OLC Group Supplier Code of Conduct

The OLC Group is committed to bringing happiness into the world through experiences found nowhere else. This is expressed in our corporate mission to “create happiness and contentment by offering wonderful dreams and moving experiences created with original, imaginative ideas.”


In order to achieve a sustainable society, it is essential for not only our company but the whole supply chain to consider social and environmental impacts, and mitigate risks.


We thus request that all our suppliers to understand and comply with the content and directives of this OLC Group Supplier Code of Conduct. We also ask for your cooperation in expanding this initiative throughout the supply chain by requesting your business partners to comply the contend of this Code.
We as a Group also intend to adhere to the same principles of this Code.

1. Legal compliance and respect for international standards

1-1. Legal compliance and respect for international standards

  • In the course of conducting business, suppliers must comply with the laws and regulations applicable in each country or region, receive necessary permits and licenses, and respect relevant international standards and social norms.


1-2. Management systems

  • Suppliers should establish practices to ensure legal compliance, such as policies, code of conduct, management systems, internal reporting systems and education.
  • Suppliers must ensure that those who use internal reporting hotlines are not subject to unfair treatment or retaliation.
  • Suppliers should be prepared for natural disasters, impacts of climate change, spread of disease, political instability or other unforeseeable circumstances by establishing a business continuity plan or other systems to set forth measures and procedures that minimize harm, as well as ensure continued stable supply and early-stage recovery of production.

2. Quality and safety

2-1. Product and service safety

  • To provide safe products and services, suppliers must not only comply with relevant laws and their own internal safety and quality standards, but also strive to maintain a reasonable level of safety. For product safety, this includes management of traceability (a record of materials, parts, processes, etc.) and rapid response measures to resolve any issues.
  • In case of accidents involving products and services or shipment of defective products, or if one of these is suspected to have occurred, suppliers are to take necessary measures such as promptly informing business partners or relevant authorities, recalling products and disclosing information, and should establish systems to implement necessary measures that prevent recurrence.


2-2. Disclosure of product safety information

  • For products to be sold to customers, suppliers should strive to give due consideration to indications (indications of warnings, precautions, etc.) related to usage, and methods of use, that should be described on the product or attached instruction manuals.

3. Human rights and labor

3-1. Support for international human rights standards and response to negative human rights impacts

  • Suppliers must respect the human rights of those involved in their value chain, including their own workers, in accordance with the human rights standards supported by the OLC Group in our Human Rights Policy Statement. Special consideration should be given to those who likely to be in more vulnerable circumstances, such as indigenous peoples, local residents, immigrant workers, children, people with a disability, LGBT, women and foreigners, and workers who are involved in raw material production etc.
  • Suppliers should determine if their operations, business relationships, products and services have any negative impacts on human rights, and work toward prevention, mitigation or remediation. They should also strive to disclose their progress and results.
  • Suppliers should conduct necessary training to provide all executives and employees with knowledge on respecting human rights.

3-2. Working hours

  • Suppliers must comply with working hour laws and regulations of a country or a region where they operate. The standards of 48 hours per week for regular working hours and 12 hours of overtime per week, or the equivalent if calculated on a monthly or annual basis should be respected. In Japan, based on applicable laws and regulations, working hours should not exceed 8 hours per day and 40 hours per week. Overtimes should be managed in principle within 45 hours per month and 360 hours per year, and if overtime exceeds this limit, an agreement between the employer and workers must be made and submitted (to the authorities) in accordance with the law.
  • Suppliers must appropriately manage employee holidays and leave, including by ensuring that the number of fixed working days per year does not exceed the legal limit, that employees are given at least one day off after 6 consecutive work days, and that they are entitled to annual paid leave as stipulated by law.


3-3. Wages and remuneration

  • In exchange for their services, suppliers must pay workers wages that at the very least exceed the legal minimum wage, and ensure that wages are properly paid, including overtime pay.
  • Suppliers must not make any unfair wage reductions that violate applicable work-related laws, and should issue workers with pay slips that include details on allowances and wage deductions.
  • Suppliers must provide all legally mandated benefits and welfare programs.


3-4. Discrimination

  • In the recruitment, employment and treatment of workers, suppliers must not engage in unfair discrimination based on factors such as a person’s sex, age, race, nationality, language, culture, religion, disability, sexual orientation, and gender identity.


3-5. Child labor

  • Suppliers must not employ anyone under the age of 15, which is the minimum working age stipulated in the conventions and recommendations of the International Labour Organization. In exceptional cases where the national law of a country sets the legal minimum age for employment as 14, this standard may be followed.
  • Suppliers must not allow anyone under the age of 18 to perform hazardous work, night shifts, or work that may be detrimental to their health, safety or morals.


3-6. Harassment

  • Supplier must prohibit harsh and inhumane treatment toward workers, including sexual harassment or abuse, corporal punishment, mental or physical coercion, and verbal abuse. Inhumane treatment includes all types of harassment, including sexual and power harassment. Special attention should be given to the treatment of workers likely to be in more vulnerable positions at workplaces.
  • Suppliers must provide an internal or external helpline for cases of harassment or other issues, and protect those that use the helpline from unfair treatment or retaliation.


3-7. Forced labor

  • Suppliers must not use forced labor that goes against a worker’s will, bonded labor that restricts a worker’s freedom to quit because of debts, or slave labor derived from human trafficking, and must not be complicit in promoting these types of labor by utilizing them as external work forces or prison labor. Suppliers must also ensure workers’ right to quit freely.
  • When employing foreign workers, suppliers must confirm residency status and make any necessary reports to the relevant administrative bodies following the laws of the countries and regions of their business activities. Suppliers should also inform workers of employment conditions in a language they understand.
  • Suppliers must not confiscate workers’ ID cards, passports, work permits or other documents that should fundamentally be held by workers themselves, which would obstruct workers’ freedom to use those documents or freedom of movement.
  • Workers shall not pay labor recruitment fees or other fees related to the employment of workers' recruiters or their contractors. If a worker has paid costs regarding their employment, suppliers must refund those costs to the worker.


3-8. Freedom of association and collective bargaining

  • Suppliers must not obstruct workers’ freedom of association, freedom to join and act in a labor union according to law as a means to engage in labor-management negotiations about working environments, wage level, or other issues.
  • Suppliers must respect workers or their representatives to be able to voluntarily discuss and negotiate with management regarding working conditions and management practices without retaliation, intimidation, or harassment.

4. Health and safety

4-1. Health and safety management

  • Suppliers must provide legally mandated safe and healthy working environments by identifying and taking effective preventative measures against risk of accidents, injuries and illness. 
  • Suppliers should strive for prevention and early detection of work-related illnesses through measures such as health check-ups conducted to the legally-stipulated level at minimum.


4-2. Health and safety of working environment 

  • To prevent accidents and health hazards, suppliers must adopt safety mechanisms for machinery, equipment and plant facilities, and perform regular inspections and maintenance. Worker safety should be managed using sensors or visual supervision, and protective equipment provided when necessary. Suppliers should also conduct periodic safety training for workers.
  • If workers may come into contact with substances hazardous to the human body, suppliers must identify direct contact opportunities and establish and implement safety standards. Education and protective equipment must also be provided when necessary.
  • Suppliers must ensure that workplaces—including offices, workshops and factories—and facilities—including cafeterias , breakrooms, restrooms, locker rooms, dressing rooms, water stations, and dormitories— provided to workers  remain safe and clean, and appropriately manage environmental factors such as facility temperature, humidity, air circulation and lighting.
  • Suppliers must ensure the structural safety of buildings where workers work.
  • Suppliers must not impose unreasonable restrictions on entry and exit to facilities and freedom of movement.


4-3. Occupational accidents

  • In case an occupational accident occurs, suppliers must have a system in place to report, record the type of accident, provide support for appropriate medical treatment, investigate the cause and take corrective action.


4-4. Emergency response

  • In case of emergency, suppliers must provide obstruction-free escape routes, install emergency exit sign lighting, fire detectors, fire extinguishers and other fire-fighting equipment, furnish disaster supply kits, ensure a means of notification and communication, and clarify evacuation methods.


4-5 Health and safety communication

  • To prevent accidents, injuries and illnesses, and to respond to emergencies, suppliers must provide information on health and safety, conduct education and training, and practice evacuation drills in a language that workers can understand.

5. Fair trade and anti-corruption

5-1. Fair trade

  • Suppliers must not engage in any conduct that impedes fair, transparent or free trade, such as cartels, collusion, misrepresentation, unfair trading, or the giving or receiving of improper benefits.
  • Suppliers must not act in a way that would disadvantage business partners by unilaterally deciding transaction details in their own favor, such as by using their superior position as a buyer to prohibit partner transactions with competitors.
  • Following the Subcontracting Act or other similar laws and regulations of countries where business is conducted, suppliers should seek to conduct fair transactions, ensure that documents related to transactions are issued, and not delay or unreasonably reduce subcontracting payments.


5-2. Anti-bribery

  • Suppliers must not engage in bribery, corruption or illegal donations, such as providing money, gifts or entertainment to politicians or public officials in return for business-related favors including obtaining permits and licenses, acquiring business and obtaining confidential information.
  • Suppliers must not provide or receive entertainment, gifts or benefits from business partners or customers beyond what is considered socially acceptable.


5-3. Intellectual property rights

  • In the production, development, sales and provision of products and services, suppliers must respect third-party intellectual property rights—including patent rights, utility model rights, design rights, trademark rights, copyright, trade secrets and product form—and not infringe upon holders’ rights.


5-4. Personal and confidential information

  • Suppliers must establish defensive measures against network security threats such as computer viruses, illegal software and hacking, and have appropriate information management systems in place to avoid internal and external influence and damage.
  • Suppliers must appropriately manage personal information and confidential information belonging to their own company and business partners, and establish protective management systems. When acquiring personal information, suppliers must indicate the purpose and not use such information for other reasons, nor disclose it to third parties.


5-5. Organized criminal groups

  • Suppliers must not have any dealings with organized criminal groups, which have a detrimental impact on public order and sound business activities, and take a firm stance against such groups without giving in to their demands.
  • When concluding a business contract, suppliers must confirm or declare and guarantee that the other party is not an organized criminal group. If the other party is found to be such a group, the contract must not be signed. Suppliers should also include a special clause in contracts to allow for termination if the other party is found to be an organized criminal group after signing.

6. Ethical procurement

6-1. Responsible raw material procurement

  • To avoid using raw materials, parts, and components that cause human rights or environmental issues, such as mineral resources that may contribute to conflict and crime, or paper resources that may be linked to deforestation, suppliers should conduct initiatives to understand current practices and prevent future issues.

6-2. Animal welfare

  • Suppliers must comply with laws related to animal welfare, and also strive to adhere as closely as possible to International Organization for Standardization standards related to animal living conditions, behavior, and physical and mental wellbeing.

7. Environment

7-1. Environmental management system

  • To promote environmental conservation and reduce their environmental impact, suppliers should establish an environmental management system, set internal standards and benchmarks that either meet or exceed the standards stipulated by law, and work toward continuous improvement by regularly reviewing implementation.


7-2. Climate change response

  • Suppliers should work to reduce their greenhouse gas emissions through energy conservation and effective use of renewable energy.


7-3. Sustainable use of resources

  • Suppliers should promote waste reduction and more effective use of resources through the environmental “three Rs” of reduce, reuse and recycle.
  • Suppliers should seek to use environmentally-conscious containers and packaging.


7-4. Water resources and biodiversity

  • Suppliers should appropriately manage water withdrawal and discharge infrastructure and water quality, and work toward reduced and effective usage of water resources.
  • Suppliers should engage in business activities in consideration of biodiversity.

7-5. Chemicals

  • Suppliers must engage in appropriate management of hazardous chemical substances in accordance with the laws and regulations of the countries and regions where they operate, and work toward reducing chemical emissions. They should also engage in the necessary assessment and reporting of emissions.

OLC Group Supplier Code of Conduct Application Regulations

We ask for the following cooperation from our suppliers in applying the OLC Group Supplier Code of Conduct.


1. Application

  • To comply with this Code, we expect our suppliers to understand, permeate and continuously improve business activities.
  • We also request that our suppliers’ own business partners understand, share and continuously work toward improving their adherence to this Code.
  • If there is any discrepancy between the Code and international standards, or between the Code and suppliers’ interpretation of the laws and regulations of the regions where they operate, we expect them to strive to comply with the strictest requirements.
  • Compliance with this Code is one criteria that will be used in determining whether our Group should begin or continue a partnership.


2. Monitoring

  • We will conduct periodic evaluation and monitoring to confirm Code compliance.
  • We expect suppliers to appropriately keep documentation and records that prove Code compliance. The OLC Group may ask for these to be disclosed or shared.
  • To ensure surveys are effective, the OLC Group or a third-party organization may enter all facilities related to products and services, contact all workers in the facility and access relevant documents upon prior notice.

3. Corrective measures

  • If a supplier is in any way noncompliant with this Code, we ask that they take corrective measures toward improvement.
  • If there are any major infringements related to this Code yet no reports made or appropriate corrective measures taken, we may take reasonable steps including rejecting new contracts or terminating existing contracts.


4. Scope of application

  • This Code is applicable to the suppliers of all products, services and materials procured by the OLC Group. It is applicable throughout the entire supply chain, including indirect suppliers (such as suppliers or subcontractors of our suppliers).