Vendor Code of Conduct

In its Code of Conduct, the Shimano Group (*1) sets forth the policy for comply with the local applicable laws and regulations and to make effort to act with integrity and fairness. Also, where there are discrepancies between internationally recognized human rights and the laws of a particular country, the Shimano Group seeks ways to respect international human rights norms.

The Shimano Group expects its suppliers to comply with laws and regulations, act with integrity and fairness, and respect international human rights norms.
As the Code of Conduct of the World Federation of the Sporting Goods Industry (WFSGI), of which the Shimano Group is a member, is based on internationally recognized standards relating to human rights, the environment, and other relevant areas, and clearly sets forth the level of conduct expected of companies engaged in the sporting goods industry, the Shimano Group considers it to be an appropriate standard for its suppliers to fulfill their social and environmental responsibilities. Accordingly, the WFSGI Code of Conduct set forth in the Appendix shall be applied as the code of conduct for suppliers of the Shimano Group (hereinafter referred to as the "Vendor Code of Conduct").
The Shimano Group requires all of its suppliers and their supply chains to understand, agree to and practice the Vendor Code of Conduct.

When the Vendor Code of Conduct is applied to suppliers of the Shimano Group, "member company" in the WFSGI Code Of Conduct shall mean the Shimano Group and "supplier" shall mean suppliers of the Shimano Group.
Between the standards required by applicable laws and regulations of a country or region in the world and the standards required by the Vendor Code of Conduct, whichever is stricter shall be followed.

<Language>
The English version of the WFSGI Code Of Conduct and the Vendor Code of Conduct shall be regarded as the original. Provisional translation of the Japanese version, etc. will be prepared as necessary. If there is any conflict between the English version and the multilingual version, the English version shall prevail.

<Establishment and Revision or Abolition>
Establishment, revision, or abolition of the Vendor Code of Conduct shall be based on the appropriate procedures of Shimano Inc. When the WFSGI Code Of Conduct is revised by the WFSGI, the revised WFSGI Code Of Conduct shall be applied as the Vendor Code Of Conduct after evaluating the contents of the revision each time and following the procedures of the Company.

(*1) Shimano Inc. and companies in which Shimano Inc. directly or indirectly owns a majority of the issued shares or equity interests with voting rights.
Establishment and Revision History
Established on August 1, 2021
Revised on September 1, 2026

Member companies and their suppliers are expected to operate in full compliance with relevant local, national and international laws, standards, rules and regulations applicable to their business operations including but not limited to employment, the fundamental principles and rights at work, environmental protection, health and safety, ethical business conduct, consumer protection and product safety. Where differences or conflicts arise between this Code and applicable national or international laws or standards, members and their suppliers are expected to apply the higher standard consistent with the UNGPs and OECD Guidelines.

Members and their suppliers shall maintain appropriate visibility, to the extent feasible, over subcontractors involved in the production process and require subcontractors to meet the same standards of compliance as set out in this Code. (*2)

Employers shall establish and maintain appropriate management systems to ensure adherence to the principles covered in this Code. These systems shall include but are not limited to:

Maintaining systems that ensure accountability and continuous improvement including mechanisms for internal reporting and corrective action.

Members and suppliers should consider the impact of their purchasing and production planning practices on working conditions, including wages, working hours, and employment stability. These systems should support ongoing human rights and environmental due diligence.

No person shall be employed directly or through business partners at an age younger than 15 unless under the exceptions recognised by the ILO, or below the age for completing compulsory education. Any legally permitted exceptions under international standards must not interfere with compulsory education or expose the child to risk. Employers shall establish and maintain robust, non-intrusive age verification mechanisms as part of the recruitment process, which may not degrade or disrespect the worker in any way.

Where underage employment is discovered, remediation measures must prioritise the best interest of the child and align with recognised good practice (e.g. education continuity and appropriate income support for families), with special care to protect workers under 18 during any transition.

All legal protections for employees under 18 shall be upheld and no person under the age of 18 shall be engaged in hazardous work or conditions, or night work, or any tasks likely to jeopardize their health, safety, or morals, as defined by the ILO. Employers and their business partners shall ensure that employment does not cause insecurity or social or economic vulnerability for the under 18 employee. Young workers shall be provided with a documented and recognised employment agreement in a language they understand using whichever national or international standard affords the greatest protection.

Special care and consideration must be given to the working hours of young workers, in accordance with laws and international guidelines. Special care will also be taken to identify measures in a proactive manner in cases of dismissal and removal of under 18s to ensure the protection of these young employees.

Employers and their suppliers shall not engage in any form of forced, bonded, indentured, or prison labour, nor in any other form of coercion or human trafficking.

Employees must be engaged voluntarily and have the right to terminate their employment freely, with reasonable notice, in accordance with applicable laws and regulations.

Employers and their suppliers shall implement the principles of responsible recruitment, ensuring that:

All employees shall be treated with dignity, fairness and respect. There shall be no discrimination in any employment practice including: recruitment, compensation, access to training, promotion, discipline, termination, or retirement, on the basis of but not limited to: race, colour, ethnicity, social group, nationality, caste, gender, gender identity or expression, age, religion or belief, disability, sexual orientation, political affiliation or opinion, marital or parental status, caregiver responsibilities, pregnancy, health conditions (including HIV status), neurodiversity, or any other status protected by applicable law.

Foreign or domestic migrant workers shall receive equal treatment and protections in line with local workers in similar roles and conditions.

Employers shall prohibit any form of corporal punishment, physical or mental coercion, verbal abuse, violence, humiliation, or other inhumane or degrading treatment either by management or other workers.

All disciplinary measures must be fair, lawful, and non-discriminatory, clearly defined and communicated to workers in a language they understand, be consistently applied and appropriately documented. Employees must have the right to respond or appeal through an accessible, transparent, and confidential grievance mechanism and be carried out without any threat of retaliation for filing a complaint.

Employers must maintain systems that ensure accountability, due process, and continuous improvement in protecting the rights and dignity of all workers.

Employers shall respect the rights of all workers to freely join or not, organisations and associations of their choice and to bargain collectively without penalty, retaliation or interference. Their right to bargain collectively shall be recognised and respected. Where these rights are restricted by law, employers must not obstruct or interfere in employees’ efforts to establish independent and representative forms of worker organisation and dialogue consistent with international standards.

Employers shall encourage meaningful and inclusive representation of all workers and engage with chosen representatives regardless of their gender, role or employment status. Where workers are represented by trade unions or other legitimate worker representatives, employers shall allow reasonable access to the workplace for the purpose of carrying out representative functions, in line with applicable laws and agreements.

Employees shall receive compensation regularly and in a timely manner, and in legal tender. All partial or “in-kind” payments or allowances will only be concluded if in line with ILO specifications. Equal remuneration for men and women employees for work of equal value shall be upheld. No deductions will be permitted unless legally required or contractually agreed upon as part of a collective bargaining agreement. All employees will be granted their statutory and mandated legal social benefits that their position and seniority is owed without negative impact on the salary. Overtime hours shall be compensated at a premium rate in line with national laws.

Members should aspire to progressive improvements in wages in line with international best practices. Employers shall pay at least the minimum or prevailing industry wage, whichever is higher, and comply with all legal requirements on wages and benefits. Where wages do not yet meet workers’ basic needs, employers should work toward the progressive realisation of a living wage in line with recognised benchmarks.

Employees shall not be required to work in excess of 48 regular hours per week, or the local legal requirement, whichever is more stringent. Overtime work must be voluntary and paid at a premium and not be required on a regular basis. The sum of regular and overtime hours in a week must not exceed 60 hours unless in exceptional or extraordinary circumstances. Employees shall receive adequate resting breaks during the working day and be entitled to at least 24 consecutive hours of rest within every 7 day period. National legal requirements, industry standards or collective agreements within international frameworks set out by the ILO will be complied with to promote a healthy work-life balance for employees.

Employees shall be employed under a recognised and documented employment relationship or legally recognised engagement agreement established in accordance with national labour and social security laws, international labour standards or industry best practices.

Employers shall ensure that recruitment and employment relationships must not cause insecurity, economic vulnerability, or social vulnerability. Employees must receive a written offer or written agreement in a language they understand, before commencing. This document must include:

Employers must not use temporary contracts, subcontracting, or apprenticeship schemes to avoid legal obligations or undermine worker rights. All employment arrangements must reflect genuine work purposes and not be used to evade legal obligations. Employees, particularly those from vulnerable groups (e.g. migrant workers, women, young workers), must be provided with training on their rights and responsibilities and recruiters, brokers and intermediaries should support and reinforce this training.

Employers shall provide a safe and healthy working environment that complies with all applicable national Occupational Health and Safety (OHS) laws by identifying, assessing and mitigating physical, chemical, and biological hazards and risks. In cases where international OHS standards go beyond local laws, employers are expected to follow the higher recognised international standard. OHS practices must be designed to prevent accidents, injuries, and illnesses arising from, linked to, or occurring during the course of work or resulting from employer operations and facilities. All legally required permits, licenses, insurances, and safety documentation must be in place and regularly updated.

Employers are responsible for the following:

All employees have the right to refuse unsafe work. Employees have the right to exit the premises and/or stop working without permission in dangerous situations or uncontrolled hazards, provided they have fulfilled their obligation to inform the employer or supervisor of the hazards and imminent danger where possible. All standards shall apply to employee residential facilities, where provided by the employer.

Members and their suppliers must comply with all applicable environmental laws and regulations. Beyond compliance, members and suppliers are encouraged to take measurable steps to reduce their environmental impact and implement responsible business practices. This includes:

Members and suppliers are also encouraged to set and pursue clear, measurable management approaches or ambitions, which may include:

Members and suppliers are encouraged to demonstrate leadership through active participation in initiatives that drive broader environmental progress across the industry.

These Principles are intended to provide guidance for members and suppliers to ensure their business operates responsibly. Members are expected to take reasonable steps, consistent with applicable law, to align their own operations and supply chains with these principles. WFSGI does not audit, certify, independently verify, or enforce members’ compliance with this Code and assumes no duty to monitor or investigate member conduct. Any information shared by members regarding implementation of the Code is provided on a self-reported basis, and WFSGI may rely on such information without verification. WFSGI may seek clarification from members, signposting the relevant statutory guidance or regulators. WFSGI may, from time to time, invite members to share high-level information about their implementation efforts for learning, benchmarking, or dialogue purposes. Such engagement does not constitute oversight, approval, or endorsement of member practices by WFSGI.

(*2) Note by Shimano Inc.
The Shimano Group requires its suppliers to understand, agree to, and implement the following:
The suppliers shall assess the compliance of their supply chains with each principle, and correct any problems on a continuous basis.