Voluntary Code of Conduct for Direct Selling Companies
Introduction
This “Voluntary Code of Conduct for Direct Selling Companies” (hereinafter referred to as
the "Code") has been established by the consensus of the members of the Japan Direct
Selling Association (hereinafter the “Association”) to embody the Code of Ethics of theAssociation, and to ensure the sound development of the direct selling business.
The Code, designed to promote appropriate business activities, can enhance public trustby being observed, and can also be used as a decision-making standard in resolving
individual cases in which consumers complain about. If the fact-finding process confirms apotential violation of the Code, it is believed that a prompt resolution by the business
operator can have the same effect as compliance with the Code. Provided, however, that it
is not a matter of immediate civil or criminal consequences for a single violation, but rather it
constitutes a factor in the overall decision-making process in resolving complaints.
A direct selling business operator shall comply with the “Act on Specified CommercialTransactions” (hereinafter “Specified Commercial Transactions Act”) and other laws andregulations in the course of its business activities. Violations of such laws and regulations
are subject to criminal, administrative and private sanctions to ensure compliance with therelevant laws and regulations. On the other hand, the Code is a voluntary provision, mainly
on matters not stipulated by laws and regulations, and is not as strictly structured as thecriminal rules of laws governing business requirements, since it does not directly aim atsanctions. However, depending on the nature and frequency of such violations, amisconduct may be subject to review by the Association's Ethics Review Committee, which
may result in a recommendation for remediation, suspension of rights, or other action that
may be considered as a sanction by the Association.
Members of the Association shall understand the importance of these points and agree tocomply with the Code.
1. Purpose
In view of the fact that “there is always a disparity in the quality and quantity of information
and bargaining power between business operators and consumers,” the Code has been
established as a code of conduct to develop soundly as a company that is accepted insociety through fair transaction of direct sales and efforts to prevent consumer disputes fromoccurring.
2. Scope of Application

The Code shall apply to the activities of members of the Association and persons
associated with members of the Association who are engaged in the business of selling
products or rights or providing services by the method of direct selling(hereinafter“Members, etc.”).
3． Content of the Code of Conduct(1) General(a)The matters set forth in relevant laws and regulations, the Code of Ethics, etc., shallbe complied with.
(b)A moderate attitude and manner in their interactions with consumers shall bemaintained.
(c)Products, services, rights, etc. (hereinafter the "Products, etc.") dealt by eachcompany shall be fully understood when selling, and their characteristics, necessity
and conditions related to the transaction shall be accurately communicated toconsumers.
Special attention shall be paid to the following points:① For information on the Products, etc. that claim efficacy or effectiveness, theevidence shall be verified internally or data shall be obtained from themanufacturer or a third party organization recognized by the supplier as fair.
② If testimonials from users of the Products, etc. are used in solicitation, etc., such
solicitation shall not mislead people into believing that everyone can achieve
such results.
③ In terms of materials, be sure to collect data that is not based on a survey of
only a portion of users, but is statistically objective enough to determine that it isrepresentative of the majority of users.
(d)At the beginning of a solicitation, it is essential to assess the consumer's judgment. If
there are concerns, be sure to either stop the solicitation and leave, or takeappropriate action while complying with the Voluntary Code of Conduct. (Certaincharacteristics can be observed in people with dementia. These include ①“smoothing over,” where they may respond as if they understand, even if they don't
fully understand, or they may use reasoning to avoid drawing people's attention totheir lack of understanding. Another characteristic is ②“an increased tendency toagree with others,” where they try to align their opinions with what others are saying.
This requires extra effort to pay attention.)(e)Any words or deeds shall not be used that defame other companies or their products
contrary to the facts.

(f)Sales activities shall be conducted in a manner that does not violate the separately
established Product-Specific Prohibitions (detailed regulations).
(g)Always pay attention to the quantity of goods sold or offered to avoid being pointed
out as having solicited the conclusion of a purchase agreement or a service provisionagreement for goods significantly in excess of the quantity normally required in daily
life without justifiable reason.
Special attention shall be paid to the following points:①Confirm that the quantity of the contracted items is appropriate in light of the“Guidelines for Quantities Not Normally Considered Excessive” (hereinafter the“Guidelines”) established by the Association. Provided, however, even if theamount is within the “guideline” range, it is still necessary to confirm that theamount is not inappropriate in light of the consumer's financial situation.
②Efforts shall also be made to confirm the consumer's history of transactions withthe company for the same goods and services. Efforts shall also be made tounderstand the consumer's situations by inquiring about their transaction history
with other companies as much as possible.
③In the case of soliciting the conclusion of a contract for a quantity of goods
exceeding the Guideline, the solicitation shall not be made against theconsumer's will. In addition, efforts shall be made to maintain data demonstratingthat there were legitimate reasons for the solicitation, as well as that there werespecial circumstances where the conclusion of the contract was necessary forthe relevant consumer.
④For products and services not included in the Guidelines, the provisions in thepart following “Provided, however,” in ① and those in ② shall be observed.
(h)From a consumer-oriented perspective, efforts shall be made to take into accountthe consumer's knowledge, experience and financial situation and to always respondin a manner appropriate to the consumer.
Special attention shall be paid to the following points:①The solicitation of contracts for unreasonable amounts of money that wouldinterfere with the consumer's livelihood shall be avoided. (For example, if theconsumer depends on the public pension as a main source of livelihood,expensive contracts such as home renovation shall not be solicited.)②While recognizing the lack of judgment of the said consumer, no sales shall bemade on credit that take advantage of such lack of judgment.
(i)While recognizing the lack of judgment of the said consumer, no solicitation shall bemade that takes advantage of such lack of judgment. (Examples of cases wherejudgment is lacking: the elderly, minors, individuals who have recently reached theage of majority, and those with dementia, mental illness, or intellectual disabilities,etc.)(j)When conducting solicitation activities with consumers who do not clearly
demonstrate a lack of judgment but are concerned about their lack of judgment,
consent shall be obtained from relatives or other individuals having sufficientjudgment.
(k)When concluding a contract that falls under any of the following items, efforts shallbe made to take appropriate measures such as establishing a system to check
whether the solicitation is being carried out properly. Furthermore, when establishing
the criteria for quantity, each Member, etc., shall determine them appropriately,
considering the relevant laws and regulations, the actual circumstances of their own
companies, and other factors.
・When concluding a contract for items that exceeds a specific quantity, amount ofmonetary, or frequency
・When concluding a contract with a consumer who is above a certain age
・When concluding a contract with a consumer who depends on public pension as asource of livelihood(l)Members, etc. shall make efforts to enhance their qualifications by providing thorougheducation and guidance to salespersons.
(m)Whether a contract falls under the case where a consumer makes a request (aso-called request-based visit), which is excluded from the scope of the Act on
Specific Commercial Transactions, is determined on a case-by-case basis. No one
may tell a consumer that, contrary to it, “the contract was concluded after a visit
based on a request and is excluded from the scope of the Act” without a legally
appropriate basis.
(2) Until the start of solicitation① Appointments by phone before the visit(a)Tell the consumer of the name of the company, the type of the Products, etc., and themain purpose of the visit.
(b)Confirm whether the person will be able to listen to you now by phone, etc.
(c)If you are told that they do not want to listen to you or that it is not a good time forthem now, end the conversation immediately. Even if it is not an expression of explicit
refusal, if the person tries to say something, stop talking and confirm their intention.
(d)Take great care to ensure that the consumer is not misled into thinking that the main

purpose of the visit is anything other than sales activity.
②The first thing to say when visiting(a) Tell the purpose of the visit with the name of the company and the type of theProducts, etc.
(b) Clearly confirm the consumer's intent and ask if they are comfortable with youcontinuing the solicitation. At this point, it shall be noted that not a few consumers are
not very good at making their intentions clear.
(c)If the consumer expresses a reluctance to continuance of your solicitation activities,
identify as clearly as possible whether it is a wish to refuse the solicitation itself or awish to cease this current solicitation activity, and in either case, stop the solicitationand leave at that point.
(d)Take great care to avoid being pointed out by the consumer as having told themsomething that is not true during a visit.
③Contact with a specific customer(a)The consumer shall not be invited to any sales office or other location unless they
have first been informed of the company name and purpose of the solicitation and it
has been confirmed whether or not they are willing to accept the solicitation.
(b)If there is a clear indication that the consumer does not want to accept the solicitation,
the solicitation activity shall be stopped immediately.
(c)The main purpose of solicitation shall not be intentionally hidden or other purposes
shall not be told when contacting a consumer.
(d)Street sales shall not be done.
(e)Do not accompany consumers to another location without the consumer's request.
(3) Explanation of products handled(a)Always make efforts to provide explanations while confirming the level ofunderstanding of the consumer.
(b)Do not tell the consumer that cooling-off is not applicable, even if the transaction iswithin the scope of cooling-off period.
(c)When the Products, etc. or services are offered as a set, provide the consumer withmaterials that show the concrete specifics of the entire package.
(d)Information on how to use the Products, etc. and replacement of parts, etc. shall be
accurately conveyed by providing specific materials.
(e)For service transactions where providing an estimate is desirable, a written estimate

or similar document shall be presented in advance and provide an explanation basedon that estimate.
(f)When soliciting the purchase of products and services together with the estimate,accurate information shall be provided about the contents and prices of each offering
separately.
(g)Do not make unreasonable promises or special arrangements not approved by thecompany.
(h)When a consumer is considered to be a socially vulnerable person, special attention
shall be paid to explanations so that the content of the Product, etc. can beunderstood, and efforts shall be made to ask for the presence of relatives or otherindividuals.
(i)Do not give no false or unfair explanations.
(4) Business practice for the conclusion of contracts(a)When concluding a contract with consumers who do not clearly demonstrate a lackof judgment but are concerned about their lack of judgment, ask for presence ofrelatives or other individuals having sufficient judgment.
(b)Efforts shall be made to double-check that the consumer understands the Products,etc. or services covered by the contract, the total amount of the contract price, thepayment method, the procedure for canceling the contract, and the contact
information for inquiries at the time of making their decision to conclude the contract.
(c)When selling on credit, inform the consumer that it is a "three-party contract", inwhich the buyer of the Products, etc., and the payee are separate. No sales on credit
shall be made to consumers who do not clearly demonstrate a lack of judgment but
are concerned about their lack of judgment, except in the presence of relatives orother individuals having sufficient judgment.
(d)The contracting party's name field in the contract and credit document shall be filledwith the sign by the contracting party.
(e)The guarantor's name field in the credit document shall be filled with the sign by theguarantor.
(f)Pay special attention to ensure that there are no omissions in the contract and credit
documents.
(g)The contract and credit documents shall be handed out in a manner directly visible
and encouraged to be read carefully.
(h)Consumers who have been denied credit for a credit contract shall be clearly
informed that the purchase agreement in question has been retroactively voided.

(5) Internal procedures(a)An administrative processing system shall be established to ensure that there are noomissions in administrative processes.
(6) Contract fulfillment and after-sales service(a)Be sure to fulfill the terms of the contract, such as delivery, provision of service, andafter-sales service.
(b)Respond to questions about the Products, etc. in a sincere manner.
(7) Support after the contract① Establishment of a contact point and a consumer-oriented response(a)Members, etc., shall designate a dedicated contact point and assign an individual
who understands the information described in Basics of Responding to Consumer
Consultations prepared by the Association, which includes the “Five Roles of theConsumer Assistance Contact Point.”(b)Carefully respond to inquiries from consumers about the Products, etc., contracts,
and other related matters, by putting yourself in the consumer's shoes.
(c)If a consumer's claims involves a skin issue, physical ailment, or a defective productthat could potentially cause expanding damage, immediate action shall be taken,
such as sending a person in charge to address the matter.
②Handling of cooling-off claims (when meeting the statutory cooling-off requirements)(a)Be careful not to be perceived as obstructing or refusing in your words and actions
regarding cooling off claims.
(b)When a cooling-off claim is made orally over the phone, etc., there are two options: a.
to ensure that the telephone conversation is recorded before starting the procedure
to avoid disputes at a later date. b. to require the consumer to send a written or
electronic record within a specified period of time. In the case of b, even if the date ofsubmitting the document or electromagnetic record received is outside the period,
when it can be objectively confirmed that the date of the claim made on the phone
was within the cooling-off period, it shall be processed as a cooling-off.
③Handling the claims of cancellation (after the cooling-off period has expired or in cases
where the statutory cooling-off period does not apply)(a)Listen to the consumer's request with sincerity and avoid dismissing them outright bystating that “cancellation is not possible under any circumstances.”(b)If it is clear that the claim content through listening to the consumer is not a case of
applicable for cancellation, explain in a sincere manner why it cannot be canceled.
(c)Basically, the content of the claim shall be fact-checked and the matter shall behandled appropriately based on the results of the investigation.
(d)If, during addressing the cancellation claim, it becomes evident that there was aviolation of the Code, the Product-Specific Prohibitions, or the Guideline, immediate
and appropriate action shall be taken.
(e)When it comes to determining whether a cancellation is possible and calculating theassociated fees, each case shall be handled on an individual basis. However, eachcompany shall establish its own guidelines and make efforts to guarantee
transparency by referring to the Basics of Responding to Consumer Consultations
prepared by the Association and industry group standards.
(f)In the case of a claim on a contract involving a so-called socially vulnerable person, agreater attention shall be paid and a judgment shall be made after fully grasping thesituation.
(8) Supplementary Provisions(a) The Code shall be effective from the resolution date of the Board of Directors (March28, 2002), as the date of enactment, and shall enter into force on June 6 of the sameyear.
(b) The Self-Regulatory Guidelines for Direct Selling Such as Learning Materials shallbe repealed as of the effective date of the Code.
(c) This revised Code shall be effective as of the resolution date of the Board of
Directors (October 5, 2004).
(d) This revised Code shall be effective as of the resolution date of the Board of
Directors (August 23, 2005).
(e)This revised Code shall be effective as of the resolution date of the Board of
Directors (October 5, 2006).
(f)This revised Code shall be effective as of the enactment date of the revised Act on
Specified Commercial Transactions (December 1, 2009).
Supplementary Provisions (April 1, 2012)
These amended rules are shall take effect as of the day of registration of the incorporation ofpublic interest corporation as set forth in the provisions of Article 106, Paragraph 1 of the Act
on Organization and Maintenance, etc. of Relevant Laws in connection with theEnforcement of the Act on Foundation of General Incorporated Associations and GeneralIncorporated and the Act on Authorization, etc. of Public Interest Incorporated Associations
and Public Interest Incorporated Foundations.
Supplementary Provisions(October 6, 2016)
These amended regulations shall take effect as of the resolution date of the Board ofDirectors.
Supplementary Provisions (March 16, 2022)
Of these revised provisions, 3(1)(i) shall come into effect as of the resolution date of theBoard of Directors (March 16, 2022), and 3(7)②(b) shall come into effect as of June 1, 2022.
Supplementary Provisions (May 21, 2024)
These amended regulations shall take effect as of the resolution date of the Board ofDirectors (May 21, 2024).