For a long time, there was no specific law dealing with workplace bullying and harassment in Japan. The need for a change in Japanese labour law was becoming critical in view of the rise in indicators relating to work-related mental diseases including suicide. This is why, on 29 May 2019, the country adopted a law that addresses the concept of “Power Harassment” (pawa hara). However, the legislative process leading to this result was complex in order to get a legal standard enacted for the labour administration defining power harassment that incorporates a representation of the notion of “superiority” in labour relations.French law on bullying and harassment at work is, on the contrary, much older, dating back to the law of 17 January 2002, and is the source of a very abundant jurisprudence on the subject. The latest advances to date are the consequences of the France Télécom ruling, handed down on 19 December 2019, which recognised the notion of “institutional psychological harassment” understood as a “general company policy destabilising and stressing a community”. The company’s former managers were sentenced to prison and the company as a legal entity was sentence to pay a fine. The “France Télécom” case shows that certain management methods, aimed in this particular case at reducing the workforce with no dismissal, give rise to acts of bullying and harassment. In some cases, this situation is able to push the targeted persons to commit suicide. This case echoes certain management methods in Japanese companies and long working hours as shown, for example, by the jurisprudence related to the “Dentsu case” (2000).The aim of this article is to examine two pathways to construct a legal regime on bullying and harassment at work. The debates on the ratification of International Labour Organization Convention 190 may be useful to highlight approaches countries might take to improve the scope of legislation on bullying and harassment at work. Developed countries, such as France and Japan, might also reflect on whether their current measures in force to prevent and address violence and harassment, which result from a long gestation period, are now sufficient to give full effect to the requirements of this instrument. Debates about ratification provide an opportunity for these countries to review their approach and to fill some gaps in the protection of those exposed to the risks of bullying and harassment.< Réduire