From November 2 to November 5, 2015, W&B Partner Cathy Wu hosted the 2015 Compliance Training for the four subsidiaries of Shimano Inc. in Shanghai, Kunshan, Lianyungang and Tianjin. Founded in 1921 and headquartered inJapan’s Osaka Prefecture, Shimano Inc. is a multinational group that specializes in manufacturing and distributing bicycle parts, fishing gear, snowboards and golf supplements. The training was a significant component of Shimano’s compliance project in the Asian-Pacific Region, and W&B was honored to provide compliance training for Shimano’s Chinese subsidiaries for the third time.

The training covers four topics: Commercial Bribery, Entertainment and Gift Policy, Trade Secret Protection and Protection of Information about Individuals, Partners and Competitors. During the Commercial Bribery session, Ms. Wu started from new types of bribery such as WeChat “red envelopes” (cash gifts), mixtures of bribes and gifts, hidden or disguised bribes and indirect bribes. She explained recent law enforcement trends and hot issues to help employees understand the nature of commercial bribery and unjustifiable interests. To illustrate the business aspects of each Shimano subsidiary, Ms. Wu explained a number of cases that address difficult issues in commercial bribery including product procurement and bidding issues, discounts, rebates and kickbacks, additional gifts and promotional expenses, slotting allowances, promotional sponsorships and the Foreign Corrupt Practices Act (“FCPA”). On that basis Ms. Wu proposed compliance mechanisms and bribery countermeasures.

In the Trade Secret Protection session, Ms. Wu first introduced the Top 10 risks of trade secret disclosure inChina. She then explained complex issues in simple terms, including the statutory elements of a trade secret and the judicial standard for determining trade secret infringement. Finally, she summarized issues relating to the potential loss or disclosure of trade secrets in routine business operations and employees’ professional and personal life, and explained risk control guidelines from various perspectives.

In the Information Protection session, Ms. Wu focused on major data acquisition and the commercial applications of compliance. She also explained the provisions of the Guidelines for the Protection of Individual Privacy in Information Security Technology Public and Commercial Service Information Systems and described information disclosure-related crimes covered by the Criminal Law. She introduced concepts related to the necessity for individual privacy protection and the consequences of disclosure. Finally, during the interactive session Ms. Wu answered questions and communicated with the audience concerning actual problems encountered in the companies’ business operations.