Purpose and scope
This policy sets out mtc’s zero-tolerance approach to bribery and corruption and its commitment to excluding anti-social forces from its business. It applies to everyone who works for or on behalf of mtc, in Japan and abroad.
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. Policy statement
mtc does not tolerate bribery or corruption in any form, whether in dealings with public officials or with private businesses. We win and keep work on the quality, price and reliability of what we deliver.
mtc also refuses any relationship with anti-social forces (反社会的勢力), including organised crime groups and the people and businesses connected to them.
This policy is owned by the Representative Director and is effective from 1 October 2026.
2. Scope
This policy applies to mtc’s directors, employees and temporary staff, and to contractors, subcontractors, agents and other third parties when they act for or on behalf of mtc. It applies to our work in Japan and to any work outside Japan.
3. Legal framework
mtc’s approach is based on Japanese law. The main laws and guidelines are listed below.
Some of our multinational clients are subject to the UK Bribery Act 2010 and the US Foreign Corrupt Practices Act (FCPA) and may include related terms in their contracts with us. These laws are not generally mtc’s own legal obligation, but this policy is designed to align with the standards they expect, and we will meet any such contractual terms we agree to.
- Penal Code (刑法): prohibits giving, offering or promising a bribe to a Japanese public official, and applies to officials who request or accept one. Some employees of public bodies and certain companies are treated as public officials by law (みなし公務員), so the same rules apply to them.
- Unfair Competition Prevention Act (不正競争防止法): prohibits bribery of foreign public officials. Amendments in force from 1 April 2024 significantly increased the penalties for individuals and companies, widened the Act’s reach to cover foreign employees of Japanese companies acting overseas, and extended the limitation period.
- National Public Service Ethics Act (国家公務員倫理法) and equivalent local government ethics rules: restrict the gifts and hospitality that public officials may accept.
- METI Guidelines for the Prevention of Bribery of Foreign Public Officials (外国公務員贈賄防止指針), as revised in 2024.
- Tokyo Metropolitan Ordinance on the Exclusion of Organised Crime Groups (東京都暴力団排除条例) and equivalent ordinances in other prefectures where we work.
- Act on Prevention of Unjust Acts by Organised Crime Group Members (暴力団員による不当な行為の防止等に関する法律).
4. Prohibited conduct
No one covered by this policy may offer, promise, give, request or accept a bribe, kickback or anything else of value intended to improperly influence a decision, secure an unfair advantage, or obtain or keep business.
“Anything of value” is broad. It includes cash, gifts, hospitality, travel, loans, discounts, favours, job offers, donations and sponsorships.
These rules apply to public officials and private individuals alike, in Japan and abroad, regardless of local custom. Offering or giving a bribe through a third party is treated the same as doing it directly.
5. Facilitation payments
Facilitation payments are small unofficial payments made to speed up or secure a routine action, such as issuing a permit, clearing goods or arranging an inspection. mtc prohibits them in all circumstances, in line with the recommendation in the METI guidelines.
The only exception is where a person faces an immediate threat to their health, safety or liberty. Any payment made in that situation must be reported to the Representative Director as soon as possible and recorded.
6. Private-sector bribery
Japanese law does not contain a general offence of bribery between private businesses, and only narrow offences apply. Regardless, mtc prohibits bribery of and by private-sector clients, suppliers and partners as our own standard. This includes the employees of clients, main contractors, building managers and suppliers.
7. Gifts and hospitality
Modest gifts and business hospitality can be a normal part of building relationships in Japan. They must never be used, or appear to be used, to improperly influence a business decision.
Any gift or hospitality given or received must be:
- modest in value and appropriate to the occasion;
- given or received openly, and never in cash or cash equivalents such as gift cards;
- lawful, and permitted under the recipient’s own rules;
- not given or received while a tender, contract award or approval involving the other party is pending, unless approved in advance by the Representative Director;
- approved in advance by the Representative Director where its value is above mtc’s internal threshold, and recorded.
- Extra care is required with public officials. Gifts and hospitality to public officials, including deemed public officials, must be approved by the Representative Director in advance.
8. Donations and sponsorships
mtc does not make political donations. Charitable donations and sponsorships must be approved by the Representative Director in advance, made transparently and never linked to a business decision.
9. Conflicts of interest
Staff must tell the Representative Director about any personal, family or financial interest that could affect, or appear to affect, their decisions for mtc, such as an interest in a supplier or client. The Representative Director will decide how the conflict is managed.
10. Third parties and business partners
We expect suppliers, subcontractors, agents and partners to act with integrity and not to engage in bribery or corruption on our behalf.
Before engaging a third party, we carry out reasonable due diligence proportionate to the risk and the work involved. Our contracts may include anti-bribery and anti-social forces terms. We will end any relationship where bribery, corruption or a link to anti-social forces is confirmed, and may suspend it while a concern is investigated.
11. Exclusion of anti-social forces
Anti-social forces (反社会的勢力) are groups or individuals who pursue economic gain through violence, threats or fraud. They include organised crime groups (暴力団), their members and former members within the period set by law or contract, their associated companies, and others who act with or for them.
In line with the Tokyo Metropolitan Ordinance on the Exclusion of Organised Crime Groups (東京都暴力団排除条例) and the Act on Prevention of Unjust Acts by Organised Crime Group Members (暴力団員による不当な行為の防止等に関する法律), mtc:
- has no business or other relationship with anti-social forces, directly or through third parties;
- makes reasonable efforts to confirm that new clients, suppliers and partners are not anti-social forces;
- includes clauses in its contracts, where possible, under which each party confirms it is not an anti-social force and which allow termination if that proves untrue;
- refuses unreasonable demands, and never makes payments or provides benefits to anti-social forces, including to settle a dispute or avoid trouble;
- responds to any approach as an organisation rather than leaving an individual to deal with it, and consults the police and legal advisers where appropriate.
12. Books and records
mtc keeps accurate and complete records of payments, expenses, gifts and hospitality. No payment may be disguised, recorded falsely or left off the books.
13. Training
Staff receive guidance on this policy when they join mtc and when it changes. Staff in roles with higher exposure, such as sales and procurement, may receive further training.
14. Speak up
Anyone who suspects bribery, corruption, a link to anti-social forces or any other breach of this policy should report it. 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 reports and will look into concerns promptly and fairly. mtc 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).
If you are asked for a bribe or approached by anyone you believe may be an anti-social force, do not agree to anything. Report it to the Representative Director straight away.
15. Breaches
Breaches of this policy may lead to disciplinary action, up to and including dismissal, or to termination of a contract. Bribery and dealings with anti-social forces may also lead to criminal or civil liability under Japanese law, for the individuals involved and for mtc.
16. Review
The Representative Director owns this policy and will review it at least annually, and sooner if the law or our business changes. Last updated: 1 October 2026.
Legal references
- Penal Code (刑法)
- Unfair Competition Prevention Act (不正競争防止法)
- National Public Service Ethics Act (国家公務員倫理法)
- METI Guidelines for the Prevention of Bribery of Foreign Public Officials (外国公務員贈賄防止指針)
- Tokyo Metropolitan Ordinance on the Exclusion of Organised Crime Groups (東京都暴力団排除条例)
- Act on Prevention of Unjust Acts by Organised Crime Group Members (暴力団員による不当な行為の防止等に関する法律)
- Whistleblower Protection Act (公益通報者保護法)
- UK Bribery Act 2010 (client alignment)
- US Foreign Corrupt Practices Act (client alignment)
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.
Related policies