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Compliance

Shibuya Group Compliance Code of Business Conduct

The management philosophy of the Shibuya Group is based on “Work with Joy,” a philosophy that encourages employees to maintain a positive attitude and take on new business challenges. This reflects the daily motto established by our founder. We contribute to society by addressing business challenges under the principle of putting the Customer first. “Compliance” refers to the Shibuya Group companies and their employees maintaining an open and fair attitude toward all stakeholders, including shareholders, customers, suppliers, and society, while complying with laws, regulations, internal rules, business ethics and social norms. The Shibuya Group Compliance Code of Business Conduct provides specific examples of conduct and behavior intended to put these principles into practice.

Compliance Committee

1. Relationships with Customers

1-1 Customer Satisfaction

We, the Shibuya Group Companies, strive to achieve customer satisfaction by providing 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 and guidelines concerning product and workplace safety. We take all reasonable measures to ensure that our products or services do not cause harm to any person or damage to property. If any damage or injury occurs despite these efforts, we are committed to providing prompt and appropriate remedies and taking measures to prevent recurrence.


1-3 Proper Advertisement and Publicity

We provide customers with accurate information regarding our products and services.


1-4 Product Liability

We comply with applicable product liability laws and regulations and provide products responsibly while fulfilling our accountability obligations.


1-5 Protection of Customers' Business Information

We comply with applicable laws, regulations, internal rules, and agreements and take all reasonable measures to protect customers’ information.


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

We are committed to maintaining after-sales support for our customers. We respond to customer requests and inquiries diligently and promptly to ensure customer satisfaction.


1-7 Business Entertainment

To maintain appropriate relationships with customers, we do not offer excessive gifts or business entertainment, whether tangible or intangible, beyond prevailing social standards and common business practices, neither do we permit any inappropriate payment to customers’ personnel.

2. Relationships with Shareholders and Investors

2-1 Accurate Accounting and Financial Reporting

To ensure our accurate and timely financial reporting, we properly, honestly, and promptly process all financial transactions of our respective companies, including, without limitation, the recognition of sales and the incurrence of costs, in accordance with applicable accounting and tax laws, regulations and internal rules. We do not engage in any inappropriate accounting practices under any circumstances.


2-2 Timely Disclosure

To maintain management transparency, we treat all shareholders and investors fairly and disclose accurate business information in a timely manner. We also promptly disclose information that may have a material impact on our business operations.


2-3 Speculative Trading

We do not engage in speculative trading which may adversely affect our business activities.


2-4 Profit Distribution

We strive to distribute profits appropriately while retaining sufficient internal reserves for investment that support long-term sustainable growth.


2-5 Improper Benefit to Shareholders

We do not provide financial benefits to improperly influence shareholder behavior.


2-6 Insider Trading

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

3. Relationships with Employees

3-1 Respect for Creativity and Independence

We provide employees with appropriate working conditions, education and training. We respect their creativity and independence and strive to promote the Three Kai initiatives of Kaizen (improvement), Kaikaku (reform), and Kaihatsu (development) We encourage and promote inventions and innovations developed through our business activities.


3-2 Employer-Employee Relationships

We respect employee's rights and comply with all applicable laws and regulations, including agreements with employees’ labor unions. We promote an environment in which employees and management cooperate to achieve corporate objectives through open communication and discussion.


3-3 Safety and Health

We strive to improve the working environment by taking necessary measures on a continuous and planned basis in order to maintain and improve employees’ physical and mental health. We comply with applicable labor laws relations and take necessary measures to establish safe and comfortable working conditions.


3-4 Fair Evaluation and Compensation

We evaluate and compensate our employees based on fair rules and criteria, including job performance, responsibilities and achievements.


3-5 Promotion and Development of Job Skills

We promote the professional development of all employees and strive to enable every employee to maximize their potential and performance regardless of age, gender, nationality, or other unrelated factors.


3-6 Harassment

We prohibit discrimination and any language or behavior that may constitute harassment, including sexual harassment and power harassment.

4. Relationships With Society

4-1 Respect for Human Rights and Prohibition against Discrimination

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


4-2 Harmonization with Society

We recognize our responsibilities as a member of society and strive not to become bound by internal organizational logic that is disconnected from broader social values. We seek to cultivate values, and conduct that are accepted by society and cooperate with local communities in pursuit if social harmony.


4-3 Protecting the Global Environment

We recognize the importance of global sustainability. We comply with applicable environmental laws and regulations and utilize environmental management systems to fulfill our environmental responsibilities.


4-4 Dealing with Antisocial Forces

We reject all relationships with antisocial organizations or individuals. We take a resolute stance against unjust demands, including those disguised as business transactions or customer complaints.


4-5 Social Contribution

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

5. Relationship with Suppliers

5-1 Equal Partnership

Suppliers and other participants in the supply chain are important business partners. We seek to establish, long-term, stable relationships based on mutual trust.


5-2 Supplier Selection

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


5-3 Fair Trade

We do not engage in unfair trade practices or unfair dealings with suppliers.


5-4 Elimination of Improper Relationships

We our employees from abusing their position by accepting entertainment, money and goods, any other tangible or intangible benefits, personal compensation, or commissions from suppliers beyond the prevailing social standards and accepted business practices.


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 do not engage in unfair business practices prohibited as an abuse of a superior bargaining position.

6. Relationships with Competitors

6-1 Compliance with Antitrust and Competition Laws

We do not engage in unreasonable restraints of trade or unfair trade practices prohibited by antitrust and competition laws.


6-2 Prohibition of Unfair Comparative Advertising

We do not disparage the products or services of other companies, or use false comparisons or comparisons that may confuse or mislead customers in our advertising and promotional activities.


6-3 Respect for Intellectual Property Rights

We respect the intellectual property rights of other companies and obtain the necessary rights through legitimate methods and procedures when using such intellectual property.


6-4 Lawful and Appropriate Information Acquisition

When acquiring non-public information of competitors or other entities, including corporate information, trade secrets, and patent-related information, we do so only through lawful and appropriate means.

7. Relationships with Governments and Politicians

7-1 Transactions with National and Local Governments and Other Public Institutions

We conduct transactions with national and local governments and other public institutions fairly, in accordance with bidding processes and other prescribed rules and procedures.


7-2 Prohibition of Bribery of Public Officials

We strictly refrain from any acts that may be regarded as bribery of public officials or persons deemed to be public officials.


7-3 Political Contributions

We comply with the Public Offices Election Act, the Political Funds Control Act, and other applicable laws and regulations related to political activities. We do not make political contributions to individual politicians where prohibited by law, or donations to political organizations or political parties in amounts that exceed legally permitted limits.


7-4 Response to Relevant Public Authorities

When requested to provide reports, notices, or other submissions by relevant public authorities, including courts, police departments, tax offices, the Fair Trade Commission, and Labor Standards Inspection Offices, the Company cooperates in good faith, except where restricted by confidentiality obligations.

8. Compliance Requirements for International Transactions

8-1 Understanding and Respect for Cultures and Compliance with Legal Systems Worldwide

In each country and region where we conduct business and transactions, we understand and respect local cultures and comply with applicable laws and regulations, including those of Japan and the relevant countries, as well as international standards.


8-2 Compliance with Import and Export Regulations

When conducting import and export operations, we follow proper procedures in accordance with relevant laws, regulations, and internal rules. We also rigorously implement security trade controls to help maintain international peace and security.


8-3 Avoidance of Dumping and Related Practices

We exercise due care in setting prices to avoid being subject to anti-dumping measures or transfer pricing rules in any country.


8-4 Prohibition of Bribery to Foreign Public Officials

We do not offer bribes to foreign public officials in violation of the laws and regulations of the relevant countries.

9. Awareness and Conduct as Members of the Shibuya Group

9-1 Maintaining Dignity and Integrity

We maintain the dignity expected of employees of the Shibuya Group and act with integrity. We do not engage in any words, actions, or socially unacceptable conduct that could damage the Company’s reputation.


9-2 Enhancing Trust in the Brand

Recognizing that the business activities of the Shibuya Group rely significantly on the image of the Shibuya brand, which has been built through the many years of dedication of our predecessors, we strive to enhance trust in the Shibuya brand through all business activities.


9-3 Avoidance of Conflicts of Interest

We do not engage in any activities that conflict with the interests of the Shibuya Group. If there is any risk of such a conflict, we report the matter and seek guidance in advance to avoid any issues.


9-4 Strict Compliance with Confidentiality Obligations

We do not improperly disclose confidential information obtained in the course of our duties to any third party, regardless of whether such information falls within our area of responsibility. This obligation applies not only during employment but also after leaving the Company.


9-5 Cooperation with Audits and Investigations

We actively cooperate with audits and investigations conducted by accounting auditors, Audit & Supervisory Board Members, Integrated Internal Control & Audit Div., and other relevant bodies regarding compliance with laws, regulations, and company rules. We provide accurate responses and submit materials based on facts. If improvements or other measures are requested, we promptly comply unless there are reasonable grounds for objection.


9-6 Significance of Internal Control

Together with the Company, including the Board of Directors and management, we carry out processes established as part of internal control to help ensure the achievement of objectives such as the effectiveness and efficiency of operations, the reliability of financial reporting, and compliance with applicable laws and regulations.


9-7 Media Relations

When contacted by the media regarding matters related to the Company, we politely ask them to contact the department responsible for public relations. Employees do not carelessly disclose their personal views or matters they have seen or heard within the Company to the media.


9-8 Appropriate Use of Company Assets

We handle buildings, equipment, fixtures, and other Company assets with care. Items issued to individual employees are used solely for business purposes.


9-9 Use and Management of Information Systems

When using information devices and information systems, we comply with internal operational rules to prevent the accidental destruction or leakage of information, and thoroughly implement safeguards against external threats and unauthorized access.

Management Structure for Public Research Funds

The Company properly administers and manages competitive research funds and other public research funds under the following structure:

1. Responsibility Structure

  • Chief Administrative Officer
    Representative Director, President and CEO
  • General Administrative Officer
    Director in Charge of General Affairs
  • Compliance Promotion Officer
    General Manager of the General Affairs Department

2. Inquiry and Consultation Desk for Competitive Research Funds / Reporting Desk for Misuse of Public Research Funds

Inquiries Regarding Competitive Research Funds
Shibuya Corporation
General Affairs Department, General Affairs Headquarters
Ko 58, Mameda-honmachi, Kanazawa, Ishikawa 920-8681, Japan
Tel: +81-76-262-1201