Anti-Competition Law Compliance Policy

Here at NITORI Group, we embrace the mission (aspiration) of “To enrich the homes of people all over the world”, and it is the cornerstone of how we conduct business. This mission can only be realized when our day-to-day operations are carried out in a sound manner.

We believe that engaging in “fair and honest transactions” with all stakeholders as stipulated in NITORI Group Code of Conduct is essential to ensure the soundness of our operation and business practice.
This Anti-Competition Law Compliance Policy (“Policy”) is established for the purpose of declaring and confirming our objective to comply with applicable anti-competition laws in all countries and regions where we conduct business.

1．Policy Framework

  1. With respect to all our business transactions and liaison activities, we comply with the “Act Concerning Prohibition of Private Monopolization and Maintenance of Fair Trade” of Japan and applicable laws of which the purpose is to facilitate fair and free market competition (“Anti-Competition Law”), and do not act in contrary to the principles thereof .
  2. We under no circumstances condone any benefits that cannot be obtained unless through unfair or dishonest transactions. We, the directors and employees of NITORI Group, undertake to act in good faith to conduct all our business transactions and liaison activities in a “fair and honest” manner.

2．Scope of Application

This Policy applies to all member entities of NITORI Group, all directors and employees, part-time employees, seconded employees and temporary employees, which are any personnel whom NITORI GROUP holds employment relationship with (“Directors and Employees”). In addition, we seek from all other entities, individuals and public officials concerning our business activities in any way (“Concerned Stakeholder”) their understanding on this Policy and respective cooperation.

3．Prohibited Acts

  1. We do not engage in acts that obstruct or hinder fair and honest competition, such as placing restraints of trade on price or production (i.e. cartel), price fixing, bid-rigging, or arranging market share by unfair agreement with competitors.
  2. We do not engage in acts that exclude other players from the market, such as eliminating competitors from the market or interfering with their market entry.
  3. We do not engage in acts that unfairly exploit any counterparty by taking advantage of our superior bargaining position.

4．Principles of Conduct for Directors and Employees

  1. Directors and Employees comply with Anti-Competition Law, this Policy and related internal rules and regulations, and do not engage in acts prohibited therein.
  2. As Directors and Employees, we limit our communications with competitors to only the extent necessary for carrying out our business. In case of any exchanges, we keep and maintain records of the reasons and details thereof. No communication with any competitor would take place if such is being suspected of the exchange of anti-competitive information.
  3. For any acts committed where the principles of Anti-Competition Law have been, or are suspected of having been violated, as Directors and Employees, we report to our supervisors, legal and compliance departments, or whistleblowing body without delay. Directors and Employees act in good faith to accommodate investigations from competent, governing authorities of Anti-Competition Law in all related jurisdictions, if any.
  4. For any planned acts where the principles of Anti-Competition Law is suspected of being violated, Directors and Employees seek advice from the appropriate, responsible body without delay, such as our supervisors and our legal and compliance departments.

5．Anti-Competition Law Compliance Structure

  1. We provide the necessary Anti-Competition Law education to Directors and Employees, and continue to raise awareness on Anti-Competition Law compliance.
  2. We have in place an Anti-Competition Law compliance structure consists of this Policy, related internal rules and regulations, and an internal control system, and will undertake review of the system on a regular basis.

6．Whistleblowing System

We establish a whistleblowing body of which Directors and Employees and Concerned Stakeholders may report to and consult with.
We respond without delay and in an appropriate manner to any whistleblower reports where the suspicion of the principles of Anti-Competition law being violated is confirmed.

7．Violation of this Policy

  1. Directors and Employees in violation of this Policy and related internal rules and regulations are subject to appropriate disciplinary actions or other measures, pursuant to applicable internal rules and regulations.
  2. Concerned Stakeholders in violation of this Policy are subject to other measures as we deem appropriate.

Enactment Date: May 14, 2023