California Transparency Act

SUPPLY CHAIN STATEMENT

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

Shimano is committed to the ensuring that the products and services provided are produced in a way that respects human rights and the environment and protects the fundamental dignity of workers. As part of this commitment Shimano is in the process of implementing and maintaining accountability standards and procedures for its suppliers including adopting a Supplier Code of Conduct.

Shimano’s suppliers under contract with Shimano are required to agree and certify that they and their subcontractors will (1) abide by Shimano’s Supplier Code of Conduct and all applicable governmental laws, rules, regulations and requirements applicable to each supplier including those prohibiting human trafficking and slavery and (2) ensure that all materials incorporated into the products supplied to Shimano comply with all laws prohibiting slavery and human trafficking in the country or countries in which they are doing business.

Shimano monitors and evaluates the performance of its suppliers. Prospective suppliers must be approved and meet Shimano Supplier Code of Conduct and all applicable governmental laws. Once approved, suppliers will continue to be evaluated through announced audits of their continued compliance with the Shimano Supplier Code of Conduct. Third parties may be utilized as needed.

Shimano continues to engage and train its employees who are directly responsible for supply chain management to understand its policies regarding its supply chain which includes understanding Shimano’s Supplier Code of Conduct requirements, awareness of human rights risks, and ways to mitigate those risks.

Shimano has developed internal accountability standards and procedures for suppliers failing to meet our company standards regarding slavery and trafficking. If and when our company uncovers supplier compliance issues, we will provide written notice and a specified period of time to take corrective action.