Sanrio Code of Conduct
Introduction
Sanrio conducts its business activities under high ethical standards based on its corporate philosophy of "Minna Nakayoku" (Getting Along Together). We believe that promoting initiatives toward the realization of a sustainable society and fulfilling our corporate social responsibility (CSR: Corporate Social Responsibility) are important management priorities.
This Sanrio Code of Conduct has been established as a set of guidelines to ensure that the business activities of Sanrio Co., Ltd. and its group companies (hereinafter referred to as the "Sanrio Group") are carried out in accordance with the principles set forth in our corporate philosophy, the Sanrio Compliance Declaration, and the Sanrio Compliance Charter. It also aims to ensure compliance with laws, regulations, and internal rules, while promoting not only high ethical standards but also effective risk management and corporate governance. The Code applies equally to all directors, employees, commissioned employees, contract employees, dispatched workers, and part-time staff of the Sanrio Group (hereinafter referred to as "officers and employees"). Through the establishment and observance of the Sanrio Code of Conduct, we aim to conduct business activities in an environment where human rights are respected and to further strengthen the fulfillment of our social responsibilities.
The Sanrio Code of Conduct sets forth basic guidelines for conduct based on Sanrio's corporate philosophy and is not intended to cover all detailed rules or internal regulations. Each officer and employee has a responsibility to properly understand and comply with the laws, regulations, and internal rules relevant to their duties.
- We will not steal from others.
Basic Policy:
Corporate assets (including intangible assets) that form the basis of any business, shall be correctly and properly used and protected.
We shall protect all personal information, third party intellectual property rights, confidential information relating to business etc. in a reasonable and appropriate manner and shall not engage in the misuse or leaking of such information.(1) Proper use of company assets
- Use company assets appropriately and distinguish clearly between business and personal use.
(2) Protection of confidential information
- Properly manage all confidential information obtained through work, including customer information and trade secrets, and prevent it from being disclosed outside the company.
- Do not improperly use confidential information, such as by disclosing it to others without authorization or using it for personal benefit.
- Do not disclose confidential information or use it for your own benefit or the benefit of others after leaving the company or engage in any actions that could harm the company's interests.
(3) Protection of personal information and privacy
- Respect the privacy of individuals, including customers, business partners, and officers and employees.
- Personal information obtained from customers, business partners, and officers and employees must be used only for purposes that were clearly communicated to the individual providing the information. Do not provide such information to third parties without a legitimate reason. Personal information must be strictly and properly managed in compliance with applicable laws and other rules to prevent unauthorized access, loss, alteration, or leakage.
- When the processing of personal information is entrusted to a third party, supervise and provide guidance to ensure that the third party properly manages the personal information.
(4) Respect for intellectual property rights
- Understand the importance of intellectual property and use it appropriately in accordance with laws and internal rules, while working to protect those rights.
- When manufacturing, selling, transferring, exporting, importing, or providing products and services, do not infringe the intellectual property rights of third parties, including patents, utility model rights, design rights, trademark rights, and copyrights.
- We will not engage in violent activities (against people, nature, or the environment, neither physically nor psychologically).
Basic Policy:
We will provide products and services that take safety, quality, and the environment into consideration.
Sanrio places value on the basic human right of equality among people, and Sanrio will not discriminate against anyone or place them at a disadvantage based upon social or employment status, age, gender, place of birth, ancestry, nationality, race, the existence of a disability, religion, ideology, marital status and so on.
A firm and uncompromising stance will be taken towards antisocial forces.(1) Product safety management
- In addition to complying with laws and regulations related to product safety, work to prevent product incidents by evaluating the safety and quality of products handled, providing feedback, and collecting information on safety and quality issues.
- If a serious safety or quality issue occurs, report it to the relevant authorities and take appropriate steps to identify the cause and implement measures to prevent recurrence so that damage does not spread.
(2) Environmental protection
- Comply with international environmental regulations as well as environmental laws and regulations of national and local governments.
(3) Respect for human rights
- Do not discriminate in hiring, pay, training opportunities, promotion, discipline, or any other employment practices based on race, beliefs, religion, skin color, gender, sexual orientation, nationality, family origin, age, marital status, disability, pregnancy, union membership, political affiliation, or any other personal characteristics.
- Do not require forced or involuntary labor. Forced or involuntary labor includes work performed under the threat of penalty or coercion, or work that a person has not voluntarily agreed to perform. Restrictions on movement or the retention of workers' identity documents or work permits are also recognized as forms of forced labor and are not permitted.
- Do not allow child labor. Child labor refers to work performed by anyone under the age of 15, the local legal minimum working age, or the age for completing compulsory education—whichever is higher. In addition, do not employ anyone under the age of 18 in hazardous or harmful work that could endanger their health, safety, or morals.
(4) Firm stance against antisocial forces
- Do not engage in any transactions with antisocial forces, regardless of whether they claim to be acting legally or under any type of pretext.
- If improper demands are made by antisocial forces, firmly refuse those demands.
- We will not lie.
Basic policy:
Sanrio will share its corporate information in a fair and reasonable manner, further improving operational transparency as it interacts with society on a broad scale.
Sanrio will provide appropriate and honest information to consumers and customers regarding its products and services.(1) Proper accounting and tax reporting
- When performing accounting duties, follow accounting rules and other internal regulations, applicable laws and regulations, and generally accepted accounting standards.
- File all tax returns properly in accordance with applicable laws and regulations.
(2) Appropriate disclosure of company information
- As a listed company, disclose important company information related to business activities, operations, or performance that may significantly affect investment decisions in a timely and appropriate manner.
(3) Prohibition of unfair competition
- Do not use names, trademarks, or other marks that are identical or similar to those widely recognized as belonging to another party (such as trade names, trademarks, or symbols).
- Do not make false or misleading statements about the origin, quality, content, manufacturing method, use, or quantity of products or services in products, services, advertising, or related materials.
- Do not sell products that imitate the design or form of another party's products (including those protected by design rights or widely recognized among consumers).
- Do not offer excessive or improper premiums or gifts or make misleading representations.
- In advertising and promotional activities, maintain fairness and high ethical standards. Take consumers' ages into consideration, confirm relevant information to avoid misleading representations, and present product features, quality, and performance appropriately. Do not defame others or use expressions that may lead to social discrimination.
- We will abide by the law.
Basic policy:
Sanrio will undertake corporate activities in a fair and reasonable manner, adhering to international and domestic law as well as societal rules and provisions.(1) Compliance with internal rules
- Properly understand and comply with internal rules, including working conditions and workplace rules set out in the work regulations, operational manuals, and other company policies.
(2) Compliance with applicable laws and regulations
- Properly understand and comply with laws and regulations related to work (such as the Companies Act, Financial Instruments and Exchange Act, Copyright Act, Trademark Act, Design Act, Act against Unjustifiable Premiums and Misleading Representations, and other relevant laws), as well as internal and external guidelines.
(3) Prohibition of bribery and corruption and restrictions on gifts and entertainment
- Comply with all applicable anti-bribery and anti-corruption laws and regulations and do not engage in corruption, extortion, embezzlement, bribery, or any similar conduct in any form.
- Do not provide or receive improper monetary payments, donations, gifts, entertainment, or other economic benefits to or from business partners or their officers, employees, or related parties beyond what is considered socially appropriate, or engage in any conduct that could create an improper relationship with business partners.
(4) Fair business practices
- Do not enter into agreements with competitors that distort fair trade or competition, such as cartels or arrangements to allocate markets, sales territories, or customers.
- Do not use a superior position to unilaterally determine or change transaction terms with business partners or impose unreasonable demands or obligations. Comply with applicable laws governing transactions, and handle any disputes related to transactions calmly and in accordance with the law.
(5) Compliance with insider trading regulations
- If you become aware of undisclosed material information about the Sanrio Group or another company, keep that information strictly confidential and do not trade in the shares or other securities of the Sanrio Group or that company until the information is publicly disclosed.
- When trading in the shares or other securities of the Sanrio Group, comply with the rules set out in the Insider Trading Prevention Regulations.
(6) Compliance with trade-related laws and regulations
- For import and export transactions involving products, technologies, or services, comply with the Foreign Exchange and Foreign Trade Act and other relevant laws and regulations in Japan and overseas, and follow the required procedures such as obtaining permits, submitting notifications, or making reports when necessary.
(7) Prohibition of conflicts of interest
- Do not engage in conduct that could damage the reputation or credibility of the Sanrio Group.
- Do not improperly destroy or damage company assets.
- When leaving the company, return any property or materials that belong to the Sanrio Group and do not use them improperly after leaving.
- Do not engage in other employment, serve as a director, executive officer, auditor, or similar officer of another company, or operate your own business without the company's permission.
(8) Fair and accurate expense reporting
- Accurately report expenses and records related to matters such as travel expenses, entertainment expenses, working hours, and paid leave.
- Employees will help each other out and foster friendly relationships.
Basic policy:
Based on the general concept that people are the core of business, Sanrio strives to create a safe, healthy and pleasant working environment where people can work with peace of mind.(1) Workplace order
- Work to maintain order in the workplace and do not engage in conduct that is inappropriate or unbecoming as a member of the Sanrio Group, whether inside or outside the workplace.
(2) Prohibition of harassment
- Work to maintain a proper workplace environment in accordance with labor laws and other relevant regulations.
- Do not engage in any form of harassment, violence, or other conduct that infringes on human rights under any circumstances, and do not tolerate such behavior by others.
(3) Protection of workers' rights
- Comply with all applicable laws and regulations regarding wages and employee benefits.
- Pay legally required premium rates for overtime work. If no legally required premium rate is specified, pay a rate higher than the regular hourly wage. Do not impose monetary penalties or wage deductions that violate labor laws or related regulations.
- Manage working hours and leave in compliance with applicable local laws and regulations. Working hours must not exceed the limits set by local laws and regulations. Employees must also be granted the leave rights provided by law.
- Ensure a safe and healthy work environment and take all necessary measures to prevent or reduce injuries, accidents, or disasters that may occur during work. Prepare response measures for potential emergencies such as fires, natural disasters, and security incidents, and ensure that employees are informed of them.
- Respect employees' rights to join or form labor unions and to engage in collective bargaining through lawful and peaceful means. Do not impose penalties, interference, discrimination, retaliation, or harassment in relation to these rights.
If a violation of the Sanrio Code of Conduct or applicable laws is discovered, the Sanrio Group will promptly investigate the cause and take measures to prevent recurrence and will impose strict disciplinary action in accordance with the work regulations and other relevant rules.
The Sanrio Group has also established a reporting hotline where questions can be raised and reports can be made if any conduct that violates, or may potentially violate, the Sanrio Code of Conduct or applicable laws is discovered.