Code of Conduct
As 'compliance' has evolved beyond mere legal observance to encompass broader corporate ethics and social norms, we established our 'Corporate Code of Conduct' in 2004 as a guideline for all employees. Made public in 2021 and partially revised to contribute to a sustainable society, we remain committed to advancing 'ONE STEP FORWARD,' with every employee recognizing their role as a company representative, conducting honest and fair business activities for the benefit of society.
November 2022
Shin Shin Co., Ltd.
Katsuhito Kitada
President Representative Director
1. Individual Responsibilities
1.1
All personnel within the company (including directors, employees, contract staff, and part-time workers; hereinafter referred to as “employees”) are required to comply with all laws applicable to their duties and follow the company’s code of business ethics.
Employees are also obligated to report any suspected illegal or unethical conduct to their supervisor or the administrative manager.
1.2
As a global company, we comply with the laws and respect the ethics of every country in which our group companies operate.
1.3
Each Employee is responsible for practicing ethical behavior. Employees are obligated to remain vigilant for situations that may lead to illegal or unethical acts and must respond in a timely and appropriate manner to prevent misconduct.
1.4
Directors and managers are expected to lead by example and are responsible for ensuring that all employees understand and put into practice the principles set forth in this Code.
2. Respect for Human Rights
We respect the fundamental human rights of all individuals. We strictly prohibit discrimination based on race, age, gender, nationality, ethnicity, religion, educational background, creed, sexual orientation, gender identity, or disability. Any actions that harm an individual’s dignity—including power harassment, sexual harassment, or any other form of harassment or bullying—are strictly forbidden, and we will take decisive action against such conduct. Furthermore, we maintain a zero-tolerance policy towards child labor and forced labor, which are prohibited by law, under any and all circumstances.
3. Social Responsibility
3.1 Environmental Policy
We have established an "Environmental Policy" to guide our business activities, products, and services from a global perspective. We are committed to complying with environmental laws and regulations while continuously working to reduce and mitigate our environmental impact. Each Employee recognizes their social responsibility and shall strive to be mindful of environmental conservation and to continuously improve our environmental performance.
3.2 Political Contributions / Political Activities
We comply with the Political Funds Control Act and other applicable laws regarding requests for financial support from political parties, political organizations, and candidates for public office, while maintaining a transparent and fair stance.
3.3 Charitable Donations
When making charitable donations, we give full consideration to their necessity and appropriateness, and act in accordance with applicable laws and regulations.
3.4 Prohibition of Involvement with Anti-Social Forces
We take a firm stance against anti-social organizations and groups that threaten public order and safety. We do not engage in any activities that support or encourage such groups and maintain no relationship with them.
3.5 Export and Import Controls
In order to contribute to the maintenance of international peace and security, we conduct appropriate import and export transactions in compliance with applicable laws and regulations, economic sanctions measures, and internal company rules.
4. Customer Relations
4.1 Business with Customers
We conduct business with customers in a fair, honest, and sincere manner. For the products and services we provide, we prioritize customer satisfaction and strive to ensure the highest standards of safety, quality, delivery, and cost efficiency.
4.2 Business with Resale Partners
Resale prices are determined at the discretion of resale partners. We do not, either contractually or verbally, engage in actions that influence resale pricing.
4.3 Sales Promotion and Advertising
All statements in promotional materials, product packaging, instruction manuals, and advertisements shall be fair, accurate, and based on facts.
4.4 Marketing / Sales Activities
We do not use misleading or false statements, representations, or claims regarding the quality, performance, specifications, or other aspects of our products and services.
5. Supplier Relations
5.1 Business with Suppliers
Relationships with suppliers are extremely important to our business with customers. In selecting suppliers, we make comprehensive evaluations based not only on price, but also on technological capabilities, quality, warranty, delivery, reliability, environmental initiatives, responsiveness, and financial stability.
We do not give preferential treatment to any specific company through gifts, entertainment, or personal relationships between suppliers and our employees.
We also periodically review suppliers by assessing whether they can continuously provide products and services that meet our specifications and whether their financial condition remains stable.
5.2 Purchasing Prices
We actively and fairly negotiate with suppliers to obtain the most favorable pricing, but we do not abuse a superior bargaining position to force unreasonably low prices.
5.3 Responsible Mineral Procurement
As part of our commitment to responsible mineral sourcing, we do not use minerals illegally mined in the Democratic Republic of the Congo or neighboring countries in our products or components. We also avoid procurement from suppliers associated with risks such as human rights violations, environmental destruction, or conflict.
To address these issues, we continuously share information and cooperate with customers and business partners.
6. Relations with Competitors
6.1 Relations with Competitors
We comply with competition laws, including antitrust laws. We do not enter into agreements with competitors regarding product pricing, production volumes, or market allocation, including cartels or bid-rigging arrangements.
6.2 Acquisition of Competitor Information
We do not illegally obtain competitors’ development information, customer information, or other confidential information. We also do not encourage competitors’ employees or former employees to disclose confidential information.
Likewise, we do not obtain confidential information from employees who previously worked for competitors and later joined our company.
6.3 References to Competitors
While we clearly explain the advantages of our own products and services, any references to competitors or their products shall be fair, accurate, and based on facts. We do not defame competitors or their products.
7. Shareholders & Investors
7.1 Corporate Information Disclosure
We disclose accurate and timely corporate information, including management and operational status, to shareholders and investors in accordance with applicable laws and regulations.
7.2 Insider Trading Prevention
We prevent insider trading based on undisclosed information that may influence investment decisions.
8. Internal Governance
8.1 Conflict of Interest
Employees shall avoid any situation where their personal interests conflict with those of the company and must not improperly use their position for personal gain or for the benefit of family or acquaintances.
8.2 Sales Activities
In relation to sales activities, we do not make payments or provide benefits, gifts, or valuables to government employees. Payments of remuneration or commissions to agents and distributors are made based on formal contracts and agreed terms.
We also do not provide commissions, gifts, or entertainment to employees of business partners (including their families), except where permitted by law, government regulations, or generally accepted business practices.
8.3 Intellectual Property Rights
We protect our own intellectual property rights as valuable corporate assets and respect the intellectual property rights of others to avoid infringement.
When using third-party intellectual property or allowing our intellectual property to be used by third parties, we conclude appropriate written license agreements.
8.4 Protection of Confidential Information
We protect information entrusted to us by customers, suppliers, business partners, shareholders, employees, and other stakeholders, and take measures to prevent leaks, loss, and other incidents.
When receiving or disclosing confidential information to third parties, we obtain prior internal approval and conclude a confidentiality agreement.
8.5 Contract Execution
When buying or selling products and services, outsourcing or receiving work, or engaging in any other transactions, we, in principle, conclude written contracts through prescribed internal procedures to clarify rights and obligations and prevent disputes.
8.6 Company Assets
Employees are obligated to protect company assets and shall not use them improperly, illegally, or for any purpose outside their authorized scope of work.
8.7 Document and Records Management
We properly create and manage business documents and records for operational, accounting, and legal purposes. Such records shall be retained for the periods specified by internal regulations and, as a general rule, shall not be stored beyond the designated retention period.
8.8 Business Continuity
In the event of unforeseen circumstances such as natural disasters, we prioritize the safety of employees and their families and strive to ensure business continuity and rapid recovery to minimize impact on stakeholders.
Supplier Code of Conduct
To ensure that social responsibility is reliably fulfilled throughout our supply chain, we request all suppliers to comply with the "Shin Shin group Supplier Code of Conduct.
"The "Shin Shin Group Supplier Code of Conduct" is available in the following languages: