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.
The Shimano Group believes that the World Federation of Sporting Goods Industry (WFSGI) Code of Conduct is an appropriate code of conduct for suppliers of the Shimano Group in fulfilling their responsibilities to society and the environment, and therefore, it has adopted the "WFSGI Code Of Conduct" shown in the Appendix 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

Appendix

WFSGI Code Of Conduct (APPROVED BY THE WFSGI GENERAL ASSEMBLY IN MUNICH, GERMANY, ON 23RD JANUARY 2016)

Member companies and their suppliers must operate in full compliance with national and local laws, rules and regulations relevant to their business operations including but not restricted to employment, environment and health and safety.

Local industry standards should prevail when higher than the local legal requirements. In countries where the legal requirements fall short of internationally recognised standards, it is recommended that members should apply the following minimum criteria:

Employers shall not use forced labour, whether in the form of prison labour, indentured labour, bonded labour or otherwise. No employee can be compelled to work through force, the threat of force, or intimidation of any form.

No person shall be subject to any discrimination in employment, included in hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin. Foreign or domestic migrant labour shall be treated on an equal basis with local employees.

The rights of workers to join (or not to join) organisations and associations of their own choosing without penalty and interference, and to bargain collectively shall be recognised and respected. Where the right to freedom of association and collective bargaining is restricted under law, the employer shall consider the development of parallel means for independent and free association and bargaining.

Employees shall be fully and legally compensated for all hours worked. In all cases, wages must equal or exceed the minimum wage or the industry wage, whichever is higher and all legally mandated benefits including insurances, holidays and leave shall be provided.
In addition to their compensation for regular hours of work, employees shall be compensated for overtime hours at the rate legally required in the country of operation or, in those countries where such laws do not exist, at a rate exceeding their regular hourly compensation rate.

Employees shall not be required, except in extraordinary business circumstances, to work in excess of 60 hours (including overtime) per week, or the local legal requirement, whichever is less. Overtime work must be voluntary.
Employees shall be allowed to at least twenty four (24) consecutive hours rest within every seven day period.

Employees shall be employed on the basis of a recognised employment relationship established through national law and practice. Obligations of employers shall not be avoided through the excessive use of temporary contracts, subcontracting or apprenticeship schemes.

No person shall be employed at an age younger than 15 (or 14 where the country of operation allows), or younger than the age for completing compulsory education in the country of manufacture where such age is higher than 15. All legal requirements for employees under 18 shall be followed and no person under the age of 18 shall be engaged in hazardous work or conditions, or any work at night.

A safe and hygienic working environment shall be provided, and occupational health and safety practices which prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employer facilities shall be promoted. This includes safe buildings, fire protection, electrical safety, safe use of hazardous substances and correct use of personal protective equipment. Lighting, heating and ventilation systems should be adequate. Employees should have access to adequate sanitary facilities and potable water at all times. The workplace shall have safety and health policies and procedures that are clearly communicated to the all employees. All standards shall apply to employee residential facilities, where provided by employers.

Every employee shall be treated with respect and dignity and has the right to a workplace free from physical, sexual, psychological or verbal harassment or abuse.

Members and their suppliers shall have full knowledge of subcontractors in their supply chain. All declared and approved subcontractors must comply with this Code. (*2)

Members and their suppliers recognise the economic and social impact of their work and commit to improving conditions in the wider communities in which they operate.

Members are encouraged to draw up their own specific code of ethical conduct, if they have not already done so, building on the above standards.

These Principles have been adopted by WFSGI to provide guidance for members and suppliers to ensure their business operates responsibly. Members shall take steps to ensure compliance with these standards in their own operations and in those of their suppliers. Where there are instances of non-compliance [e.g. significant and/or persistent breaches] whether found by internal or independent external monitors, members shall ensure timely and reasonable remediation of such non-compliance; and ensure that adequate steps are taken to prevent recurrence and/or occurrence in other organisations. WFSGI reserves the right to require members to report regularly on the steps they are taking to ensure compliance with this Code and responsible business practices more broadly.

(*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.