Basic Policy on Customer Harassment

Protectstance Sports Management Co., Ltd. (hereinafter, “the Company”) has established the following Basic Policy on Customer Harassment (hereinafter, “this Policy”) to ensure that all employees working for the Company can work in a safe and secure environment.

1Response to Clients and Other Users

The Company, guided by a client-first spirit, values its gratitude toward clients and other users of the Company’s services (hereinafter, “Users”), and strives daily to respond sincerely to inquiries and requests in order to provide services of the highest possible quality.
While the Company regards opinions and requests from Users as valuable opportunities to improve its services and quality, some Users’ demands and conduct may include abusive language, intimidation, threats, or other behavior that undermines the dignity of employees.
Conduct that is objectively unjust and clearly excessive in light of social norms not only deteriorates employees’ work environment but may also adversely affect the provision of services to other Users. Therefore, the Company will respond resolutely to customer harassment in accordance with this Policy.

2Definition of Customer Harassment

For the purposes of this Policy, the Company defines “Customer Harassment” as behavior by Users that meets the following criteria, based on the “Customer Harassment Countermeasure Guidelines for Companies” published by the Ministry of Health, Labour and Welfare:
Harassing complaints or conduct by Users directed to the Company, the content of which, in light of the reasonableness of the demand, involves means or manners that are socially unacceptable, and that thereby harms the work environment of employees.
The following examples are illustrative and not exhaustive:

(1) Unreasonable Demands

• Unjustified demands relating to matters outside the Company’s authority
• Unjustified demands relating to matters that are difficult for the Company to accommodate
• Excessive demands that deviate from prescribed procedures
• Unjust insistence that imposes non-statutory obligations on the Company

(2) Socially Unacceptable Means or Conduct

• Physical assault or injury
• Threatening acts such as shouting, pounding on desks, kicking, or other intimidating behavior
• Recording or photographing communications or employees’ appearance and threatening to disclose such materials to media or on the Internet
• References to connections with antisocial forces
• Persistently demanding disclosure of employees’ personal information or unjustly posting such information online or on social media
• Repeated unsolicited visits or calls (including silent calls), repeated mailings, etc.
• Repeatedly and insistently demanding explanations or apologies of the same content
• Extended phone calls that detain employees, refusal to leave, or occupying premises
• Insults, discriminatory or sexual remarks, or other conduct that causes employees emotional distress
• Defamation, stalking, or other harassment involving unnecessary physical contact or approaches toward employees

3Response to Customer Harassment

The Company will take the following actions if conduct that qualifies as Customer Harassment occurs:

• The Company will immediately request that the abusive conduct cease. If the conduct continues, the Company may suspend the User’s access, response, or provision of services, among other measures.
• If defamation of the Company or its employees or disclosure of employees’ personal information occurs, the Company will take necessary legal measures, including requests for removal.
• In cases assessed as malicious or severe, the Company may cooperate with the police, legal counsel, and other relevant authorities to respond strictly.

4Initiatives to Prevent Customer Harassment

The Company undertakes the following initiatives to address Customer Harassment:

• Giving highest priority to the protection and physical and mental care of employees who have experienced harassment.
• Promoting education and training for employees on knowledge of Customer Harassment and appropriate response methods.
• Establishing a consultation desk for Customer Harassment, and developing a system to promptly report and respond to such cases.

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