Our Strategy
In August 2023, the TOMY Group established and published our Human Rights Policy in accordance with the Guiding Principles on Business and Human Rights, the global standard for respect for human rights by corporations.
To date, we have established the TOMY Group Code of Business Conduct (COBC) and the TOMY Group Responsible Procurement Guidelines, and have been working with our employees, business partners, and other stakeholders to build a value chain that takes human rights into consideration. In addition, based on the Guiding Principles on Business and Human Rights, we have again clarified our policy to promote even greater respect for human rights throughout the TOMY Group.
In establishing this policy, we identified our salient human rights issues through a comprehensive review of human rights issues in the value chain of the TOMY Group’s major businesses, deliberations by management, discussions by a company-wide cross-group task force team, and interviews with external experts.
We will make this policy known internally and to our business partners, and will comply with and implement it in all our business activities.
Our Policy
TOMY Group Human Rights Policy(Established August 2023, Revised June 2024)
Based on the TOMY Group’s ONE TOMY’s Promise of “Our sincerity and diligence will contribute to society and lead to our own success and happiness,” we develop our business in various countries and regions around the world. “Contribute to society and lead to our own success and happiness” is a spirit of co-existence and co-prosperity with children, customers, employees, shareholders, business partners, and society, and respect for human rights is the foundation of this spirit. The TOMY Group hereby declares that we respect the human rights of those involved in our business, and we strive to increase our level of sensitivity to and address human rights issues so as to avoid directly causing or contributing to human rights violations.
This policy shows our commitment to our initiatives for respecting human rights, based on the TOMY Group’s Philosophies.
Respect for international human rights standards
The TOMY Group supports and respects the International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights) and other international human rights standards, as follows.
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International Bill of Human Rights: sets out basic rights that should be enjoyed by all people.
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International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work: sets out fundamental rights at work.
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Guiding Principles on Business and Human Rights: a global standard to be respected by all countries and corporations, consisting of three pillars—the State duty to protect human rights, the corporate responsibility to respect human rights, and access to remedies.
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Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises: comprehensive guidelines for responsible corporate behavior agreed upon multilaterally by the OECD member countries and others.
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The Ten Principles of the UN Global Compact: principles of the UN Global Compact, an international sustainability initiative, related to the protection of human rights, elimination of unfair labor practices, responding to the environment, and anti-corruption.
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Children’s Rights and Business Principles: ten principles that set out the actions that all corporations should take to respect the rights of children.
We also comply with the respective laws and regulations of the countries and regions in which we conduct our business activities. If there is a discrepancy between the local legal system and the international standards, we take appropriate actions through dialog and consultation with local stakeholders in accordance with the TOMY Group Philosophy and the TOMY Group Human Rights Policy.
Scope of application
This policy applies to all officers and employees, including part-time, contract, and temporary employees, of the TOMY Group. We also endeavor to ensure that all our business partners throughout the value chain of our business, our products, and our services understand this policy, and we require the same compliance by them with this policy.
Promotion Structure
As the chief executive, the President is responsible for TOMY Group sustainability, including human rights due diligence.
In July 2024, the TOMY Group established the Sustainability Committee as an advisory body to the president to carry out initiatives for sustainability issues with the intent of more actively promoting sustainability management.
The Sustainability Committee comprehensively grasps the Group’s sustainability initiatives and deliberates on the course of action for issues and endeavors based on diverse and wide-ranging viewpoints.
For themes within the mid-term sustainability targets and KPIs in particular need of cross-departmental initiatives, theme-based task forces headed by executive officers and comprised of diverse members from across the Group are established under the supervision of the Sustainability Committee. These task forces are responsible for executing, promoting, and newly proposing initiatives.
The progress of the theme-based task forces is reported on at the Sustainability Committee meetings held twice a year, and initiatives are strengthened through direction and monitoring by the Sustainability Committee.
The contents of discussions held during the Sustainability Committee meetings are reported on and viewpoints presented as necessary during board and managing directors’ meetings.
Human rights-related issues are discussed and addressed by the Human Rights Due Diligence Task Force.
Disclosure
The TOMY Group reports regularly on the sustainability website and in annual reports and other media regarding our initiatives for respecting human rights.
Training and education of officers and employees
In addition, we provide information and education on this policy throughout the Group, including through study groups for officers, training for all Group officers and employees, and briefings for business partners.
Addressing salient human rights issues
The TOMY Group has assessed potential human rights risks related to our business and value chain, and we have identified our salient human rights issues to be addressed according to the likelihood of occurrence of such risks and the severity of their impact on human rights.
Addressing salient human rights issues
| TOMY’s key human rights areas |
Potential human rights violation risks |
Main affected stakeholders |
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Supply chain Local community |
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Workplace and working environment |
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Expressions in advertising, promotions, etc. |
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Safety and quality of products and services |
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Engagement with stakeholders
The TOMY Group places importance on engagement (constructive dialog) with stakeholders, and strives to ensure transparency and to respond in a responsible manner.
We will continue to promote human rights due diligence initiatives while engaging in dialog with stakeholders, including external experts.
Remedies and grievance procedures
The TOMY Group has established the whistleblower hotline for reporting concerns about business activities. If a report is received, the content is reported to the Risk/Compliance Committee secretariat, which investigates, considers remedies, requests relevant departments to take corrective actions, and conducts monitoring. We protect the privacy of whistleblowers, and condemn any action taken following a hotline report that could prove detrimental to the whistleblower.
We do not accept or tolerate any incidents or problems related to human rights violations in our business or supply chain, and take allegations seriously and implement remedial and corrective measures to respond appropriately.
Review of policy
The TOMY Group will continue to regularly review and improve our Human Rights Policy to strengthen our human rights initiatives.
TOMY Company, Ltd.
Kazuhiro Kojima Representative Director, Chairman & CEO
Akio Tomiyama Representative Director, President & COO
How the Policy was Established
Recognizing that our Group business has an impact on human rights, we identified and evaluated significant potential human rights risks, then established the TOMY Group Human Rights Policy based on our Founding Philosophy and Corporate Mission.
Step1 Determine the issues
We assessed risks for each activity in the value chain process.
Assessing risks from multiple perspectives
- Analysis of external environments
- Study groups and workshops for officers
- Consultation with relevant departments
Step2 Identify significant potential
human rights risks
To identify potential human rights risks, we performed a preliminary evaluation to set priority based on 1) the chance an impact will occur, and 2) the severity of the potential impact. We then consulted with relevant departments and external experts to adjust these priority levels.
Step3 Establish the Human Rights Policy
The policy was then decided upon by the Board of Directors.
Addressing Identified Human Rights
Risks
Below are the significant potential human rights risks identified by the TOMY Group. As external and internal conditions change in the future, we will periodically analyze and review these risks and conduct due diligence accordingly.
| TOMY’s key human rights areas |
Potential human rights violation risks |
Main affected stakeholders |
Countermeasures | Methods to continuously evaluate risk |
|---|---|---|---|---|
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Supply chain Local community |
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Workplace and working environment |
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Expressions in advertising, promotions, etc. |
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Safety and quality of products and services |
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We are confirming that there is no child labor or forced labor in the TOMY Group supply chain. We are also conscious of diversity in aspects such as race, religion, gender, sexual orientation, age, nationality and ability or disability.
In addition to addressing potential human rights risks, we also remain committed to having a positive impact on human rights through our business activities by promoting initiatives such as universal design (accessible-design toys), human resource training and development programs, and support for next-generation education.
Key Initiatives
Protecting Human Rights
The TOMY Group has set up the whistleblower hotline as a mechanism for protecting the human rights of our employees.
The hotline is designed to be used by all directors and employees, including seconded staff, contract or fixed-term employees, part-time or casual staff and temporary workers. We offer three reporting avenues: 1) a web-based contact point, 2) the contact person at the TOMY Group, and 3) an external contact point, such as a lawyer. The contact point that receives a whistleblowing report conveys the details to the Risk/Compliance Committee secretariat. The secretariat then determines its response within 20 days of receipt of the report, including whether and, if so, how it intends to investigate the matter, and then communicates those decisions to the original reporting contact. We protect the privacy of all whistleblowers, and condemn any action taken following a hotline report that could prove detrimental to the whistleblower.
To advertise the hotline, we display multiple compliance posters in Group offices and plants and distribute small cards with hotline details to the Group directors and employees.
We also provide feedback on the whistleblower system operation to all employees on our annual Think about Compliance Day and remind them of the different hotline contact points.
Human Rights-related Training
The TOMY Group strives to prevent harassment in the workplace by including sessions on both sexual and power harassment as part of the management and employee mental health training program in Japan, and conducting relevant e-learning sessions for all employees and directors to enhance their awareness of diversity. Our e-learning training sessions on the TOMY Group Code of Business Conduct (COBC) also include elements on human rights. All employees take this course each year and pledge to uphold the Code. Furthermore, our annual Think about Compliance Day not only focuses on compliance with laws and regulations, but also shares details of our human rights initiatives with all employees.
Response to UK Modern Slavery Act
TOMY UK, a subsidiary of the TOMY Group, released a statement in 2016 in relation to the UK Modern Slavery Act 2015. This statement is designed to prevent slave labor or human trafficking within the company and across its supply chain. TOMY UK has established its own policy and due diligence process, pursuing initiatives to prevent modern slavery.
Below is the link to the statement, which was updated in June 2019.
Reference initiative
The TOMY Group indicated its participation for the United Nations Global Compact, the international framework for the global community to achieve sustainable growth. The Group will promote initiatives to achieve the 10 principles of the Global Compact that cover the areas of human rights, labour, the environment and anti-corruption.
The 10 Principles of United Nations Global Compact
| Human Rights | Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and Principle 2: make sure that they are not complicit in human rights abuses. |
| Labour | Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining; Principle 4: the elimination of all forms of forced and compulsory labour; Principle 5: the effective abolition of child labour; and Principle 6: the elimination of discrimination in respect of employment and occupation. |
| Environment | Principle 7: Businesses should support a precautionary approach to environmental challenges; Principle 8: undertake initiatives to promote greater environmental responsibility; and Principle 9: encourage the development and diffusion of environmentally friendly technologies. |
| Anti-Corruption | Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery. |
