Shibuya Group Compliance Code of Conduct

Shibuya Group Compliance Code of Conduct

The management philosophy of the Shibuya group is based on the “joy of working,” a philosophy which encourages a positive attitude in our employees allowing them to rise to the challenge of new business opportunities. This reflects our daily motto created by our founder.

We contribute to society through acting on our business challenges by the principle of putting the “Customer first.” “Compliance” refers to the Shibuya group companies and to our employees having an open and fair attitude with regard to all stakeholders including shareholders, customers, suppliers, and society, complying with legal requirements and internal codes, and conforming to business ethics and social norms. The Shibuya Group Compliance Code of Business Conduct offers specific examples of actions and behavior that will help to bring these concepts to reality.




1-1 Customer Satisfaction

We, the Shibuya Group Companies, strive and make our best efforts to achieve customer satisfaction by providing our customers with high quality products and services that we develop and manufacture.

1-2 Safety of Products and Services

We design and manufacture our products to meet or exceed regulations or guidelines concerning product and workplace safety. We will take all reasonable measures to ensure that our products or services do not damage or injure anyone’s life, body or property. In the event that any damage or injury is caused despite our efforts, we are committed to providing prompt and appropriate remedies and taking appropriate steps so that the same event will not happen again.

1-3 Proper Advertisement and Publicity

We disclose to our customers accurate information on our products and services.

1-4 Product Liability

We recognize and observe applicable regulations for product liability and supply our products to our customers while carrying out our responsibility for accountability.

1-5 Protection of Customers’ Business Information

We comply with applicable laws and regulations including our internal regulations and agreements and take all reasonable measures to protect customer’s information.

1-6 After-Sales Services and Response to Customer Inquiries

We commit to our customers and maintain after-sales support. We respond to customer’s requests and inquiries in a diligent and prompt manner for customer satisfaction.

1-7 Business Entertainment

In order to maintain appropriate relationships with our customers, we will not permit or offer excessive gifts or business entertainment, whether tangible or intangible, beyond the prevailing social standards and common sense. We will not permit any inappropriate payment to customer’s personnel.




2-1 Accurate Accounting and Financial Reporting

In order to ensure our accurate and timely financial reporting, we will properly, honestly and timely process all financial transactions of our respective companies, including without limitation, recognition of sales and incurrence of costs, in accordance with the applicable accounting and tax laws, regulations and internal rules. In no case will we engage in any inappropriate accounting practice(s).

2-2 Timely Disclosure

In order to maintain transparency of our management, we treat all shareholders and investors in an impartial manner, and will disclose to them accurate information on our business in a timely fashion. We also promptly publish any information that may have a material impact regarding our business operations.

2-3 Speculative Trading

We will not engage in any speculative trading which may impair our business activities.

2-4 Profit Distribution

We will seek and strive to properly distribute profits as well as to reserve internally for investment for our long-term sustainable growth.

2-5 Improper Benefit to Shareholders

We will not extend financial benefits to anyone to unduly influence shareholder behavior.

2-6 Insider Trading

We shall not engage in any insider trading or other transactions that may give rise to any suspicion of insider trading, whether concerning the Shibuya Group, its customers, business partners or otherwise.




3-1 Respect for Creativity and Independence

We will provide our employees with good working conditions, appropriate education and training. We will respect their creativities and independence and strive to promote “Kaizen (Improvement), Kaikaku (Innovation), and Kaihatsu (Development).” We will encourage and promote inventions and creations produced in the course of our business activities.

3-2 Employer-Employee Relationships

We will respect our employee’s rights and comply with all applicable laws and regulations including agreements with the labor union(s), if any, of our employees. We will promote an environment where employees and employer can cooperate with each other to achieve corporate objectives through mutual conversation and discussions.

3-3 Safety and Health

We will strive to improve our working environment by taking necessary measures in a continuous and planned manner in order to maintain and improve the physical and mental health of employees. We will comply with laws of labor relations and take required measures to establish comfortable and safe working conditions.

3-4 Fair Evaluation and Compensation

We will evaluate and compensate our employees based on fair rules and criterion such as the ability to perform tasks, job responsibilities and achievements. We will not use any form of child or forced labor.

3-5 Promotion and Development of Job Skills

We will promote skill development of our employees and maximize their performance regardless of their age, gender, sexual orientation, religion, nationality, race, and other unrelated factors.

3-6 Harassment

We prohibit discrimination by language or behavior that may be construed as harassment, including sexual harassment and power harassment.




4-1 Respect for Human Rights and Prohibition against Discrimination

We will respect fundamental human rights throughout our business activities. We will object to any discrimination based on age, race, gender, sexual orientation, religion, language or ethnic background, and will not discriminate based on ideology, creed or political opinion.

4-2 Harmonization with Society

We acknowledge our responsibilities as a member of social community and endeavor to be a good corporate citizen. We will strive to foster socially acceptable values, conduct, and cooperate with the local community to harmonize with society.

4-3 Protecting the Global Environment

We recognize the importance of the global environment and its sustainability. We will comply with applicable environmental laws and regulations, and utilize environmental management systems to implement full responsibility for our environment.

4-4 Dealing with Antisocial Forces

We will reject any relationship with antisocial organizations or individuals. We will take resolute attitudes toward unjustifiable demands when disguised as business or customer claims.

4-5 Social Contribution

We will contribute and promote social development and welfare through our business activities. We will support the activities of “Shibuya Foundation for Promotion of Local Culture.”




5-1 Equal Partnership

Suppliers and other players in the supply chain are important business partners for us. We seek establishment of long-lasting stable relationship on the basis of mutual trust.

5-2 Supplier Selection

We employ free competition in the selection of our business partners on the basis of fair and reasonable criteria.

5-3 Fair Trade

We will not engage in unfair trade or dealings with our suppliers.

5-4 Elimination of Improper Relationships

We prohibit our employees to abuse their position and accept entertainment, money and goods, any other tangible or intangible benefits, personal compensation or commission in relation to the business from our suppliers beyond the prevailing social standards and common sense.

5-5 Transactions with Small Subcontractors

We comply with our obligations under the Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors and will not conduct unfair business and practices prohibited as an abuse of dominant bargaining position.




6-1 Compliance with Antitrust Laws

We will not engage in unreasonable restrictions of competition and/or unfair practices prohibited by any applicable antitrust laws.

6-2 Improper Advertising

We will not knowingly damage the reputation of the products and services of other companies nor use false or deceptive forms of comparison in our advertisements.

6-3 Intellectual Property Rights

We will honor and respect intellectual property rights owned by others and take appropriate measures when rightful uses of intellectual property rights of others are required.

6-4 Legitimate and Appropriate Acquisition of Information

We take appropriate and legitimate measures against acquiring any non-public information of others. We will take legitimate and appropriate measures should we obtain and use undisclosed information of others.




7-1 Transactions with Government and Public Officials

We will conduct our business with government and/or public entities fairly in accordance with applicable regulations, and bidding rules and procedures.

7-2 Anti-Bribery to Government Officials

We will refrain from any conduct or behavior that could be deemed as bribery to officials of any government including quasi-government.

7-3 Political Contributions

We will comply with Public Offices Election Act, Political Funds Control Act, and other relevant political laws and regulations. We will not make political contribution to any individual or organization of policy prohibited by law or in an excess amount under the law.

7-4 Relationships with Governmental Authorities

We will fully cooperate with courts, police, tax authorities and other government authorities when such authority legally requires applicable report or notice subject to our confidential obligations to others.




8-1 Respect for Local Cultures and Compliance with Applicable Laws

We respect and understand culture of countries or regions where we conduct our business and comply with applicable laws and regulations as well as internationally acceptable standards.

8-2 Compliance with Import and Export Regulations

We will comply with proper customs procedures according to the relevant import and export laws and regulations as well as our company policy. Furthermore we will conduct security control in rigorous manner to preserve peace and harmony of international community.

8-3 Anti-Dumping

We will exercise due care in setting prices for our products and services in order to prevent and avoid anti-dumping measure or issues in international transfer-price taxation.

8-4 Gift to Foreign Governmental Officials

We will refrain from any conduct or behavior that could be deemed as bribery to officials of any foreign government under applicable laws and regulations.




9-1 Integrity

We will strive to maintain our integrity and behavior in good faith and sincere manner. We will not take or get involved in any antisocial activities that may harm our company’s reputation and damage our brand image.

9-2 Shibuya Brand Integrity

We acknowledge that our business activities and success rely heavily on the brand integrity of Shibuya acquired through past years of hard work of our employees. We will endeavor to enhance the trustworthiness and goodwill of the Shibuya brand through our business activities.

9-3 Conflict of Interest

We will not engage in any conduct which may sacrifice the interest of the Shibuya group. When conflict of interest is likely to be an issue or happened, we will report or consult with appropriate entity or body to avoid or prevent any problem.

9-4 Strict Maintenance of Confidentiality

We will not improperly disclose any confidential information obtained during one’s performance of duties, whether such information is under one’s direct control or responsibility, and the confidential obligation shall survive after one’s employment.

9-5 Cooperation with Audit

We will actively cooperate with all audits and inspections conducted by independent auditors, corporate auditors, and internal audit departments based on laws and regulations including corporate rules adopted by us, and accurately respond or submit information based on relevant facts. Furthermore, when such audits or inspections disclose a need for improvements, we will immediately follow up such requests unless there are reasonable grounds for objection.

9-6 Internal Control

We will observe and follow our internal control system to achieve the effectiveness and efficacy of business, the reliability of financial reporting, and the compliance of laws and regulations.

9-7 Publicity

When an employee is asked by any media about matters related to the company, one should politely direct such requests to the public relations department and should not make any personal comments or remarks or reports as to what he/she may have seen or heard within the company without prior permission of the company.

9-8 Utilization of Company’s Assets

We will utilize company assets including buildings, facilities, and equipment with due care and use them only for our business purpose.

9-9 Utilization of the Information Systems

We will observe internal security rules and regulations when we use the company information systems and prevent from leakage or destruction of internal information and take appropriate protective measures against unauthorized access.