The TOMY Group strives to conduct business activities based on our founding philosophy “Let’s excite the world’s markets with our outstanding products.”“Our sincerity and diligence will contribute to society and lead to our own success and happiness.”
Our corporate mission focuses on fulfilling the dreams of our stakeholders, and our commitment to each group of stakeholders is set out in our corporate guidelines. In order to fulfill the dreams of all stakeholders, we have decided a code of conduct that we expect all Group employees to adhere and refer to in their daily business dealings.

We have established the TOMY Group Code of Business Conduct (COBC) which determines more concrete guidelines and encourages a deeper understanding across the Group of the elements relating specifically to “observing our company policy, the rule of law and good common sense,” and “competing honestly and following fair trade practices” within our Code of Conduct. The COBC conveys a key message about the Group’s fundamental spirit, namely that if we want to maintain a position of deep respect and admiration among our most important customers, children, we must never act in a way that displays adults in an ugly light.
The COBC is intended to explain how employees should act in the event of a compliance violation or any action that is deemed or is suspected to be contrary to the COBC. More specifically, the COBC encourages employees to learn about and uphold laws, regulations and internal standards, understand and respect different customs and values, discuss issues with their superiors or responsible departments, and make use of the TOMY Group hotline to file a report.
We have created study materials in seven languages and offer offline and e-learning training to ensure all Group employees, both inside and outside Japan, gain an accurate understanding of the content of the COBC.

TOMY Group Philosophical Construct

Code of Conduct

As we strive to fulfill the dreams in our Corporate Mission, we promise...

We will produce products that promote children's healthy growth.

We will maintain thorough product quality and safety assurance.

We will observe our company policy, the rule of law and good common sense.

We will compete honestly and follow fair trade practices.

We will not tolerate anti-social behavior.

We will be a good corporate citizen toward society and the regions where we operate.

We will be considerate of resources and the natural environment.

We will respect individuality and foster initiative and creativity.

Outline of TOMY Code of Business Conduct

• 1. Fundamental spirit
• 2-1. Basic approach
• 2-2. Observe company policy and rule of law
  Comply with subcontracting, antitrust and other relevant laws and regulations/Conduct thorough internal management of intellectual property, etc. and respect the rights of other companies/Accurately record and process accounting data and strictly handle accounting records/Prohibit insider trading, etc.
• 2-3. Act with good common sense
  Maintain clean and healthy relationships with politicians and governments/Uphold the laws and regulations of each country or region and respect human rights and cultures (prohibit child labor, forced labor, and long working hours, guarantee minimum wage and the right to collective bargaining, etc.)/Contribute to the development of local economies and community culture by developing and growing business in individual countries and regions/Train and hire local personnel/Uphold laws and regulations relating to international trade transactions/Prohibit harassment/Respect the freedom of individual thought and religious beliefs, etc.
• 2-4. Compete honestly and follow fair trade practices
  Prohibit conflicts of interest in business/Prohibit any involvement in bribery/Rules surrounding entertaining and gift-giving, etc.
• 3. How to deal with compliance violations (encourage discussion, reporting)
  Pledge

With the goal of fostering an ethical corporate culture that is in step with the times, within the Sustainability Promotion Division under direct control of the President, the TOMY Group has established a corporate ethics department that promotes relevant initiatives throughout the Group, such as developing internal regulations and creating structures to apply them.
We are particularly conscious of the influence we may exert on children and other users through merchandizing and media expressions. Therefore, in addition to complying with laws, regulations and the TOMY Group COBC, in our internal regulations and Social Media Policy we have established ethical standards that take into account social norms and moral perspectives for merchandizing and expressions used in media advertising. In addition, we have also taken steps such as creating guidelines for providing ethical responses suitable to the target age ranges for our products and media, utilizing a thorough checking system, and having ethics specialists available for consultation.
With the aim of ensuring awareness of rules and regulations, we hold ethics training for all employees working for the Group in Japan and include related content in a monthly newsletter to deepen employee understanding of corporate ethics so that they may apply them in their own duties.