Report and Apology Regarding the Consumer Affairs Agency's Corrective Order

ROHTO Pharmaceutical Co., Ltd. (hereinafter referred to as ROHTO V5 our company") received an administrative order from the Consumer Affairs Agency on March 25, 2025, pursuant to Article 7, Paragraph 1 of the Act against Unjustifiable Premiums and Misleading Representations (hereinafter referred to as the Premiums and Representations Act), regarding some of the advertising representations for "Rohto V5 ActVision," which our company sells.

We sincerely apologize for the great inconvenience caused to our customers and all other parties involved by this situation. We take this corrective action order very seriously and will strive to prevent a recurrence.

Please note that this administrative order concerns our advertising practices and does not relate to the quality or safety of the products or services we provide. Furthermore, we have promptly removed and corrected the web advertisements that were pointed out by the Consumer Affairs Agency.

We would like to report the details of the corrective action order as follows:

Facts that were subject to the corrective action order

In our web advertisements for "ROHTO V5 ActVision" (hereinafter referred to as "the Product"), we requested third parties to post about the Product on Instagram, on the condition that we would provide them with the Product free of charge, and included the content of those posts in the advertisements.
However, in one advertisement, from September 30, 2023 to July 29, 2024, the text of the Instagram post was hidden when the Instagram image included in the advertisement was clicked. As a result, viewers of the advertisement were unable to see the explicit expressions indicating the relationship, such as "#PR" and "#RohtoPharmaceutical," which violated the Premiums and Representations Act.

background

The circumstances surrounding this violation of the Premiums and Representations Act are as follows:
Following the launch of the advertisement, and in accordance with the amendment to the Premiums and Representations Act that will come into effect in October 2023, we have decided to review the content of the Instagram posts in which the advertisement was placed and change the posting method (post format where the post text is displayed when the image is clicked: Document 1).
First, we reviewed the Instagram posts and asked the posters of any posts that needed correction to add hashtags such as "#PR" or "#CompanyName,BrandName" (hereinafter referred to as "this notation").

▲Document 1

Subsequently, when processing Instagram posts that had already been marked with "this notice" for advertising, we mistakenly set one web ad to hide the post text when the image was clicked, resulting in an inability for ad viewers to see "this notice" in the post text (Document 2). This was overlooked within our company, and the ad in question was published on September 30 of the same year.

▲Document 2

Due to the circumstances described above, although the relevant Instagram post text includes a "PR" or similar designation, the advertisement was published in a way that prevented viewers from seeing the "PR" designation in the original posts and confirming the explicit representation of the relationship. The Consumer Affairs Agency determined that this violated the Premiums and Representations Act.

Furthermore, for the other nine advertisements that featured similar Instagram posts, clicking on the image displayed the post text, allowing users to view the "this notice" (see Document 3).

▲Document 3

Contents of the corrective action order

1. The above facts shall be thoroughly communicated to the general public through a method approved by the Commissioner of the Consumer Affairs Agency.
2. Take all necessary measures to prevent similar displays from occurring in the future, and ensure that all officers and employees are fully informed of these measures.
3. Going forward, the company must not use similar representations to mislead general consumers regarding the content of the service or the relationship between the company and the poster.
4. 1. Report the measures taken based on 2. to the Commissioner of the Consumer Affairs Agency.

Measures to prevent recurrence

We take this administrative order very seriously and sincerely. We will review our management system regarding the Premiums and Representations Act, further strengthen our management system by thoroughly educating our employees and conducting internal reviews before publication, and we will strive to regain trust by complying with appropriate advertising practices and by establishing a compliance system.