Code of Conduct

To accomplish our mission statement, “To promote health and happiness through the enjoyment of nature and the world around us,” Shimano will contribute to sustainable economic growth and the resolution of social issues based on universal ethical values and law-abiding spirit common to the world as a corporate citizen in the global society and will continue to be a “Value Creating Company” which provides "Captivating Products" loved by people around the world.

This Code of Conduct (hereinafter referred to as “the Code”) is a stipulation of policies that every individual within Team Shimano, including Shimano Inc. and all of its subsidiaries around the world, will comply with in our daily business activities, for the purpose of the development of a sustainable society through sound business practices, and to strengthen the confidence in Team Shimano from all stakeholders, including our customers, shareholders, and business partners.

Team Shimano strives to always comply with the Code, as well as applicable laws and regulations, and conduct its business with sincerity.

1 Laws and Regulations and Ethical Standard

1–1 We comply with the laws and regulations of each country while respecting their culture and customs.

-We comply with applicable laws and regulations of each country and region, while respecting human rights of all persons and other various international standards.
-We respect the culture and customs of each country and region, but endeavor not to act outside of the sincere and fair conducts stipulated in the Code regardless of whether or not they are deemed acceptable in a specific country and/or region.

1–2 We will utilize our established reporting system appropriately and will not engage in retaliation or harassment of those who report such violations.

-We will report any violations or suspected violations of the Code or applicable laws and regulations to our supervisor, the designated section or personnel.
-We will not make false reports, and we will not make reports that are intended to defame a person.
-We will not retaliate against or harass any employee for reporting such violations or suspected violations.

1–3 We do not have any relationship with anti-social forces.

-We do not have any relationship with anti-social forces (including, but not limited to, any groups, individuals, and organizations involved in crime).
-We take a firm stance against anti-social forces and will not participate in any activities that are illegal or anti-social

2 Business Activities

2–1 We strive to provide reliable, safe, and trustworthy services and products.

-We prioritize the provision of high-satisfaction, safe, and reliable services and products for our customers.
-We aim to sincerely and appropriately respond to requests for consultations we receive from our customers regarding the services and products that we provide.

2–2 We conduct business that is fair, transparent, and in the spirit of free competition.

-In order to create a market that is fair, transparent, and allows for free competition for all, we do not engage in any unjust activities that limit business or eliminate the freedom of competition.
-We acknowledge that our business activities are founded upon cooperation and support from our business partners and approach our business with good judgment and sincerity while conducting our business fairly and justly.
-We do not engage in advertising or publicity activities that cause misunderstandings or misrecognitions.

2–3 We thoroughly comply with trade controls and other international trade rules.

-We do not sell, loan, or perform any other transfers of products, technologies, or information to organizations or countries which are barred by relevant trade laws and regulations.
-We follow appropriate import and export procedures that comply with relevant laws and regulations and do not export or import contrabands.

2–4 We maintain a sound and normal relationship with related parties, including politicians, government officials, and business partners.

-We do not engage in any exchange of inappropriate gifts or business entertainment, especially not for the purpose of gaining or retaining business, or those that may give the impression or incite the expectation of advantageous relationships in business dealings with third parties with whom we do business or who are hoping to do business with us.
-We do not offer, ask for, or promise money or other financially profitable items to governmental officials for the purpose of securing unfair profits or advantages. In the event that business-related negotiations with governmental officials or political donations/donations to other organizations are necessary, we act in accordance with relevant laws and regulations for appropriate handling.

2–5 We respect our intellectual property as well as those of others and prohibit unfair competitive actions.

-We utilize our intellectual property appropriately and work towards maintaining such intellectual property while respecting the intellectual property of others.
-We do not acquire any third party trade secrets through unfair or illegal means. Additionally, we do not use third party trade secrets that have been or are suspected to have been obtained through unfair or illegal means, nor do we use trade secrets for purposes other than the purposes agreed upon by the third party.

2–6 We appropriately manage and use company assets.

-We protect our company’s tangible assets, as well as intangible assets including trade secrets and personal information, from theft, destruction, embezzlement and leaks.
-We establish management systems to prevent the leakage of information assets such as trade secrets, and establish systems to address information security incidents such as cyber attacks, and implement appropriate information security measures.
-We safely and appropriately use information systems such as email, Social Networking Services, and the internet, and do not receive or send inappropriate or discriminatory messages that result in the discomfort of others.

2–7 We conduct accurate financial reporting, as well as timely information disclosure, while prohibiting insider transactions.

-We maintain accurate and complete accounting records pertaining to our business and its results, and conduct accurate, complete, and logical financial reporting, as well as timely information disclosures.
-We prohibit the purchase and sales of securities (insider transactions) based on material undisclosed information (insider information) obtained in the course of carrying out our business duties or from insider information disclosed to us by third parties and prohibit the disclosure of such insider information to third parties.

2–8 We will not take any such action as would harm Shimano for personal gain.

-We will not conduct any transaction that would advantage a competitor, or conduct any transaction on terms that would disadvantage our Company, for personal gain.
-We will use Company funds and assets, whether tangible or intangible, only for Company purposes and will not use them for personal gain or to the advantage of another company.

2–9 We strive to protect personal information and create innovation through use of information.

-We establish systems for the protection and management of information and implement appropriate information security measures to protect the rights and interests of individuals including their privacy, while giving due consideration to the usefulness of personal information.
-We ensure transparency and respect the will of the data subject when using personal information.

3 Environmental Protection and Social Contribution

3–1 We undertake environmental protection activities.

-We aim to reduce the burden on the environment and prevent pollution by striving to create products that are friendly to the environment, not only by examining the processes of research, development, manufacturing, distribution, sales, and disposal of our products, but also by employing highly energy-efficient technologies.
-We comply with applicable laws and regulations pertaining to environmental protection and give sufficient consideration to environmental protection.

3–2 We contribute to the local community as a corporate citizen.

-We communicate closely with local communities and strive to prosper together as a corporate citizen.
-We recognize our responsibilities and roles as a corporate citizen and strive to actively participate in activities that widely contribute to the society.

4 Work Environment

4–1 We appreciate diversity and prohibit discrimination and harassment.

-We respect human rights and do not discriminate based on race, gender, belief, social hierarchy, citizenship status, sexual orientation, exercising of workers’ rights, pregnancy, religion, political affiliations, marital history, or physical disabilities.
-We strictly prohibit all forms of harassment, including sexual harassment.

4–2 We maintain sound work force, promote cooperation, and provide a safe working environment.

-We comply with applicable labor-related laws and regulations, do not accept forced labor or child labor, and will work towards the realization of harmony between work and personal lives and strive to create a fair and lively workplace where employees can share a sense of accomplishment and joy.
-Based on the spirit of "prioritizing safety and health above all else," we create a comfortable work environment that secures employees’ health and safety, and strive towards the prevention of workplace accidents.

5 Crisis Management

5–1 We conduct thorough and organized crisis management against actions by anti-social forces, terrorism, cyber attacks, trade secrets leakage, natural disasters and other crises that pose a threat to civil society and corporate activity.

6 Establishment of Systems for the Code and Cultivation of Awareness the Code'.

6–1 In order to realize the spirit of the Code, we build effective governance systems and strive to implement the systems throughout Team Shimano.

6–2 We will ask our suppliers to understand and agree to this Code and encourage them to act in accordance with the Code.

6–3 In the event of occurrence of a situation not conforming to the spirit of the Code, whereby we may lose the trust from society, the top management will proactively take responsibility by striving to address the situation including resolving the problem, investigating the causes, and preventing the problem from recurring.

Created in December, 2016
Revised in January, 2022