The findings in this report suggest that many companies are systematically misreporting compliance with their sustainability and stakeholder obligations under the code, or, have a fundamental lack of understanding as to what constitutes meaningful sustainability reporting and stakeholder engagement. While this is not the fault of the corporate governance code itself, the ambiguity in the code and guidelines facilitates this misreporting. in particular, there is a lack of clarity on the range of stakeholders that should be considered, what measures are “appropriate” in addressing sustainability issues and what non- financial information should be disclosed (see recommendations section). Consequently, Japan’s corporate governance code does not presently enable shareholders or other stakeholder groups to have sufficient confidence in the corporate sustainability performance of Japanese companies. In order to remedy the deficiencies identified in this study, the code’s sustainability and stakeholder reporting obligations and guidance must be strengthened and clarified, and companies must urgently improve efforts to understand and address the serious range of sustainability and stakeholder issues connected to their business operations.