Policy and basic approach
Sanrio Compliance Declaration
Since its founding, Sanrio and the Sanrio Group companies (hereinafter referred to as Sanrio) have followed the basic philosophy that social communication is important for people around the world to live in harmony. Based on that philosophy, Sanrio has developed a social communication business mediated by Hello Kitty and other Sanrio characters following the principles of behavior of not stealing from other, not engaging in violence, not engaging in deception, following the law, and employees helping each other to live in harmony.
As a result, Sanrio has earned high praise in Japan and around the world as an unparalleled social communication business.
Given the attention it has received, Sanrio decided to issue its Sanrio Compliance Charter to share its basic philosophy and code of conduct
I hereby declare that all Sanrio employees and executives will continue to comply with the Sanrio Compliance Charter and make every effort to enhance social communication.
Tomokuni Tsuji
President and CEO
Prevention of corruption
The Sanrio Compliance Charter requires compliance with anti-corruption laws and regulations and measures to prevent bribery and other corrupt practices.
We maintain sound and normal relations with the administrations and governments of the countries and regions in which we operate, and we do not condone any act of corruption. We do not make illegal or inappropriate donations or contributions that violate relevant laws, regulations, or internal rules. We follow appropriate procedures and conduct fair transactions in Japan or overseas when dealing with administrations and government agencies and when carrying out administrative procedures necessary for business activities. We do not provide bribes, gifts, or entertainment to public officials or equivalent persons.
We do not use non-public information from within the Company or our business partners to engage in any act that could be considered as insider trading.
Approach to preventing insider trading
We specify management standards relating to internal information and rules that company officers and employees must comply with when trading company shares, etc. Rules on preventing insider trading have been established to prevent insider trading that violates laws and regulations. To accomplish the purpose of these rules, we strive to educate employees on the importance of internal information management and the intent of laws and regulations pertaining to insider trading.
Compliance with the Act Against Unjustifiable Premiums and Misleading Representations
Please refer to Policy for the Prevention of Misleading Representations (in Japanese only)
Structure and governance
Compliance promotion system
Sanrio maintains the Sanrio Joint Compliance Committee consisting of five members—a chairperson (Managing Executive Officer responsible for the Internal Control Division and the Human Resources Division), a vice-chairperson (Managing Executive Officer responsible for the Corporate Management Division), an outside director who does not serve as an Audit and Supervisory Committee member, an outside director who serves as an Audit and Supervisory Committee member, and an outside attorney. The committee's objective is to raise awareness of compliance and it meets, in principle, four times a year. The committee deliberates and determines policies to promote effective compliance activities while receiving objective opinions and viewpoints from outside committee members, and establishes temporary or other committees to discusses individual matters. The Sanrio Joint Compliance Committee deliberates on prevention of bribery, money laundering, and other forms of corruption during committee meetings and subsequently reports the significant details of such deliberations to the Board of Directors, which are then supervised by directors.
In addition, the Sanrio Joint Compliance Committee regularly has officers and employees conduct self-assessments of their activities in terms of the basic philosophy and code of conduct to ensure thorough compliance and compliance awareness. The results of the self-assessments are reported to the Board of Directors and used in deliberations on policy for future initiatives.
Compliance Department
The Compliance Department was created in October 2023 to ensure and establish overall compliance throughout the Company and to continuously improve it. The department conducts compliance education and training, regularly disseminates messages on compliance from top management, carries out monitoring activities to determine the level of compliance awareness, and plans and implements compliance activities. The department also serves as the secretariat of the Sanrio Joint Compliance Committee.
Compliance and Harassment Consultation and Reporting Desk
Sanrio has established a Compliance and Harassment Consultation and Reporting Desk for all Sanrio Group employees (including part-time and temporary employees, as well as those who have left the company within the past year), management, and business partners to report any corruption, bribery, or other illegal acts, violations of laws or regulations, the Sanrio Compliance Declaration, and other company policies, bullying, harassment, and other inappropriate behavior or conduct in the workplace that has been directly experienced, observed, or heard about. While the person reporting provides their real name to the consultation desk to enable confirmation of the circumstances cited in the report, in principle, anonymous reports are also accepted.
The consultation desk talks directly with the person who has provided the information and the chairperson of the Sanrio Joint Compliance Committee determines whether an investigation is warranted. If necessary, the committee conducts an investigation that includes collecting objective evidence and interviewing the parties concerned. Investigation results are reported to the Sanrio Joint Compliance Committee, which includes external experts, and the committee determines the appropriate action. Upon completion, the investigation results, corrective measures, preventive measures, and details of any disciplinary action are reported to the individual who reported the matter.
Report details are only shared with a limited number of relevant people and the privacy of the individual who reported the issue and the employees who participated in the interviews is protected in the course of interviews and investigations. In the event that the person who reported the issue suffers discrimination or harassment, disciplinary action will be taken in accordance with the Regulations of Employment.
In FY3/2025, the number of reports received was 67 (an increase of 20 from the previous fiscal year, partially owing to an increase in the number of employees and greater awareness of the desk achieved through compliance training and employee surveys). In 16 of these cases, the Compliance Subcommittee convened and discussed the matters after which appropriate measures were taken, such as improving the workplace environment.
Risk management
Corruption risk evaluations
Sanrio endeavors to understand and evaluate compliance risk, including the risk of bribery and corruption, at each Group company. The Sanrio Joint Compliance Committee evaluates the minutes of the Risk Management Meeting, which is held twice a year at each Group company, and the responses to the annual compliance questionnaire distributed to all employees of Group companies. If a bribery, corruption, or other compliance issue is identified, the Joint Compliance Committee requests the relevant Group company to implement the committee’s recommendations for improvement or to submit improvement measures, after which the committee monitors the implementation of improvement measures, regardless of whether it poses a high risk.
Moreover, we have introduced a system for evaluating multiple risks such as corruption and bribery, money laundering, and violation of human rights, which we use to comprehensively evaluate risk in an effort to prevent corruption when commencing commercial negotiations with a new business partner, intermediary, or other entity.
In the companywide risk evaluation performed in FY3/2025, we evaluate whether control activities are properly established and operated in regard to potential risks relating to detected acts of corruption.
Going forward, in order to improve risk evaluation accuracy, we plan to include “corruption risk” as a separate agenda item at risk management meetings, and to include specific questions on corrupt practices in the compliance questionnaire.
Indicators
Anti-corruption activities
In FY3/2025, there were no cases of political donations or lobbying activities.
In addition, there were no cases of fines or penalties due to corrupt practices or settlements of money.
Main initiatives
Anti-corruption initiatives
The Sanrio Group Compliance Manual for officers and employees stipulates and disseminates information on conflicts of interest, insider trading, and other matters related to corrupt practices. Contracts for business partners and agents of the Sanrio Group contain provisions from the Sanrio Supplier/Licensee Code of Conduct and we make sure they understand these provisions when renewing their contracts.
We also began to enforce rules and guidelines for the Head Office from July 2025 regarding entertaining and gift-giving to third parties.
Compliance Manual
As a manifestation of the Sanrio Compliance Charter, we have compiled the internal Sanrio Group Compliance Manual to promote compliance practices and serve as a guidebook for the standards of conduct that Group officers and employees are expected to follow in the course of carrying out their daily duties.
Compliance training
Officers and all employees participate in compliance training.
Officers participate in annual group training presenting content about the obligations of directors to ensure thorough compliance and on methods for fostering the corporate culture and employee awareness.
Employees participate in training about general compliance, specific laws and regulations, and recent issues associated with the annual curriculum. The Subcontract Act and personal social media use were among the topics presented in compliance training in FY3/2025.
Compliance self-assessment
Sanrio employees and officers participate in compliance self-assessments. To prevent compliance violations, regular reviews are conducted annually to ensure full understanding of the basic philosophy and behavioral principles, and irregular reviews are conducted concerning particularly important and timely items. The results of compliance self-assessments are reviewed to understand the circumstances and the self-assessments are periodically revised for effective content. This information is then reported to the Board of Directors via the Sanrio Joint Compliance Committee.
Employee surveys
Compliance questionnaires are conducted among all employees (including part-time and temporary employees) to raise awareness of corruption, misconduct, and harassment, and to collect data about pertinent issues. In the event that information related to a compliance violation is received, the Company conducts interviews and takes appropriate action in accordance with the nature of the information. We raise awareness of routine issues on employee surveys through messages to alert everyone on the company intranet, adding them to training content, messages from top management, and other means.