Purpose and scope
This Code sets out what mtc expects of its suppliers, subcontractors and business partners, and what suppliers can expect from mtc as a buyer. It applies to all goods and services supplied to mtc and to all work performed on mtc projects.
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. Purpose and scope
mtc (株式会社エム・ティー・シー) is a Tokyo-based IT, AV and physical security integrator. We rely on suppliers, subcontractors and business partners to deliver our projects, and we expect them to work ethically, lawfully and safely.
This Code applies to every organisation and individual that supplies goods or services to mtc, including sole traders and freelancers, and to anyone who performs work on an mtc project. Suppliers must pass the requirements of this Code on to any lower-tier subcontractors they engage for mtc work.
This Code sits alongside our contracts. Where a contract sets a more specific or stricter requirement, the contract applies.
2. Our commitments as a buyer
Fair dealing goes both ways. Japanese law places clear duties on businesses that entrust work to others, and mtc commits to meeting the duties that apply to our transactions. In particular, we will:
- set out the scope of work, price, delivery date and payment terms clearly and in writing before work starts;
- agree prices through genuine discussion, and not set or reduce prices unilaterally;
- pay the agreed amount on time and by the agreed method, without unjustified deductions or delays;
- not use our position to impose unreasonable demands, such as returning goods without a valid reason, requesting unpaid extra work, or setting unreasonably short schedules;
- for construction work, use written contracts, avoid contract prices below the cost of properly performing the work, and follow the fair-contracting and payment rules of the Construction Business Act (建設業法);
- for work entrusted to freelancers and sole traders, provide the written terms and meet the payment and other obligations required by the Freelance Act;
- for other entrusted work covered by the amended fair transactions law in force from 1 January 2026, meet the obligations that apply to us under that Act;
- not reduce prices or change terms simply because a supplier is or is not registered under the Qualified Invoice System (適格請求書等保存方式) without proper discussion;
- not treat a supplier unfavourably because it has raised a concern or reported a possible breach of these commitments.
3. Compliance with laws
Suppliers must comply with the laws and regulations that apply to their business and to the work they perform for mtc, in Japan and in any other country where they operate. This includes labour, health and safety, environmental, privacy, anti-corruption and trade control laws.
Where this Code sets a higher standard than local law, suppliers should meet the higher standard where lawful to do so.
4. Human rights and labour
We expect suppliers to respect human rights in line with the UN Guiding Principles on Business and Human Rights, the Japan National Action Plan on Business and Human Rights and the METI Guidelines on Respecting Human Rights in Responsible Supply Chains. Suppliers must:
- not use forced, bonded, compulsory or child labour, or take part in human trafficking;
- not retain workers’ passports, residence cards or other identity documents, and not charge workers recruitment fees;
- pay at least the legal minimum wage, keep working hours within legal limits, and meet the Labour Standards Act (労働基準法) and Minimum Wage Act (最低賃金法);
- enrol workers in social insurance where required by law;
- provide a workplace free from discrimination, harassment, bullying and abuse;
- respect workers’ freedom of association as provided by law.
5. Residence status of personnel on mtc projects
Everyone who works on an mtc project must be a resident of Japan with a valid status of residence that permits the work they perform. Suppliers must check the residence card (在留カード) and work permission of each foreign worker they assign to mtc work before that person starts, keep the check up to date, and provide confirmation to mtc on request.
Suppliers must comply with the Immigration Control and Refugee Recognition Act (出入国管理及び難民認定法). Assigning a person who is not permitted to perform the work is a serious breach of this Code.
6. Health and safety
Suppliers must provide a safe and healthy working environment and comply with the Industrial Safety and Health Act (労働安全衛生法) and related regulations. On mtc projects and client sites, suppliers must:
- follow mtc’s site safety instructions and the rules of the client and any main contractor;
- assign only workers with the qualifications and training required for the task, including licensed electricians for electrical work under the Electricians Act (電気工事士法) and special training for work at height where required;
- provide and use appropriate personal protective equipment;
- take measures against heat stress;
- report accidents, injuries, near misses and unsafe conditions to mtc promptly.
7. Environment
Suppliers must comply with applicable environmental laws and work to reduce their environmental impact through responsible use of energy and materials and proper management of waste.
Industrial waste, including packaging and removed equipment, must be handled in accordance with the Waste Management and Public Cleansing Act (廃棄物の処理及び清掃に関する法律), including the manifest system where it applies. Equipment that stores data must have its data securely erased or destroyed before disposal, and suppliers must provide evidence of this when mtc requests it.
8. Ethical business conduct
Suppliers must act with integrity and honesty in all dealings with mtc, our clients and public officials.
- Bribery and corruption in any form are prohibited, including facilitation payments. This applies to dealings with public officials under the Penal Code (刑法) and the Unfair Competition Prevention Act (不正競争防止法), and to dealings with private businesses as a matter of mtc policy.
- Suppliers must not offer mtc personnel or our clients any gift, hospitality or other benefit intended to influence a business decision. Any gift or hospitality must be modest and transparent.
- Suppliers must disclose to mtc any conflict of interest, such as a personal or financial relationship with an mtc employee involved in selecting or managing the supplier.
- Suppliers must not engage in bid rigging, price fixing or other anti-competitive conduct.
- Suppliers must keep accurate business records and invoices for work performed for mtc.
9. Exclusion of anti-social forces
mtc does not deal with anti-social forces (反社会的勢力), including organised crime groups, their members and associated persons or companies. 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), suppliers must:
- confirm that neither they, nor their officers, major shareholders or subcontractors, are or have links with anti-social forces;
- not provide funds or other benefits to anti-social forces, or use them in any way in connection with mtc work;
- refuse any unjust demand from anti-social forces and report it to mtc and, where appropriate, the police;
- notify mtc immediately if any of these confirmations stops being true.
10. Information security and confidentiality
Suppliers must protect confidential information belonging to mtc and our clients, including site plans, network details, security system configurations and access credentials. Such information must be used only for the purpose of the work and must not be disclosed without authorisation.
Where suppliers handle personal information on our behalf, they must comply with the Act on the Protection of Personal Information (個人情報の保護に関する法律), apply appropriate security measures, follow our instructions, and tell mtc promptly about any actual or suspected data breach.
11. Trade compliance
Suppliers must comply with export control and trade laws that apply to the goods, software and technology they supply, including the Foreign Exchange and Foreign Trade Act (外国為替及び外国貿易法). This is particularly relevant to security products and products that include encryption. Suppliers must tell mtc if any product they supply is subject to export restrictions.
12. Subcontracting
Suppliers must not subcontract any part of mtc work without our prior approval. Any approved subcontractor must meet the requirements of this Code, and the supplier remains responsible for its subcontractors’ compliance. mtc may approve or decline a proposed subcontractor.
13. Monitoring and corrective action
mtc may check supplier compliance with this Code through reasonable means, such as questionnaires, document reviews or site visits, with reasonable notice. Suppliers should cooperate with these checks.
If we find a breach, we will normally work with the supplier on a corrective action plan. Serious or repeated breaches, including any link to anti-social forces or the use of workers without a valid status of residence, may lead to suspension or termination of the business relationship, in accordance with our contract.
14. Speak Up: reporting concerns
Suppliers, their workers and anyone else may report a concern about a possible breach of this Code, unethical behaviour or a breach of mtc’s own commitments as a buyer. Reports can be made to the Representative Director directly or by email to compliance@milestonetc.asia with “Confidential” in the subject line. You can also contact us by phone on 03-6773-5523 (9:30 to 18:30, weekdays excluding public holidays).
mtc will protect the confidentiality of the reporter and the report as far as possible 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). Suppliers must not retaliate against their own workers for raising concerns.
15. Acknowledgement, ownership and review
We may ask suppliers to confirm in writing that they have read and will comply with this Code.
This Code is owned by the Representative Director of mtc and is reviewed periodically and when relevant laws change. Effective and last updated: 1 October 2026.
mtc (株式会社エム・ティー・シー), 2F Tosei Building, 18-10 Nihonbashi Hakozakicho, Chuo-ku, Tokyo 103-0015, Japan. Representative: Leon Appleby, Representative Director.
Legal references
- Act Against Delay in Payment of Fees, etc. to Small and Medium-sized Entrusted Business Operators in Manufacturing and Other Specified Fields (製造委託等に係る中小受託事業者に対する代金の支払の遅延等の防止に関する法律)
- Act on Ensuring Proper Transactions Involving Specified Entrusted Business Operators (Freelance Act) (特定受託事業者に係る取引の適正化等に関する法律)
- Construction Business Act (建設業法)
- Antimonopoly Act (私的独占の禁止及び公正取引の確保に関する法律)
- Labour Standards Act (労働基準法)
- Minimum Wage Act (最低賃金法)
- Immigration Control and Refugee Recognition Act (出入国管理及び難民認定法)
- Industrial Safety and Health Act (労働安全衛生法)
- Electricians Act (電気工事士法)
- Waste Management and Public Cleansing Act (廃棄物の処理及び清掃に関する法律)
- Penal Code (刑法)
- Unfair Competition Prevention Act (不正競争防止法)
- 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)
- Act on the Protection of Personal Information (個人情報の保護に関する法律)
- Foreign Exchange and Foreign Trade Act (外国為替及び外国貿易法)
- Whistleblower Protection Act (公益通報者保護法)
- Japan National Action Plan on Business and Human Rights (「ビジネスと人権」に関する行動計画)
- 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)
- UN Guiding Principles on Business and Human Rights
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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