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
Compliance Promotion System
Sanrio maintains a Joint Compliance Committee consisting of five members—a chairperson, a vice-chairperson, an outside director, an outside auditor, and an 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.
In addition, the Joint Compliance Committee regularly has employees and officers conduct self-assessments of their activities in terms of the basic philosophy and code of conduct as a method for enhancing 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 Office
The Compliance Office was created in October 2023 to ensure and establish overall compliance throughout the company and to continuously improve it. The office 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 office also serves as the secretariat of the Joint Compliance Committee.
Employee and Executive Awareness and Training
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 employees and officers are expected to follow in the course of carrying out their daily duties.
Compliance Training
Executives and all employees participate in compliance training.
Executives participate in annual video lessons presenting content about the obligations of directors to ensure 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.
Compliance Self-assessment
Sanrio employees and executives 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.
Employee Surveys
Compliance questionnaires are conducted by 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.
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), management, and business partners to report any company or employee misconduct that has been experienced, observed, or heard about, violations of laws or regulations, or inappropriate behavior or conduct in the workplace.
The consultation desk talks directly with the person who has provided the information, and the head of the 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 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. In the course of interviews and investigations, the privacy of the individual who reported the issue and the employees who participated in the interviews is protected. 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 FY3/2024, the number of reports received was 47 (an increase of 17 from the previous fiscal year). In nine of these cases, the Compliance Subcommittee convened and discussed the matters after which appropriate measures were taken, such as improving the workplace environment.
Depending on the content, reported matters are investigated and details are verified prior to taking responsive action, such as steps to improve the work environment.
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 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 and 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.
Corruption Risk Assessment
Sanrio makes efforts to understand compliance risk, including corruption risk, at each Group company. The 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 an 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.
No issues related to corrupt activities or risks were reported in the evaluation conducted for FY3/2024.
Sanrio plans to improve the evaluation of corruption risk in the future by stipulating the inclusion of “corruption risk” as a separate category and including specific questions about corrupt practices in the compliance questionnaire.
Anti-corruption Activities
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.
In addition, the Company plans to establish and enforce rules and guidelines regarding entertainment and gift-giving for the head office by the end of FY3/2025.
Anti-corruption Activities
In FY3/2024, 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.
Compliance with the Act Against Unjustifiable Premiums and Misleading Representations
Please refer to Policy to Misleading Representations(Japanese)
Information Security
Sanrio uses information about our customers and business partners as well as information created by the Company for its business activities. We recognize our responsibility as a business operator to protect this information and the information systems used to handle it from various threats so our customers can use our products and services with peace of mind.
Information Security System
Sanrio appoints a Group general manager and maintains an internal control department for information security, and each department appoints a person in charge and an information system manager to implement departmental measures. We also assess Group risk-response and correction measures. To ensure comprehensive information security measures, Sanrio conducts mandatory e-learning courses for employees several times a year, offers voluntary information security seminars three times a year, and conducts targeted e-mail attack tests multiple times a year. In addition, we engage reliable third parties to audit the quality of our security at appropriate times.
Protection of Private Information
Sanrio enforces the Sanrio Group Privacy Policy and strives to ensure the appropriate handling of private information. Overseas Group companies comply with local privacy laws; in the European Union, policies and enforcement systems have been established based on the EU General Data Protection Regulation (GDPR) and in the United States, a private information handling policy and enforcement system have been established based on the California Consumer Privacy Act (CCPA).
A system has been established for digital businesses to verify and ensure compliance with the laws and regulations of each region. After confirming matters to address with a law firm, an external third-party organization checks the operating system and system configuration at the company and its outsource partners. Through these measures, Sanrio seeks to ensure information security and compliance with Japanese and local laws.