http://dictionary.reference.com/browse/religion
Looking at a definition of religion:
a set of beliefs concerning the cause, nature, and purpose of the universe,
especially when considered as the creation of a superhuman agency or agencies,
usually involving devotional and ritual observances, and
often containing a moral code governing the conduct of human affairs.
So it does not require a) god , higher power or b) devotion or ritual observance or c) a moral code for it to comply as being a religion.