California Transparency In Supply Chain Act

DISCLOSURE STATEMENT TO THE CALIFORNIA TRANSPARENCY IN THE SUPPLY CHAIN ACT (SB 657)

SHIMANO AMERICAN CORPORATION is strongly committed to maintaining high compliance standards in its supply chain management through its Code of Conduct and Social Accountability Standards (“Code”). The Code aligns with the international audit standard for workers’ rights, workplace conditions and management systems created by Social Accountability International, commonly referred to as SA8000®. The Code ensures that best efforts are made to positively contribute to sustainable development by addressing social and environmental impacts and by aligning the internal business goals with external society goals, including a distinct prohibition to any form of human trafficking or slavery.

• All manufacturers and suppliers are screened and verifications made to ensure they meet the high compliance standards required to produce our products. They are required to enter into formal written agreements, sign certifications of compliance for adherence to our stringent Code, Green Plan and Vendor Manual. The certifications also require that the manufacturers and suppliers do not engage in business with other parties who would violate the Code.

• Shimano American Corporation maintains internal accountability standards and procedures for employees or contractors to meet the Code including routine screenings and audits, both announced and unannounced, by personnel and/or by third party vendors to ensure full compliance. In the event that non compliance is found, prompt action is taken to remedy or immediately terminate the relationship.

• Shimano American Corporation provides its employees and management involved in the supply chain management with training on its Code to proactively mitigate risk in the production of its products.

(SA8000® is a registered trademark of Social Accountability International and is used here with their permission. For more information please go to www.sa-intl.org.)