the Industrial Safety and Health Act extend protections on mixed construction sites to sole-proprietor workers. We apply the same safety expectations to everyone working on mtc tasks, whatever their employment status.
6. Risk assessment and safe systems of work
Before work starts, we identify hazards, assess the risks and put controls in place. We review the assessment when conditions change. Higher-risk activities include:
- work at height, including ladders, scaffolding and aerial work platforms (高所作業車);
- electrical work and work near live equipment;
- work in ceiling voids and other confined or restricted spaces;
- manual handling of heavy equipment such as displays and racks;
- heat stress, particularly during summer and in ceiling spaces; our heatstroke measures include procedures for spotting symptoms early, reporting them and responding quickly.
7. Competence and training
People carry out only the tasks they are competent and qualified to do. Where the law requires special training (特別教育) or a licence, for example for full-body harness use or operating aerial work platforms, we make sure it has been completed before the work is assigned.
We provide induction and ongoing training relevant to each person’s role, covering safe installation practices, equipment handling, emergency response and environmental protection.
8. Personal protective equipment
We provide suitable personal protective equipment, such as helmets, safety footwear, harnesses, gloves and eye protection, where the risk assessment or site rules require it. Everyone must wear it correctly and report damaged or missing equipment.
9. Incident reporting and investigation
Injuries, near misses, unsafe conditions and environmental incidents must be reported promptly to the project lead or the Representative Director, and to the main contractor when on a construction site.
We investigate incidents to find their root causes and put corrective actions in place to prevent them happening again. Where the law requires it, we submit a report of worker injury or death (労働者死傷病報告) to the Labour Standards Inspection Office.
10. Health and wellbeing
We provide health checks for employees as required by the Industrial Safety and Health Act and support mental health at work. We aim to manage workloads and working hours responsibly and encourage staff to raise any health concerns early.
We monitor changes in the law, including the planned extension of mandatory stress checks to smaller workplaces, and will update our practices as they take effect.
11. Environmental responsibility
We work to reduce the environmental impact of our operations by:
- using energy responsibly in our office and recommending energy-efficient equipment to clients where suitable;
- reducing and separating packaging and installation waste on site;
- disposing of industrial waste through licensed waste contractors and using the manifest system to track it;
- arranging recycling of business-use PCs and electronic equipment through manufacturer take-back schemes or licensed processors;
- planning deliveries and site visits to reduce unnecessary vehicle use;
- considering durability, repairability and environmental impact when selecting equipment.
12. Data-bearing devices
Computers, storage devices, recorders and similar equipment can contain client or personal data. Before any such device is reused, recycled or disposed of, the data must be securely erased or the storage physically destroyed. Where a client requests it, we arrange evidence of erasure or destruction.
13. Speak Up
Anyone can raise a concern about health, safety or environmental matters, or about a breach of this policy. Reports can be made to the Representative Director directly or by email to compliance@milestonetc.asia with “Confidential” in the subject line.
mtc will protect the confidentiality of the person reporting and prohibits retaliation against anyone who raises a concern in good faith, in line with the Whistleblower Protection Act (公益通報者保護法). No one will be penalised for stopping work they reasonably believe to be unsafe.
14. Review
We review this policy at least once a year, and sooner if the law, our operations or the results of an incident investigation call for it. We use staff feedback, incident findings and internal checks to improve our practices.
Policy owner: Representative Director. Effective and last updated: 1 October 2026.
Legal references
- Industrial Safety and Health Act (労働安全衛生法)
- Ordinance on Industrial Safety and Health (労働安全衛生規則)
- Construction Business Act (建設業法)
- Electricians Act (電気工事士法)
- Fire Service Act (消防法)
- Waste Management and Public Cleansing Act (廃棄物の処理及び清掃に関する法律)
- Act on the Promotion of Effective Utilization of Resources (資源の有効な利用の促進に関する法律)
- Whistleblower Protection Act (公益通報者保護法)
- ISO 45001 and ISO 14001 (aligned with, not certified)
Contact and reporting concerns
Questions about this policy, requests and reports of concerns can be made to Leon Appleby, Representative Director, directly or by email to compliance@milestonetc.asia (please write “Confidential” in the subject for reports). You can also call 03-6773-5523, 9:30 to 18:30 on weekdays excluding public holidays. mtc will not tolerate retaliation against anyone who raises a concern in good faith.
mtc K.K. (株式会社エム・ティー・シー), 2F Tosei Building, 18-10 Nihonbashi Hakozakicho, Chuo-ku, Tokyo 103-0015, Japan. This policy is governed by the laws of Japan.
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