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| Ethical business conduct and compliance with applicable laws and regulations are fundamental aspects of Sony's corporate culture. To this end, Sony has established a Compliance Office at its corporate headquarters and regional offices around the world, adopted and implemented the Sony Group Code of Conduct, and set up Compliance Hotline systems through its global compliance network—all in order to reinforce the company's worldwide commitment to integrity and help assure resources are available for employees to raise concerns or seek guidance about legal and ethical matters. |
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Strengthening the Compliance System
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In July 2001, Sony Corporation established the Compliance Office, charged with exercising overall control over compliance activities across the Sony Group, to emphasize the importance of business ethics and compliance with applicable laws, regulations and internal policies. The Compliance Office establishes compliance policies and structures for the Sony Group and performs crisis management functions.
In July 2003, Sony established a regional compliance network comprised of offices in the Americas, Europe, Japan*1, East Asia*2 and Pan-Asia*3, which are charged with assisting the Compliance Office at Sony Corporation and exercising regional control over compliance activities to strengthen the compliance system throughout the Sony Group. Officers responsible for compliance in each region have the authority to issue instructions concerning compliance to Sony Group companies in their respective regions and, by cooperating with one another, are working to establish and maintain a comprehensive global compliance structure. |
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*1 Coverage area of Japan compliance office: Japan, South Korea and Taiwan
*2 Coverage area of East Asia compliance office: Mainland China and Hong Kong
*3 Coverage area of Pan-Asia compliance office: Southeast Asia, Middle East, Africa and Oceania |
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| Sony Compliance Network |
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Sony Group Code of Conduct
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In May 2003, Sony adopted the Sony Group Code of Conduct, which sets the basic internal standards to be observed by all directors, officers and employees of the Sony Group in order to emphasize and further strengthen corporate governance, business ethics and compliance systems throughout the entire Sony Group.
This Code of Conduct sets out, in addition to legal and compliance standards, the Sony Group's basic policies concerning ethical business practices and activities, on such topics as respect for human rights, safety of products and services, environmental conservation and information disclosure.
It has been adopted and implemented by each Sony Group company globally as its own internal code of conduct. To date, the document has been translated into 26 languages.
The Sony Group Code of Conduct reflects principles set out in the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, the United Nations Global Compact and the United Nations Universal Declaration of Human Rights.
Sony also participated in the formulation of and observes the standards outlined in the Charter of Corporate Behavior of the Nippon Keidanren (Japan Business Federation), an alliance of Japanfs leading corporations.
Since the implementation of the Sony Group Code of Conduct, Sony has centralized development and management of key internal rules to facilitate consistent group-wide compliance with provisions of the Sony Group Code of Conduct. |
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Internal Hotline System
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With the adoption of the Sony Group Code of Conduct, Sony also established the Sony Group Compliance Hotline as a resource for employees to report concerns or seek guidance about possible violations of laws or internal policies, and to allow the Sony Group to respond swiftly to potential risks of such possible violations. The Sony Group Compliance Hotline is available in the Americas, Europe, Japan, East Asia and Pan-Asia, and is ready to receive the concerns of any Sony Group employee in any part of the world through telephone calls, e-mail or letters.
The Sony Group Compliance Hotline is directly linked to the Corporate Executive Officer in Charge of Compliance and is operated independently from the ordinary line of command. In addition to periodic reports to senior management and the Audit Committee summarizing the hotline operation, important hotline calls also are reported individually to the Audit Committee as appropriate. Calls received are handled in line with established procedures, and callers who report issues in good faith will be protected from any possibility of recrimination. |
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| Sony Group Compliance Hotline |
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Educating Employees about the Sony Group Code of Conduct and the Internal Hotline System
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To ensure that all Sony Group employees are aware of the Sony Group Code of Conduct and the internal hotline system, Sony Group companies inform their employees about the Code and hotline through the ongoing dissemination of e-mails, booklets, wallet cards, posters, posting on the company's intranet and/or feature articles in internal newsletters.
Education and training sessions that use e-learning, case studies and other approaches presenting real-life examples also provide instruction both on business ethics generally and on individual aspects of the Sony Group Code of Conduct that are crucial to either some or all of the Group. Examples would be education programs regarding fairness in competition and business dealings, and training to avoid discrimination and harassment in the workplace.
Through ongoing awareness and training efforts, Sony will continue striving to promote a thorough understanding group-wide of the importance of the policies and values set out in the Sony Group Code of Conduct. |
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| Booklets, wallet cards, posters and training DVDs used to raise awareness of the Sony Group Code of Conduct and the internal hotline system |
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Risk and Crisis Management Systems
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Each Sony Group business unit, subsidiary or affiliated company, and corporate division is tasked with reviewing and assessing business risks on a regular basis and establishing and maintaining necessary systems for, among others, detecting, communicating, evaluating and responding to risk in its particular business area.
In addition, Sony Corporation's corporate executive officers have the authority and the responsibility to establish and maintain a system for identifying and controlling risks with the potential to cause losses or reputational damage to the Sony Group in the areas for which they are responsible.
The Corporate Executive Officer in Charge of Compliance has created and oversees the maintenance of a risk management system through the coordinated activities of the compliance, internal audit, group risk, and other relevant groups.
In the area of crisis management, in 2001 Sony established a group crisis management system and formulated procedures to enable a swift and organized group-wide response to crises. Under this system, crises are classified on three levels to ensure dynamic responses. Level 1 is defined as a crisis with the possibility of significant impact on the Sony Group, and will be handled under the direction of the CEO. Level 2 is defined as a crisis with the possibility of widespread impact within the Sony Group, and will be addressed by a cross-functional committee composed of a specialist management team. A Level 3 crisis has little impact outside the business unit involved and will be handled by the affected business unit or Sony Group company. |
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Information Security and Personal Information Management
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Sony has established the "Sony Global Information Security Policy" and its subordinate rules, the "Sony Global Information Security Standard," which sets forth our commitment to information security and states policies to be followed by all Sony personnel. Sony has established an organization charged with developing, maintaining and implementing this policy. The organization coordinates with individuals responsible for information security at Sony Group companies globally to create an effective group-wide information security management system.
Sony formulated the "Global Basic Principles on Personal Information" in July 2000, and is reinforcing internal rules and business processes to ensure the appropriate handling of the personal information of its customers and business partners. To encourage broad understanding of its principles on personal information management, in April 2005 Sony also introduced the Sony Group Privacy Policy*4 at all Sony Group companies in Japan.
Recognizing that employee awareness is key, Sony Corporation requires training programs for its employees to increase their understanding of the issues and improve the overall level of information security and personal information management. These training activities are implemented at each of the Sony Group companies.
Sony is making strenuous efforts to reinforce information security and safeguard personal information. In March 2007, however, an incident related to personal information occurred at a Sony Group company in Japan in which certain employees and other individuals illegally obtained personal credit information and sold it to an outside party. The Sony Group company apologized and explained the circumstances to the people affected and publicly disclosed the incident. To prevent recurrence of such an incident, the company subsequently took steps to further strengthen its personal information management processes, including implementing additional restrictions on access to such information, reinforcing log-in access procedures, and stepping up regular checks and other monitoring measures.
Sony recognizes the serious nature of such incidents and is also working to more broadly strengthen and expand procedures for managing personal information across Sony Group companies, including procedures to be followed by employees and subcontractors, to prevent similar incidents from occurring in the future. |
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| *4 This policy applies to Sony Corporation and its subsidiaries in Japan. |
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Fair Business Practices, Transparency and Equal Opportunity in Procurement
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Sony is committed to fair business practices, transparency and equal opportunity in its procurement operations, where purchasing is conducted according to established policies and procedures.
To protect the integrity of the process, Sony procurement agents in the electronics business are not permitted to form personal ties or relationships based on potential personal gain with any supplier. Among other things, this rule also prohibits the acceptance of personal gifts from or participation in a supplier's business while employed at Sony.
To raise awareness, Sony has distributed a handbook, entitled "Working Principles for Procurement Personnel," to employees in the procurement sections of Sony's Japanese electronics businesses. To reinforce observance of procurement ethics on a global basis, Sony has translated this handbook into English, Chinese, Spanish and Thai and distributed it to procurement agents at its sites, including those in North America, Europe, East Asia and Southeast Asia. Other Sony Group companies globally also are implementing new procedures to ensure that there are no improper conflicts of interest in their business dealings on behalf of Sony. |
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| English, Chinese and Thai versions of gWorking Principles for Procurement Personnelh |
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