What is Customer Harassment?

In accordance with the Corporate Manual on Measures against Customer Harassment published by the Ministry of Health, Labour and Welfare of Japan, we define customer harassment as “any complaint from or behavior by a customer or a potential customer that uses socially unacceptable means or manners to achieve demands in light of the appropriateness of the demands, and that has detrimental effect on the work environment of workers.” A customer or a potential customer is hereinafter referred to as the “Customer, etc.”.

Criteria for determining whether behavior constitutes customer harassment

Pursuant to the above definition, HENNGE uses the following two factors to determine whether conduct constitutes customer harassment:

(1) Whether the demand by the Customer, etc. is inappropriate

(2) Whether the means and manners to achieve the demand is socially unacceptable

With regard to (1), we first check the facts and causal relationship of the demands by the Customer, etc., to confirm that there is no negligence on our part and that the demands are well-founded, and determine whether the demands by the Customer, etc., are appropriate.

With regard to (2), in addition to confirming the appropriateness of the demands by the Customer, etc., we determine whether the means and manners adopted to achieve the demands exceed a reasonable scope in light of socially accepted ideas.

Conduct that constitutes customer harassment

(1) and (2) specifically apply to the following conduct.

(1) Examples of when the demand by the Customer, etc. is inappropriate

• When no defect or negligence is found in the products or services provided by HENNGE
• When the demand is unrelated to the products or services provided by HENNGE



(2) Examples of when the means and manners to achieve a demand is socially unacceptable The following conduct is highly likely to be considered inappropriate in terms of the means and manners, even if the demand is appropriate.

• Physical attacks (assault, injury)
• sychological attacks (intimidation, slander, defamation, insults, abusive language, demands to get down on one’s knees)
• Continuous (repetitive), insistent (persistent) behavior
• Restrictive behavior (refusal to leave, sit-in, confinement)
• Sexual language and behavior
• Discriminatory language and behavior
• Privacy infringements



The following conduct is considered inappropriate in light of the appropriateness of the demands.

• Demands to exchange products
• Excessive demands (demands for after-hours service)
• Demands for monetary compensation, etc.

External Response for Customer Harassment Prevention

To prevent customer harassment, we record conversations between customers and representatives that take place at our support desk.

We will refuse to provide support if we deem that demands constitute customer harassment. We may also suspend provision of products and services in accordance with our Terms of Service.

Establishment of an internal system to prevent customer harassment

HENNGE shall establish the following internal system to prevent customer harassment.

• Clarification of the response system and procedures in the event of customer harassment
• Establishment of an internal consultation service (including cases that lead to consultation with a corporate lawyer, depending on the situation)
• Provision of mental health care for victims and organized multi-person responses to demands by Customers, etc.
• Stipulation of the protection of privacy and prohibition of disadvantageous treatment with regard to consultations by victims in internal rules
• Reporting to the Compliance Committee and consideration of measures to prevent recurrence
• Employee training and awareness raising activities to prevent customer harassment

Employee Responsible

The person responsible for promoting this policy shall be the Chairperson of the Compliance Committee.