In 2000, Mattel formally adopted a
vision and values statement that acts as a moral compass for the way we work
within the walls of Mattel and interact with our co-workers, our partners,
our customers and our communities. As an organization and individually,
Mattel employees are responsible for acting with integrity, treating others
with dignity and respect, being honest and fair in all transactions and
consistently striving to "do the right thing."
While the focus on integrity is
not new to Mattel, the Code of Conduct, which formally rolled out to
employees in January 2003, provides a common point of reference for Mattel
• The Code of Conduct Is Our General Statement of Ethical
• To Whom Does the Code Apply
• Those With Leadership Roles Have Additional Responsibilities
• Where Should We Turn For Guidance?
• What Are The Consequences For Failing To Act Ethically?
Interest Situations Commonly Faced by Employees
• Family Members and Close Personal Relationships
• Business Gifts and Entertainment
• Outside Activities
• Seek Guidance and Assistance
How to Get Help and Raise Concerns
• Raising Concerns or Complaints about Accounting or Auditing Matters
- The Code of
Conduct is Our General Statement of Ethical Business Conduct
Code of Conduct is a general statement of our standards of ethical business
conduct, based on our commitment to adhere to Mattel's values and to comply
with the law.
Mattel, our values are:
Play with Passion
Make a positive impact on the lives of children and families around the
with unparalleled creativity and innovation
Love what you do
and have the courage to make a difference
Play as a team to realize our full potential
Form deep partnerships with the people and companies with whom we work
Enrich the communities in which we work and play
Treat each other with respect and dignity
Trust each other to make the right decisions
Be accountable for all that passes in front of us
Act with unwavering integrity on all occasions
Play to Grow
Seek continuous improvement and deliver quality results in every part of our
Provide opportunities and support for personal and professional growth
Reward excellence and achieve financial goals so that we can continue to
The Values Statement includes a
commitment to act with unwavering integrity on all occasions. This includes
an obligation to obey the law of the countries and communities in which we do
business. As a global company conducting business around the world, Mattel’s
operations are subject to the laws of many governments. We must comply with
all applicable laws, rules and regulations wherever Mattel does business.
While the Code of Conduct outlines
our broad responsibilities, we also have more specific guidelines and company
policies for various activities. All company policies and the underlying
procedures established for business operations must be consistent with the
standards of ethical behavior outlined in the Code of Conduct. All employees are
required and expected to comply with the Code of Conduct, and with the laws
and company policies that govern our activities.
- To Whom Does
the Code Apply
Unless stated otherwise, the Code of Conduct applies to all Mattel
employees and to any person performing work or providing services on
Mattel’s behalf, including field representatives, temporary and seasonal
employees, and legal agents, in each case in their capacity as such.
Certain provisions of the Code of Conduct also apply to members of
Mattel’s Board of Directors (“Directors”), as indicated where
- Those With
Leadership Roles Have Additional Responsibilities
Leaders should foster an environment of ethical behavior by:
- acting as role models,
demonstrating ethical behavior in the performance of their own duties,
- making sure that employees
understand that business results are never more important than
compliance with the standards for ethical behavior,
- ensuring that employees are
familiar with the standards for ethical behavior as outlined in the
Code of Conduct, and the company policies that are relevant to the
performance of their duties,
- encouraging open
communication regarding business practices and ethical issues,
- acting to address incidents
of unethical behavior, including training, counseling and disciplinary
action where appropriate, and
- recognizing and rewarding
- Where Should We
Turn For Guidance or to Raise Concerns
When questions arise regarding the Code of Conduct, company policy or
conduct that may violate these standards, we should first consult our
supervisors, the Human Resources Department or the Law Department.
As an alternative, employees can call the Mattel EthicsLine to raise
concerns or report violations of the Code of Conduct or Company
Policies. The EthicsLine is a toll-free number available to employees 24
hours a day, 7 days a week.
Employees who call the EthicsLine can choose to remain anonymous, but
are encouraged to identify themselves and to provide as much information
as possible in order to facilitate an efficient and effective
investigation of the reported issue. All questions and concerns will be
handled fairly and discreetly.
See the “How to Get Help and Raise Concerns” section for information
about procedures for raising concerns about accounting and auditing
- What Are The
Consequences For Failing To Act Ethically?
Failures to act ethically and violations of the Code of Conduct and
company policies can impact Mattel’s business and reputation, and can
have serious consequences for all Mattel stakeholders, including
employees, shareholders, consumers, business partners and our
Whenever Mattel becomes aware of a violation of the Code of Conduct,
company policy or the law, we will act to correct the problem and
prevent future occurrences. Depending on the circumstances, the
corrective and preventive steps might include training, counseling and
disciplinary actions up to and including termination of employment and
civil or criminal prosecution. If you are in a situation which you
believe may violate or lead to a violation of the Code of Conduct,
company policy or law, follow the guidelines described in
“How to Get Help.”
Conflicts of Interest
Employees and Directors must act
in the best interests of Mattel, without consideration for our personal
interests or the potential for personal benefit. A conflict of interest
arises any time our personal interests (including relationships, investments
or activities) might affect our judgment as to what is in the best interest
of Mattel, or make it difficult to perform our work for Mattel objectively
and effectively. It is very important to consider the appearance of conflicts
of interest, since perceived conflicts can be as damaging to Mattel's
reputation as actual conflicts.
We need to be diligent in
recognizing actual and potential conflicts of interest, and those of us with
responsibility for purchasing goods and services and for awarding contracts,
must be especially aware of the potential for a conflict of interest.
of Interest Situations Commonly Faced by Employees
It is not possible to anticipate
all situations which could present a conflict of interest, and only
some of the more common are listed here. Mattel may also at any time require
reporting by employees of activities that could present conflicts of
- Family Members
and Close Personal Relationships
Jobs and work assignments will be awarded on the basis of
qualifications, skills and achievement, and not family or personal
Work assignments involving employees who are related, or who have close
personal relationships, may lead to actual or perceived favoritism, lack
of objectivity and poor employee morale among co-workers. Family members
of employees (anyone related by blood, marriage or adoption), and
individuals with whom an employee has a close personal relationship
(partners of either sex, anyone who resides with an employee and
individuals with whom an employee has a close friendship or a dating
relationship) will not be eligible for employment in positions that could
present a conflict of interest, such as a direct reporting relationship.
Human Resources should be advised when a family or personal relationship
between employees could present an actual or perceived conflict.
- Business Gifts
In some circumstances business gifts and entertainment can be used to
strengthen business relationships. However, no
gift, favor or entertainment should be accepted or provided if it will
obligate or appear to obligate the recipient.
Requesting or soliciting personal gifts, favors, entertainment or
services is unacceptable. In addition, we should not exploit our
position at Mattel to solicit vendors to provide individual preferential
treatment in pricing, terms or loans.
When considering whether to accept or offer a gift or other business
courtesy, we should use prudent judgment and moderation.
We should not accept gifts from any person or organization with whom
Mattel does business or is in competition, with the exceptions of gifts
that do not exceed (or that the recipient reasonably believes do not
exceed) $100 in value from a single source during any year. Gifts in
excess of this value should be returned to the sender with a letter of
explanation. However, if it would be impractical or discourteous to
refuse a gift, the gift should be donated to charity through Mattel
Accepting a gift of cash or cash equivalents (such as checks, savings
bonds, stock or other corporate securities) of any value is strictly
prohibited. Certain gift certificates and gift cards that allow the
recipient to choose from a wide range of goods and services may be
considered cash equivalents. For this reason, employees should consult
their HR representatives before accepting a gift certificate or gift
We should not offer a gift unless it is a gift that is given as a common
courtesy or gesture, is customary business practice and is proper and
reasonable in the circumstances. A gift should not be offered if the
gift would violate known customer business practice. Special
restrictions apply to government officials in most countries, and we
should always consult the Law Department before offering any gifts to
any government officials (see the discussion on Anti-Corruption Laws).
We may accept or provide business entertainment and meals that are
reasonable in the context of the business and advance the Company's
interests, for example attending a local cultural event, a sporting
event or a business meal with a business associate (such as a customer
or a supplier). However, accepting tickets to an event if the business
associate will not also be present should not be considered business
entertainment, but should instead be considered a gift, subject to the
$100 limitation described above.
Mattel expects the complete commitment of its employees, and therefore
discourages outside employment. We must obtain the approval of the Human
Resources Department before accepting a second job, commencing a
business venture or personal project, or agreeing to act as an advisor,
consultant, officer or director under circumstances that may conflict
with our ability to fulfill our job duties or may raise a potential
conflict of interest.
We must be sure the skills we learn and use at Mattel are not used in a
way that could hurt Mattel’s business. Providing services in any
capacity to an organization that competes with Mattel in any manner
presents an actual conflict of interest, and is prohibited. Providing
services in any capacity to suppliers or customers of Mattel will be
closely scrutinized because of the high potential for a conflict of
Our personal investments should not influence, or appear to influence,
our business decisions. For example, if we are in a position to make
decisions on behalf of Mattel that could have a significant impact on
the business of a supplier or customer, we should avoid any investment
in the supplier or customer of such value that it might affect, or
appear to affect, our business decisions regarding the supplier or
customer. We should also avoid any investment in a competitor which
might affect, or appear to affect, our business decisions.
Serving Non-Profit or Community Organizations
Mattel supports non-profit or community organizations through
Philanthropy Programs, including the Mattel Children’s Foundation and
Signature Partnerships, with financial contributions, toy donations,
organized volunteer activities, brand engagement, or the use of Mattel
Mattel encourages employees to participate in Mattel’s Philanthropy
Programs, and to support charitable organizations and our communities
generally, by taking an active role in volunteer activities. However, we
should not allow our volunteer activities to interfere with the conduct
of Mattel’s business.
Use of Mattel Authority for non-Mattel Purposes
When engaged in activities that are not related to Mattel’s business or
to our volunteer activities in support of Mattel’s Philanthropy
Programs, we should not use our position in Mattel in a manner that
would lead outsiders to believe that we are acting on Mattel’s behalf,
or that Mattel is actively involved in or sponsors these activities.
- Seek Guidance
We should discuss any questions about Conflicts of Interest with our
supervisors and Human Resources representative, and consult the Law
Department if necessary. Specific guidelines on these and other common
situations, as well as reporting requirements, are provided in the Conflict of Interest Policy.
Employees and Directors should not compete with Mattel, or pursue for
personal benefit opportunities (for example, relating to products, inventions
or investments) that are discovered through the use of corporate property,
information or position. We should not use corporate property, information or
position for personal gain. Employees and Directors should seek to advance
the legitimate interests of Mattel when the opportunity to do so arises.
Responsibility to Each Other
We will treat others as we want to be treated - with respect, dignity
We have the right to work in an environment free from discrimination and
harassment based on race, color, religion, sex (including pregnancy,
childbirth or related medical conditions), sexual orientation, gender
identity, national origin, ancestry, social origin, age, disability,
marital status, veteran status or other protected characteristics. We
should respect our co-workers' rights, and remember that such
discrimination and harassment will not be tolerated.
We should speak out when the conduct of a coworker makes us or others
uncomfortable. We each have a responsibility to report to Human
Resources any such harassment or discrimination that we experience or
Mattel recognizes diversity as an asset, and is committed to actively
seeking and promoting diversity in the workforce.
We value the different perspectives, insights and experiences of diverse
individuals and cultures, and we aspire to create a company culture that
encourages an expression of, and a respect for, diverse viewpoints. We
provide equal employment opportunity for all applicants and employees,
without regard to factors such as race, color, religion,sex (including
pregnancy, childbirth or related medical conditions), sexual
orientation, gender identity, national origin, ancestry, social origin,
age, disability, marital status, veteran status or other protected
characteristics. We make employment decisions to meet our business needs
based on factors such as qualifications, skills and achievement. We
comply with local and national employment laws.
- Employee Health
Mattel is committed to providing a safe, healthful and environmentally
responsible workplace, and has established safety programs to provide
information and training for safe practices in the normal conduct of
business and for emergencies.
We are responsible for observing safety and health rules, for taking
appropriate precautionary measures and for reporting unsafe or hazardous
conditions to our supervisors, to Mattel’s Global Sustainability
Department, Global Security Department or local Mattel security
In order to maintain our high standards for quality, productivity and
safety, we should be in suitable mental and physical condition at work.
Possessing, buying or selling, using or being under the influence of
illegal drugs or engaging in any other activities which create an unsafe
work environment while on duty, or when on Mattel premises, are
expressly prohibited. The consumption of alcohol while on duty or when
on Mattel premises is prohibited except during approved Mattel social
functions, or during business meals.
Responsibility to Consumers
- Product Quality
Mattel's reputation for product quality and safety is among its most
valuable assets, Our commitment to product quality and safety is an
integral part of our design, manufacturing, testing and distribution
processes, and is essential to the success of our business. Children's
health, safety and well-being are our primary concern. We will meet or
exceed legal requirements and industry standards for product quality and
safety. We strive every day to earn our consumers’ trust through our
dedication to safety, and to exceed the expectations of parents.
Employees have an obligation to immediately report any concerns about
product safety or quality to Mattel’s Worldwide Product Integrity
We respect the confidentiality of consumer information consistent with
all applicable privacy and data protection laws and regulations. We do
not share, sell or trade any private or sensitive personal information
obtained online from children without the prior consent of the parent or
unless compelled by legal process.
- Advertising and
Mattel's brand and product promotion activities, including advertising,
packaging, point of purchase displays, promotional programs and
sweepstakes, should be conducted in a manner consistent with applicable
laws and with our reputation for honesty and integrity. We adhere to
high standards of commercial fairness in ads and promotions. We must
accurately portray the features, quality and performance of our products
in all advertising media and packaging in a manner appropriate for our
target audience. We do not misstate facts or provide misleading or
deceptive information about Mattel's products, or the products of a
We should be diligent in safeguarding the reputation of Mattel brands
and products by being selective about promotional opportunities, such as
event sponsorship and other joint promotions, avoiding association of
Mattel's name with any product, service or activity which might be
considered unsafe or inappropriate for children, or with any person or
organization if the relationship might be damaging to Mattel's
Responsibility to Shareholders
All employees and Directors share in the responsibility to protect
Mattel's assets, including physical assets, financial assets,
intellectual property and proprietary information from theft, loss,
damage, misuse or waste.
Those of us who have custody of company property, such as vehicles and
laptop computers, should take appropriate measures to ensure their
proper security and use.
Company assets should not be used for illegal purposes, or for personal
benefit. (except as may be allowed in company-approved compensation
arrangements). Incidental personal use of company assets, such as
telephones, personal computers and photocopying machines, is permitted
as long as such use does not interfere with the employee's duties, is
not done for monetary gain, does not conflict with Mattel's business and
does not violate any Mattel policy or applicable law.
The security of computer systems and electronic data should be protected
by allowing access only by authorized persons, and by properly using
Commitments and Expenditures
Mattel has established policies that grant authority and establish
review and approval requirements for commitments and expenditures. These
guidelines apply to all financial expenditures (including capital
expenditures), and to all agreements that commit Mattel's resources and
define its business activities. Licensing agreements, joint venture or
other strategic agreements, and contracts for the engagement of
services, investments, acquisitions, or the lease or sale of corporate
assets are examples of commitments subject to these guidelines. Only
officers of Mattel (generally those having a title at or above the Vice
President level) are authorized to enter into agreements on behalf of
Mattel, and this authority is to be exercised only in compliance with
the guidelines. We are each responsible for being familiar with these
guidelines, understanding the scope of our authority,and ensuring that
we do not make commitments (including oral commitments) that exceed our
Intellectual Property and Confidential Information
Mattel's intellectual property, including trademarks, tradedress, trade
names, copyrights, patents,internet domain names and similar rights or
interests are among its most important assets. Improper use of
intellectual property in advertising, packaging, correspondence and
contracts can erode Mattel's rights. Questions regarding the proper use
of Mattel's intellectual property should be referred to the Law
Confidential information is any information not generally known to the
public that is useful to Mattel, that would be useful to its competitors
or other third parties or that would be harmful to Mattel or its
customers if disclosed. Confidential information includes revenue and
profit information and projections, information regarding potential
acquisitions, divestitures and investments, new product information,
marketing plans, design and development efforts, manufacturing
processes, and other trade secrets.
Employees and Directors should not discuss confidential information with
those who are not obligated to maintain the information in confidence or
in public places where the information is not likely to be kept secret,
such as planes, restaurants and elevators.
In view of the competitive nature of Mattel’s business and the
significant impact of the theft or unauthorized use of Mattel's
intellectual property on Mattel’s business and consumers, the protection
of Mattel’s intellectual property is one of the most important
responsibilities of employment with Mattel. This obligation continues
even after employment ends.
Mattel recognizes and respects rights in intellectual property and
confidential information owned by third parties. Mattel’s employees
should protect the confidential information of third parties from theft,
misuse or unauthorized disclosure with the same degree of care used to
protect Mattel’s confidential information.
Information and Securities Trading
Employees and Directors who have access to confidential information are
not permitted to use or share that information for purposes of trading
securities of Mattel or any other company, or for any other purpose
except the conduct of our business. All non-public information about
Mattel and non-public information about Mattel's business partners
obtained in the course of employment at Mattel should be considered
confidential information. To use such information for personal financial
benefit or to "tip" others who might make an investment
decision on the basis of this information is not only unethical, but
Employees and Directors should be familiar with and follow Mattel's
Insider Trading Policy, and should contact the Law Department with any
To ensure compliance with the securities laws, it is Mattel's policy
that only certain designated officers and Directors designated from time
to time are authorized to communicate with investors and securities
market professionals, including brokers, analysts and other market
professionals on any subject relating to Mattel business. No other
employees or Directors are to engage in any such communications and we
should refer all requests for information to the Investor Relations
- Accuracy of
Company Records, Public Reports and Communications
Mattel is committed to provide full, fair, complete, accurate, timely
and understandable disclosure of information, including financial
information, in reports filed with the Securities and Exchange
Commission and other public communications, in accordance with
applicable laws, rules and regulations.
Financial books, records and accounts must be maintained in reasonable
detail, accurately reflect transactions and events and conform to
applicable legal and accounting requirements and to Mattel's system of
internal controls. In order to fulfill our responsibility for sound
decision-making, we require honest and accurate recording and reporting
of business information and transactions, including quality, safety and
personnel data records, as well as financial transactions and records.
Falsification of any record or financial report, such as quality and
safety data, time reports or expense reports, will result in immediate
See the "How to Get Help and Raise Concerns" section for
information about procedures for raising concerns about accounting and
- Recording and
Retaining Business Communications
Communications (even those we may consider "private" or
"personal") may become public, so all correspondence should be
clear and accurate. We should avoid exaggeration, inappropriately colorful
language, derogatory characterizations and, except for members of the
Law Department, legal conclusions. These guidelines apply to
communications of all kinds, including e-mail.
We should follow Mattel's records retention policies and procedures, and
in accordance with those policies we should contact the Law Department
in the event of litigation or government investigation.
Responsibility to Business Partners
- Doing Business
We are committed to expanding and improving Mattel's business through
business alliances, including customers, suppliers, vendors,
subcontractors, licensees, agents, joint ventures, etc. We will build
productive relationships with business partners based on integrity,
legal and ethical behavior and mutual trust. We seek to do business with
customers and suppliers who reflect the diversity of the worldwide
community in which we operate. Any person who acts, or who could be
perceived as acting on Mattel's behalf should be made aware of Mattel's
Code of Conduct.
Integrity, ethical behavior and mutual trust should be important
criteria when evaluating and selecting our business partners. We should
seek to do business with parties who enjoy a history of ethical
- Fair Dealing
Employees and Directors should endeavor to deal fairly with Mattel's
customers, suppliers, competitors and employees. We should never take
unfair advantage of anyone through manipulation, concealment, abuse of
privileged information, misrepresentation of material facts or any other
Manufacturing and Distribution Practices
Mattel's Global Manufacturing Principles (GMP) are the cornerstone of
our ongoing commitment to responsible manufacturing and distribution
practices around the world. These standards apply to all parties that
manufacture, assemble or distribute any product or package bearing the
Mattel's GMP includes some of the most detailed and comprehensive
standards in the consumer products industry. Detailed standards have
been developed for each of the principal countries in which Mattel
conducts its manufacturing and distribution operations. The standards
address a wide spectrum of issues relating to living and working
conditions. They serve as the criteria according to which Mattel's
internal and independent monitoring programs operate around the world.
Mattel works closely with its business partners to ensure compliance
with the GMP.
All suppliers should be treated in a fair, ethical and impartial manner.
All decisions regarding suppliers and vendors of goods and services should
be made on the basis of factors such as suitability, quality, price, and
Individuals involved in the review and selection of potential suppliers,
vendors and services providers must be diligent in avoiding actions that
convey or imply that decisions will be influenced by favors or
concessions, or by personal or family relationships.
Most countries and localities have special rules, restrictions and
procedures for dealing with government customers (including
government-owned enterprises). Requirements may include enhanced
disclosure requirements in contract negotiations, special billing or
shipping procedures or stringent restrictions on gifts, travel and
entertainment which can be offered to government employees. All statements
and representations to government procurement officials must be accurate
Responsibility to Fair Competition
Mattel does not seek to obtain competitive information by illegal or
unethical means, and we do not knowingly use any information obtained in
If we find ourselves in possession of information that may have been
obtained in an illegal or unethical manner, such as information provided
to us in breach of a confidentiality agreement, we should immediately
inform the Law Department and should turn the information over only to a
member of the Law Department staff, without showing it to or sharing it
with other Mattel employees.
Competition and Antitrust
Mattel competes aggressively and fairly in each market in which it
operates and is dedicated to compliance with the applicable antitrust
and competition laws in all its worldwide activities and locations.
Antitrust laws are designed to prohibit agreements among companies that
would fix prices, divide markets, allocate customers, limit production
or otherwise impede or destroy market forces. We must strictly comply
with the antitrust laws of all countries, states and localities in which
we conduct Mattel business.
Antitrust restrictions may apply to agreements with customers or
suppliers, such as:
- Agreements with customers
regarding retail prices, or
- Agreements with customers
that Mattel will refuse to sell to other customers or restrict the sale
of certain products to other customers.
addition, we should generally avoid exchanging or discussing with any
customer information about another customer's pricing policies, product
offerings, marketing strategies or any other similar competitive
information.We should always consult the Law Department before we agree to
perform any category management services for a customer that may expose us to
confidential information about competitors’ pricing, product offerings, marketing
strategies or any other similar competitive information.
Membership in trade associations, while helpful to Mattel's business, may
also inadvertently create opportunities for discussions that may be contrary
to the antitrust laws. If a prohibited subject comes up during the course of
a trade association or other meeting, we should leave the meeting and inform
the Law Department.
Responsibility to Communities
Mattel is committed to improving the communities in which it operates
through Philanthropy programs supported by Mattel and accomplished by
voluntary efforts of Mattel employees. As a company, Mattel works to
improve the lives of children in need through a variety of efforts,
including corporate financial and product contributions, organized
employee volunteer activities and through programs administered by the
Mattel Children's Foundation.
- Environment and
Mattel is committed to protecting the health and safety of its
employees, as well as minimizing our impact on the environment. Mattel
strives to be a responsible citizen in the communities in which we
operate. As part of this commitment, we follow environmental laws and
regulations applicable to our operations worldwide, and integrate
environmental, health and safety standards into our business operations
to reduce risks, minimize impacts and strive to provide a safe,
to the Media
In order to ensure that the information provided to the public is
accurate and consistent, all communications to the media should be
coordinated with Corporate Communications. We should not engage in
conversations with the media without prior authorization from Corporate
Communications, and if contacted by a member of the media should refer
inquiries to Corporate Communications.
Communications with investors and with the financial community are
similarly restricted, and are addressed in the "Responsibility to
Responsibility to Government and Compliance with the Laws
Employees and Directors must
comply with all applicable laws, rules and regulations wherever we do
When we have any questions or concerns about the legality of an action, we
should seek guidance from the Law Department. Each of us has a responsibility
to understand the legal and policy requirements that may apply to our jobs or
- Which law
Mattel is a corporation organized in the United States. The laws of the
United States frequently extend to the operations of Mattel and its
subsidiaries throughout the world, as well as to the business activities
of Mattel employees wherever we live and work. Mattel conducts business
around the world, and our employees are citizens of many countries. As a
result, our operations are subject to the laws of numerous countries,
provinces, states, municipalities and governmental organizations.
Mattel's policies reflect the reality that a global company may be
regulated by many different laws at the same time. In some instances,
there may be a conflict between the applicable laws of two or more
countries. When we encounter such a conflict, it is especially important
to consult the Law Department to understand how to resolve that conflict
The Code of Conduct has been written to promote compliance with the laws
and regulations that govern Mattel's business. However, if compliance
with the Code of Conduct would bring us into conflict with applicable
laws or regulations in any jurisdiction where Mattel conducts its
business, we must obey the laws and regulations and notify the Law
Department of any such conflict as soon as possible. If any local
business custom or practice conflicts with the Code of Conduct, we must
comply with the Code of Conduct and notify our supervisor of any such
conflict as soon as possible.
Mattel's funds and resources, including personnel, facilities and
inventory, should not be used directly or indirectly to make a political
contribution to any elected official, political candidate or party or
for campaigning, fundraising or any other political activity, without
required approval according to Mattel policy.
Political activities by corporations, including lobbying, are subject to
detailed restrictions under U.S. law and the laws of many countries in
which Mattel does business. In order to avoid any inadvertent violation
of the laws which control these activities, all political and lobbying
activities should be discussed and coordinated with the Government
Affairs Department and the Law Department.
Voluntary personal contributions to candidates, parties and civic
organizations are encouraged and are consistent with Mattel's commitment
to citizenship and community involvement. Our individual involvement
must be totally voluntary and must be on our own time and at our own
We must follow the laws of the U.S. and other countries on bribery and
improper payments to government officials.
Bribery of or the offer or payment of money to public officials is
absolutely prohibited. We should not offer directly or indirectly
anything of value to government authorities, including political parties
or candidates, to obtain an improper advantage, or to retain or obtain
business. No gifts, contributions , meals or entertainment are to be
offered which might create an appearance of impropriety. We should
immediately report to the Law Department any suspected violation of
Because Mattel's business partners (vendors, suppliers,licensors,
licensees, joint venture partners, etc.) may also be required to comply
with these laws, we should exercise due diligence in selecting our
business partners and should avoid relationships with parties with a
history of corrupt practices.
Because of the complexity of the laws, and the severity of the
consequences for violations of the anti-corruption laws, the Law
Department should be consulted in advance for advice on dealings with
government officials including any proposed meals, travel or
Mattel does not permit its employees or resources to be used in money
laundering activities. Mattel complies with all U.S. and international
laws against money laundering, which prohibit the acceptance or
processing of proceeds of criminal activities (e.g., drug trafficking,
We should follow basic "Know Your Customer" procedures, and
should comply with company policy regarding acceptable forms of payment.
The U.S. and other nations strictly regulate the import and export of
products, materials, services, information and technology. We must
comply with all applicable laws, regulations and restrictions on trade,
and we should contact the Law Department with any questions.
Mattel will not cooperate with any restrictive trade practices or
boycotts prohibited or penalized under U.S. or applicable local laws,
such as boycotts against countries friendly to the U.S. (such as Israel)
or blacklisted firms. Boycott-related requests must be reported immediately
to the Law Department.
to Get Help and Raise Concerns
When faced with an ethical
decision, you should ask yourself these questions:
What is the ethics issue?
Start by identifying the problem – what is it about the situation that makes
you feel uncomfortable?
Is it a violation of Mattel’s Code of Conduct,
Company Policy or the law?
If it is, don’t do it. If you’re not sure, you should talk to your
supervisor, your Human Resources representative, or the Law Department.
How will it affect Mattel’s stakeholders?
What is the impact on Mattel’s consumers, investors, fellow employees,
communities and other stakeholders?
How will this affect my reputation and the
reputation of Mattel?
Are your actions consistent with Mattel’s values? Are you playing fair? Would
you feel comfortable explaining the situation to your family or the news
media? How does your conscience feel? What would a trusted friend advise?
If you have questions about the Code of Conduct, you should speak up, bring
your concerns into the open and ask for help. Mattel offers many
resources to assist you in obtaining answers to your questions. The first
place to turn is to your supervisor. Other resources include the Human
Resources Department and the Law Department.
Taking action to correct problems
Taking action to correct problems is part of the Mattel culture. If you
observe conduct that you believe may be unethical, illegal or in violation of
the Code of Conduct or other company policies, you are encouraged to report
your concerns to your supervisor, the Human Resources Department, the Law Department,
the Internal Audit Department, the Global Security Department or the
confidential EthicsLine. All reported concerns will be handled promptly,
fairly and discreetly. Employees must cooperate fully with any investigation
that Mattel undertakes and must answer truthfully any questions that are
asked as part of the investigation.
Retaliation is not tolerated
Retaliation toward any employee who in good faith reports an integrity or
ethical concern or issue will not be tolerated. Any employee who believes
that he or she is being subjected to retaliation for reporting an issue in
good faith or assisting in good faith with a Mattel investigation should
report the matter immediately to the Human Resources Department, the Law
Department, the Internal Audit Department, the Global Security Department or
the confidential EthicsLine.
Because these guidelines are very general, it is possible that under unusual
circumstances, the Code of Conduct may not appear to provide complete guidance.
You should always seek the advice and agreement of management before taking
any action that would conflict with the Code of Conduct. In addition, any
waiver of any provision of the Code relating to any Executive Officer or
Director must be approved by the Board or a Board committee, and will be
promptly disclosed as required by applicable laws, regulations and stock
exchange listing standards.
Concerns or Complaints about Accounting or Auditing Matters
Any employee may submit a good faith concern or complaint regarding
accounting, internal accounting controls or auditing matters to Mattel,
without fear of retaliation of any kind, in any of the following ways
(these are general complaint procedures and may vary from country to
country due to local laws and regulations):
- Contact an Officer:
Employees with complaints regarding accounting, internal accounting
controls or auditing matters may report their complaints to the General
Counsel or Vice President – Audit, in writing, by phone or via e-mail.
Employee complaints submitted in writing or by telephone may be made on
a confidential and anonymous basis. Due to technical constraints, e-mail
submissions may not be made anonymously.
- Call the EthicsLine:
Mattel’s EthicsLine permits employees to report complaints
regarding accounting, internal accounting controls or auditing
matters and other matters confidentially and anonymously.