Purpose and scope
This policy sets out how mtc respects human rights and works to prevent forced labour, child labour, human trafficking and other forms of modern slavery in its own operations and in the work of its subcontractors and suppliers. It applies to everyone who works for or on behalf of mtc in Japan.
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 believes that everyone should be treated with dignity, fairness and respect. We are committed to respecting human rights in everything we do, and we do not tolerate any form of modern slavery, including forced labour, bonded labour, child labour and human trafficking.
This policy is guided by the UN Guiding Principles on Business and Human Rights, the ILO core labour standards, Japan’s National Action Plan on Business and Human Rights (「ビジネスと人権」に関する行動計画), as revised in December 2025, and the Ministry of Economy, Trade and Industry (METI) Guidelines on Respecting Human Rights in Responsible Supply Chains (責任あるサプライチェーン等における人権尊重のためのガイドライン, September 2022). The Japanese Government expects companies of every size to respect human rights, and we apply these frameworks in a way that is proportionate to a business of our size.
2. Scope
This policy applies to mtc’s directors, employees and temporary staff, and to everyone else who works on mtc projects. We also expect our subcontractors, suppliers and other business partners to meet the standards in this policy, and we set out our expectations of them in our Supplier Code of Conduct.
mtc operates in Japan. Everyone working on mtc projects is a resident of Japan with a valid status of residence permitting their work.
3. Legal framework
We work to comply with the laws that apply to our business in Japan, including:
- Labour Standards Act (労働基準法)
- Minimum Wage Act (最低賃金法)
- Industrial Safety and Health Act (労働安全衛生法)
- Labour Policy Comprehensive Promotion Act (労働施策総合推進法), including the duties to prevent power harassment and, from 1 October 2026, customer harassment
- Equal Employment Opportunity Act (男女雇用機会均等法)
- Immigration Control and Refugee Recognition Act (出入国管理及び難民認定法)
- Whistleblower Protection Act (公益通報者保護法)
4. Prohibited practices
mtc does not use, and will not accept in its operations or supply chain, any of the following:
- Forced, compulsory or involuntary labour, including prison labour
- Bonded labour or debt bondage
- Child labour, or the employment of anyone below the legal minimum working age
- Human trafficking in any form
- Holding workers’ passports, residence cards or other identity documents, or otherwise restricting their freedom of movement
- Charging workers recruitment fees or related costs for obtaining work
- Threats, violence, intimidation or withholding of wages to keep someone in work
5. Residence status and foreign workers
Before anyone starts work with mtc, we check their residence card (在留カード) to confirm that they hold a valid status of residence permitting the work, in line with the Immigration Control and Refugee Recognition Act (出入国管理及び難民認定法). We check again when a period of stay is due to expire.
We require our subcontractors to carry out the same checks for anyone they bring onto an mtc project.
Workers who are not Japanese nationals receive the same treatment, pay and conditions as other workers doing the same work. Where it helps, we explain employment terms and workplace rules in a language the worker understands.
6. Working conditions
All employment with mtc is voluntary, and employees are free to leave in line with their employment terms. Every employee receives clear written employment terms.
We pay at least the applicable minimum wage, manage working hours and overtime in line with the Labour Standards Act (労働基準法), and work to provide a safe and healthy workplace in line with the Industrial Safety and Health Act (労働安全衛生法).
7. Equality, dignity and harassment
We do not discriminate on the basis of gender, nationality, race, religion, age, disability, sexual orientation, gender identity or any other personal characteristic. Decisions about hiring, pay, training and promotion are based on ability and performance.
We take steps to prevent power harassment, sexual harassment and harassment related to pregnancy, childbirth or childcare, as required of employers under Japanese law. Because our staff often work on client premises, we also take measures to protect them from customer harassment (カスタマーハラスメント), in line with the duty that applies to all employers from 1 October 2026.
Anyone who experiences or sees harassment can raise it through the Speak Up channel described below.
This includes customer harassment (カスタマーハラスメント): abusive, threatening or unreasonable conduct towards our staff by clients, site visitors or other business contacts. From 1 October 2026, employers in Japan must take measures against customer harassment under the amended Act on Comprehensive Promotion of Labour Policies (労働施策総合推進法). mtc provides a way for staff to report incidents, including on client sites, responds promptly to protect the people affected, and may decline or end work where harassment continues.
8. Due diligence in our supply chain
We work mainly with established manufacturers, distributors and subcontractors. We take a risk-based approach that is proportionate to our size, focusing on areas where the risk to people is higher, such as on-site labour provided by subcontractors.
Our due diligence includes:
- Communicating our expectations to suppliers and subcontractors through our Supplier Code of Conduct
- Reviewing suppliers’ publicly available human rights policies or statements where appropriate
- Requiring subcontractors to confirm the residence status of their personnel on mtc projects
- Following up on any credible concern that is raised with us
9. Responding to concerns
If we find that mtc has caused or contributed to a negative human rights impact, we will act to stop it and to support an appropriate remedy for the people affected.
If a supplier or subcontractor does not meet our standards, we will first work with them to put things right. Where a serious issue is not addressed, we may suspend or end the relationship.
10. Speak Up
Employees, workers on mtc projects, supplier personnel and anyone else can report a concern about human rights, modern slavery or harassment connected with mtc. 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 making a report and prohibits retaliation against anyone who raises a concern, in line with the Whistleblower Protection Act (公益通報者保護法).
11. Modern slavery legislation and our clients
Many of our clients are international companies that report under laws such as the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018. mtc is not required to publish a statement under these Acts, but we support our clients in meeting their obligations. We are happy to answer reasonable supply chain questions and to cooperate with client due diligence.
12. Training and awareness
We make sure our team understands this policy, knows how to recognise signs of forced labour and exploitation, and knows how to raise a concern.
13. Responsibility and review
The Representative Director owns this policy and is responsible for its implementation. We review it at least once a year, and sooner if the law or our business changes.
Effective and last updated: 1 October 2026.
Legal references
- UN Guiding Principles on Business and Human Rights
- ILO Declaration on Fundamental Principles and Rights at Work (core labour standards)
- National Action Plan on Business and Human Rights (「ビジネスと人権」に関する行動計画), revised December 2025
- METI Guidelines on Respecting Human Rights in Responsible Supply Chains (責任あるサプライチェーン等における人権尊重のためのガイドライン), September 2022
- Labour Standards Act (労働基準法)
- Minimum Wage Act (最低賃金法)
- Industrial Safety and Health Act (労働安全衛生法)
- Labour Policy Comprehensive Promotion Act (労働施策総合推進法)
- Equal Employment Opportunity Act (男女雇用機会均等法)
- Immigration Control and Refugee Recognition Act (出入国管理及び難民認定法)
- Whistleblower Protection Act (公益通報者保護法)
- UK Modern Slavery Act 2015
- Modern Slavery Act 2018 (Cth), Australia
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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