As part of its evidence-based policymaking, the Japan Fair Trade Commission (JFTC) undertakes ex-post verification, focusing specifically on measures to prevent the recurrence of previously issued cease-and-desist orders. This process serves dual purposes: it verifies the effectiveness of the implemented measures, particularly those aimed at preventing unfair trade restrictions according to Article 3 of the Antimonopoly Act, and it generates insights for crafting more effective strategies to avert recurrence. These iterative checks help ensure a robust, competitive, and fair marketplace.
Approach
A web survey targeted 719 businesses previously issued cease-and-desist orders, receiving 410 valid responses (57% response rate). The survey ran from Oct. 27 to Dec. 8, 2022. Furthermore, Oliver Wyman Group K.K. and NERA Economic Consulting investigated overseas corrective measures, studying practices in the EU, U.S., UK, Germany, and Korea.
Verification Basis: The Logic Model
Basing analysis on logic frames the critical intermediate outcome—observable behavioral change in employees of businesses that previously violated regulations. This shift, often overshadowed by more immediately tangible results, is a clear indicator of successful interventions.
The logic model’s structured causal relationships illuminate this focus, tracing outcomes back to implemented measures. This method ensures not only the clarity and precision of the analysis but also its depth, encompassing the layers of human behavioral changes vital to prevention success.