Enforcement record
Recommendation disclosure naming SANEI株式会社
This page records one action from a Japanese government disclosure, including the published name, governing law, authority, action details, and official source.
Action type
Recommendation
Law
Subcontract Act
Authority
Japan Fair Trade Commission
Action date
26 September 2024
Current page: Enforcement record
This screen focuses on one disclosed action: the published name, governing law, authority, facts, source status, and review evidence.
Source verification
Public-source and preservation status
- Publishing authority
- Japan Fair Trade Commission
- Official source URL
- Recorded by RegBase
- Entity match
- Not confirmed; shown under the published name
- Kiroku preservation
- Completed archive verified
- Captured: Jul 10, 2026, 04:49 PM JST
“Confirmed” means that RegBase matched this record to the cited public disclosure or entity under the stated checks. It does not verify the truth of the disclosure or guarantee the entity’s current status, creditworthiness, or any legal conclusion.
Open the official source links in the section below to review the original disclosure.
Action summary
- Company
- SANEI株式会社Japanese onlyOriginal: SANEI株式会社
- Governing law
- Subcontract Act下請代金支払遅延等防止法
- Action type
- Recommendation勧告
- Action date
- 26 September 2024
- Issuing authority
- Japan Fair Trade Commission公正取引委員会
- Industry context
- 水栓金具製造販売
Violation
SANEI Corporation, a water fixture manufacturer with capital under 300 million yen, was advised by the Fair Trade Commission for violations of the Subcontractor Payment Delay Prevention Law. The violations include: (1) from July 2022 to January 2024, deducting 'purchase discounts' totaling 4,709,138 yen from payments to 10 subcontractors; (2) on August 30, 2024, paying back the deducted amount; (3) lending molds (totaling 692 types) without charge to 50 subcontractors, despite not ordering products made with these molds for a long period after July 1, 2022, and conducting annual inventory checks that unjustly harmed subcontractors' interests; (4) discarding 182 molds out of the 692 types between July 31, 2023, and April 5, 2024, affecting 28 subcontractors. The actions involved lending molds without charge and conducting inventory checks, which are violations of the law.
Show original Japanese text
SANEIは、資本金の額が3億円以下の法人たる事業者に対し、自社が販売する又は製造を請け負う水栓金具等の製造を委託している。下請代金の額から「仕入割引」の額を差し引き、金型を無償で貸与し棚卸し作業を行わせるなどの行為。
Compliance context
MediumA regulator issued a recommendation or formal request for corrective action.
Japanese regulatory disclosure under Subcontract Act.
Review the facts and follow-up status. This is usually less severe than a suspension or revocation, but still a public enforcement signal.
This context is an operational aid for review workflows, not a credit opinion or legal conclusion.
Open original sources and verification detailsOfficial URL, direct PDF, and Kiroku archive
- Extracted at
- 2026-07-10T07:49:30.602+00:00
- Evidence checked
- 2026-07-10T07:49:31.369+00:00
- Archive captured
- 2026-07-10T07:49:48.493558+00:00
Show audit JSON
{
"record": {
"id": "a7f10aa8-2314-4287-aade-baddbcea73c7",
"url": "https://regbase.jp/en/enforcement/shitaukeho-sanei-20240926",
"company_name_original": "SANEI株式会社",
"company_name_registry": null,
"corporate_number": null,
"law": {
"ja": "下請代金支払遅延等防止法",
"en": "Subcontract Act"
},
"action_type": {
"ja": "勧告",
"en": "Recommendation"
},
"authority": {
"ja": "公正取引委員会",
"en": "Japan Fair Trade Commission"
}
},
"entity_match": {
"status": "unresolved",
"confidence": 80,
"method": "normalized_name_existing_company",
"method_label": "Normalized Japanese name matched to an existing RegBase company profile",
"notes": "Matched by normalized Japanese company name to one existing RegBase company profile. The selected profile has a Corporate Number, but that number was not present in this disclosure and therefore does not confirm the entity match."
},
"review": {
"status": "machine_reviewed",
"label": "Machine checked"
},
"compliance_context": {
"severity": "Medium",
"actionMeaning": "A regulator issued a recommendation or formal request for corrective action.",
"practicalNote": "Review the facts and follow-up status. This is usually less severe than a suspension or revocation, but still a public enforcement signal.",
"lawContext": "Japanese regulatory disclosure under Subcontract Act."
},
"evidence": {
"recordUrl": "https://regbase.jp/en/enforcement/shitaukeho-sanei-20240926",
"officialSourceUrl": "https://www.jftc.go.jp/houdou/pressrelease/2024/sep/0926_kinki_shitauke.html",
"officialDocumentUrl": null,
"archiveUrl": "https://kiroku.today/a/9d490b4f84emxfm9",
"archivedSourceUrl": "https://www.jftc.go.jp/houdou/pressrelease/2024/sep/0926_kinki_shitauke.html",
"archiveCapturedAt": "2026-07-10T07:49:48.493558+00:00",
"extractedAt": "2026-07-10T07:49:30.602+00:00",
"translatedAt": "2026-07-10T07:50:42.51+00:00",
"evidenceCheckedAt": "2026-07-10T07:49:31.369+00:00",
"generatedAt": "2026-09-16T10:38:31.543Z"
},
"limitations": [
"RegBase aggregates public Japanese government disclosures and does not provide a credit opinion.",
"English summaries are provided for reference. The original Japanese source is authoritative.",
"Possible or unresolved entity matches should be manually verified before use in a decision."
]
}The original Japanese disclosure is the authoritative record. Use possible or unresolved matches only as leads for manual review.
Language
日本語版を見る (Japanese)About this recordAggregated and translated from public Japanese government disclosures. The English text is for reference only — authoritative content is the linked Japanese source.