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.




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?
•  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

How to Get Help and Raise Concerns

• General
• Raising Concerns or Complaints about Accounting or Auditing Matters



  • The Code of Conduct is Our General Statement of Ethical Business Conduct

The 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.

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.

    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 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 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.

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 may also at any time require
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

    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 Philanthropy Programs.

    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 card.

    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.
  • 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 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 interest.


    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 facilities.

    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 and Assistance

    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.


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 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 observe.
  • Diversity

    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 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, to Mattel’s Global Sustainability Department, Global Security Department or local Mattel security personnel.

    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, 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 Department.
  • 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, understanding the scope of our authority,and ensuring that we do not make commitments (including oral commitments) that exceed our authority.

    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 Department.

    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.
  • 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 Investor Relations Department.
  • 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 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. 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 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. These standards apply to all parties that manufacture, assemble or distribute any product or package bearing the Mattel logo.

    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.
  • 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 Fair Competition

  • 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, 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.
  • 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.

    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.

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.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.



Our Responsibility to Communities

  • Community Service

    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 Sustainability

    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, 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 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 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.
  • 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 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 these requirements.

    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 entertainment.
  • 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, 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.

Additional guidance

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.

  • 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 (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.