Our Policy and Strategy
To give shape to our commitment to fulfill the dreams of our stakeholders, the TOMY Group has determined a Code of Conduct for all employees to observe, and also set up a TOMY Group Code of Business Conduct (COBC) to promote a deeper understanding across the Group of the specific actions required to fulfill the Code of Conduct.
Management Structure
Risk/Compliance Committee
The Risk/Compliance Committee, chaired by one of the representative directors and comprising primarily outside directors and Audit & Supervisory Board members, deliberates important risk and compliance-related issues and reports its findings to the Board of Directors. The Internal Control & Audit Group, an organization under the direct control of the representative directors, audits the Group’s compliance status and reports the results to the representative directors and the Audit & Supervisory Board while conducting compliance awareness-building activities.
Compliance Leaders System
We have introduced a compliance leaders system with the aim of further strengthening compliance awareness and forming a relevant framework. We appoint a senior-level manager from each department of our Group companies in Japan to serve as compliance promotion officer. We invite external specialists to conduct training sessions for compliance leaders, who have been selected by the appointed compliance promotion officers, on the relevant compliance laws and regulations that need to be adhered to and other pertinent knowledge.
Dealing with Antisocial Forces
TOMY has implemented various measures to prevent interaction with antisocial forces, including creating a designated department, establishing pertinent internal frameworks, facilitating the centralized collection and storage of information relating to antisocial forces and compiling a comprehensive response manual. We foster close links with local police, attorneys and related organizations to ensure active and effective cooperation in times of emergency. We also exploit compliance training and other opportunities to pursue awareness-building activities designed to eliminate antisocial forces.
Key Initiatives
Think about Compliance Day and Compliance Leaders’ Activity Report
The TOMY Group designates a Think about Compliance Day once a year when all Group employees reaffirm the importance of compliance and share the nature, causes, and specific countermeasures enacted in the rare event of a compliance violation to help prevent a recurrence. A video recording is available for anyone who couldn’t attend the conference and for Group companies outside Japan to use to improve compliance awareness.
In fiscal 2019, we distributed online videos and offered online e-learning opportunities with a view to preventing the spread of COVID-19. We prepared top messages from the TOMY Group chairman, president, and heads of individual Group companies, a report on the use of our whistleblower system and an activity report about our compliance leaders system. In the activity report, the compliance leaders reported the results of various improvement activities carried out in individual workplaces in accordance with an annual activity plan based on important compliance-related themes such as workstyle reform.
Compliance Training
To prevent compliance violation, it is vital that we boost compliance awareness among all employees and directors across the organization. The TOMY Group has implemented various measures to help them fully comprehend the need for strict compliance.
We support a variety of ongoing awareness building for Group companies in Japan, including poster displays within the company and an e-mail magazine. The twice-a-month e-mail magazine covers compliance-related news and familiar local cases, and uses mini tests, visual comic strips, illustrations and other communication tools to steadily foster a more intuitive understanding of compliance.
Over the past three years, we have also offered e-learning programs, which cover a basic understanding of contracts, standards for recording sales and expenses, information security, Japan’s Act against Unjustifiable Premiums and Misleading Representations and subcontracting law, along with other compliance-related programs on such topics as protecting intellectual property, protecting personal information, effective time management, manners and ethics, diversity, harassment, and reducing long working hours.
Internal Whistleblower System (TOMY Group Hotline)
The TOMY Group has set up the whistleblower hotline to strengthen compliance management through the early detection and correction of misconduct. When a report comes in, we promptly check the facts and, if we discover a violation, strive to correct it and prevent a recurrence. In addition, we have internal rules and systems in place that ensure whistleblowers are not treated disadvantageously for having submitted a report and that protect their privacy.
