Our Policy and Strategy
To give shape to our commitment to fulfill the dreams of our stakeholders, the TOMY Group has determined the ONE TOMY’s Promise 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 ONE TOMY’s Promise.
Management Structure
Risk/Compliance Committee
The Risk/Compliance Committee, chaired by the Representative Director and composed of directors, including members of the Audit and Supervisory Committee, deliberates on significant risk and compliance matters* and reports its findings to the Board of Directors to strengthen and ensure the effective operation of the Group's compliance and risk management framework.
Based on the deliberations of the Risk/Compliance Committee, the Company has established a Group-wide risk management framework integrated with internal controls and promotes a strong culture of compliance throughout the TOMY Group.
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 officers and others who could not attend the conference to use to improve compliance awareness.
Since the COVID-19 pandemic began in fiscal 2019, we have been distributing online videos and e-learning on an ongoing basis. The main content includes messages from top management, including the TOMY Group chairman, president, and others, sharing of compliance violation case studies, reports on the use of our whistleblower system, and activity reports from our compliance leaders. In these activity reports, compliance leaders report 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 established the TOMY Group Hotline (internal whistleblower system) to facilitate the early detection and correction of violations of laws and regulations, misconduct, and inappropriate conduct*, thereby ensuring respect for and protection of the human rights of officers and employees, effective risk control, and the maintenance of social trust.
When a report is received, the Company promptly conducts a fact-finding investigation and, where a violation is identified, takes corrective action and implements measures to prevent recurrence. In addition, the Company has established internal rules to ensure that whistleblowers are not subjected to any disadvantageous treatment as a result of making a report and maintains a framework that protects the privacy of whistleblowers.
