Mattel - About Us - Corporate Governance



	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 employees worldwide.
	Introduction • The Code of Conduct Is Our General Statement of Ethical Business Conduct • To Whom Does the Code Apply • Those With Leadership Roles Have Additional Responsibilities • Where Should We Turn For Guidance or to Raise Concerns? • What Are The Consequences For Failing To Act Ethically? Conflicts of Interest Conflict of Interest Situations Commonly Faced by Employees • Family Members and Close Personal Relationships • Business Gifts and Entertainment • Outside Activities • Seek Guidance and Assistance Corporate Opportunities Our Responsibilities Our Responsibility To Each Other • Respect • Diversity • Employee Health and Safety Our Responsibility to Consumers • Product Quality and Safety • Consumer Information • Advertising and Promotions Our Responsibility To Shareholders • Protecting Mattel Assets • Insider Information and Securities Trading • Communications With Investors • Accuracy Of Company Records, Public Reports and Communications • Recording and Retaining Business Communiations Our Responsibility To Business Partners • Doing Business With Others • Fair Dealing • Responsible Manufacturing and Distribution Practices • Purchasing Practices • Government Customers Our Responsibility To Competitors • Gathering Competitive Information • Fair Competition and Antitrust Our Responsibility To Communities • Community Service • Environment • Communication To The Media Our Responsibility To Government and Compliance With The Laws • Which Law Applies? • Political Activity • Anti-Corruption Laws • Money Laundering • International Trade How to Get Help and Raise Concerns • General • Raising Concerns or Complaints about Accounting or Auditing Matters
	Introduction The Code of Conduct is a general statement of the standards of ethical business conduct, based on our commitment to adhere to Mattel's values and to comply with the law. At Mattel, our values are: Play with Passion Make a positive impact on the lives of children and families around the globe, with unparalleled creativity and innovation Love what you do and have the courage to make a difference Play Together 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 Play Fair 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 business Provide opportunities and support for personal and professional growth Reward excellence and achieve financial goals so that we can continue to play! 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 applicable. 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 ethical behavior. 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. An EthicsLine has been established for employees to raise concerns or report violations of the Code of Conduct or company policies. 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 matters. 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 communities. Whenever Mattel becomes aware of an unethical act or 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. Conflict 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 also has a company policy that requires periodic reporting by employees of activities that could present conflicts of interest. 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 relationships. 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 and Entertainment 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. Gifts 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. Accepting a gift of cash or cash equivalents (such as gift certificates, stock or other corporate securities) of any value is strictly prohibited. We should not offer gifts other than token gifts of nominal value, which are given as common courtesies and are standard business practice. Even gifts of nominal value 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 gifts to any government officials (see the discussion on Anti-Corruption Laws). Entertainment 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. Outside Activities Secondary Employment 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 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 interest. Investments 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 From time to time, Mattel makes an institutional decision to support particular non-profit or community organizations through means such as financial support, toy donations or use of Mattel facilities. The Corporate Communications Department is responsible for coordinating the identification of such "Approved Charitable Organizations." Mattel encourages employees to support these Approved Charitable Organizations, as well as other 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 We should generally not use our position in Mattel when engaged in activities that are not related to either Mattel's business or to our volunteer activities in support of Approved Charitable Organizations 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 and Assistance We should discuss any questions about Conflicts of Interest with our supervisors, or should consult the Human Resources Department or the Law Department. Specific guidelines on these and other common situations, as well as reporting requirements, are provided in the Conflict of Interest Policy.
	Corporate Opportunities 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. Our Reponsibilities Our Responsibility to Each Other Respect We will treat others as we want to be treated - with respect, dignity and fairness. We have the right to work in an environment free from intimidation and harassment based on race, color, religion, gender, sexual orientation, national origin, age, disability, marital status, veteran status or other protected characteristics. We should respect our co-workers' rights, and we must refrain from engaging in such harassment. 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 harassment or discrimination that we experience or observe. Diversity Mattel recognizes diversity as an asset, and is committed to actively seeking and promoting diversity in the workforce. We value the differences of diverse individuals and cultures. We provide equal employment opportunity for all applicants and employees, without regard to factors such as race, color, religion, gender, sexual orientation, national 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 and Safety 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 and to the Environmental, Health & Safety Department. 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.
	Our Responsibility to Consumers Product Quality and Safety Mattel's reputation for product quality and safety is among its most valuable assets, and our commitment to product quality and safety is essential. Children's health, safety and well-being are our primary concern. We could damage our consumers' trust if we sell products that do not meet our standards. Our commitment to product quality and safety is an integral part of the design, manufacturing, testing and distribution processes. We will meet or exceed legal requirements and industry standards for product quality and safety. We strive to meet or exceed the expectations of our customers and consumers. Any compromise to product safety or quality must be immediately reported to Worldwide Quality Assurance. Consumer Information 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 Promotions 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 competitor. 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 reputation.
	Our Responsibility to Shareholders Protecting Mattel Assets 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 passwords. 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, and for ensuring that we do not make commitments (including oral commitments) that exceed our authority. Intellectual Property Mattel's intellectual property, including trademarks, tradedress, trade names, copyrights, patents 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 Department. Proprietary Information Employees and Directors have an obligation to protect the confidentiality of Mattel's proprietary information. Proprietary 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. Proprietary information includes trade secrets, revenue and profit information and projections, new product information, marketing plans, design and development efforts, manufacturing processes and any information regarding potential acquisitions, divestitures and investments. We can protect the security of Mattel's proprietary information by limiting access to it. Confidential information should not be discussed with those who are not obligated to maintain the information in confidence and in public places where the information is not likely to be kept secret, such as planes, restaurants and elevators. The obligation to preserve confidential information continues even after employment ends. Insider 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 also illegal. Employees and Directors should be familiar with and follow Mattel's Insider Trading Policy, and should contact the Law Department with any questions. Communications With Investors 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 Vice President of 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 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 disciplinary action. See the "How to Get Help and Raise Concerns" section for information about procedures for raising concerns about accounting and auditing matters. 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.
	Our Responsibility to Business Partners Doing Business With Others 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. 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 behavior. 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 unfair-dealing practice. Responsible 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, and apply to all parties that manufacture, assemble or distribute any product or package bearing the Mattel logo. Mattel's GMP are 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. Purchasing Practices 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 delivery. 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. Government Customers 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 and truthful.
	Our Responsibility to Competitors Gathering Competitive Information Mattel does not seek to obtain competitive information by illegal or unethical means, and we do not knowingly use any information obtained in this manner. If we find ourselves in possession of information that may have been obtained in an illegal or unethical manner, 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. Fair 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. For example, we should comply with the laws which prohibit: Agreeing or reaching an understanding with customers regarding retail prices. Agreeing or reaching an understanding with customers that Mattel will refuse to sell to other customers or restrict the sale of certain products to other customers. In 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. 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. Should a prohibited subject come up during the course of a trade association or other meeting, we should leave the meeting and inform the Law Department.
	Our Responsibility to Communities Community Service Mattel is committed to improving the communities in which it operates through 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, and through programs administered by the Mattel Children's Foundation. Environment Mattel is committed to minimizing our adverse impact on the environment, as well as protecting the health and safety of employees and of the communities in which we operate. As part of this commitment, we will 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, incident-free workplace. Communication 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 the Vice President of Corporate Communications. Communications with investors and with the financial community are similarly restricted, and are addressed in the "Responsibility to Shareholders" section.
	Our Responsibility to Government and Compliance with the Laws Employees and Directors must comply with all applicable laws, rules and regulations wherever we do business. 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 role. Which law applies? 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 properly. The Code of Conduct has been written to promote compliance with the laws, rules and regulations that govern Mattel's business. However, should compliance with the Code of Conduct bring us into conflict with applicable law in any jurisdiction where Mattel conducts its business, we must obey the law and notify our supervisor of the conflict as soon as possible. If local custom or policy, rather than law, in any region where Mattel does business, 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. Political Activity 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 expense. Anti-Corruption Laws We must follow the laws of the U.S. and other countries on bribery and improper payments to government officials. Bribery of 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 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 these requirements. Because Mattel's business partners (vendors, suppliers, 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 for advice on dealings with government officials. Money Laundering 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, bribery, fraud). We should follow basic "Know Your Customer" procedures, and should comply with company policy regarding acceptable forms of payment. International Trade 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.
	How to Get Help and Raise Concerns General When faced with an ethical decision, look yourself in the mirror and ask these questions: Is it iIllegal, or a breach of the Code of Conduct or a company policy? If it is, don’t do it. What will others think? Would I feel comfortable explaining my decision to my supervisor, my mother, the news media or people affected by my decision? Is it right? How does my conscience feel? What would a trusted friend advise? If you have questions about the Code of Conduct, 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 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. Retaliation toward any employee who in good faith reports an integrity or ethical concern or issue will not be tolerated. 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 law or applicable regulations. Raising 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: 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.