In July 2001, Sony Corporation established the Compliance Division, 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 Division establishes compliance policies and structures for the Sony Group.
In July 2003, Sony established a regional compliance network comprised of offices in the Americas, Europe, Japan, East Asia*1 and Pan-Asia,*2 which are charged with 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.
To further reinforce global compliance efforts, a Compliance Leadership Team was formed in September 2009 as an additional component of the global compliance organization. The Compliance Leadership Team assists the Sony Corporation General Counsel and Compliance Division in identifying, developing and implementing key compliance strategies and compliance-related measures; encourages more active participation in Group-wide compliance activities from a larger group of key Sony personnel by involving not only the Regional Compliance Officers but also experienced legal/compliance personnel from Sony Group companies; and creates a global framework that by its very structure highlights the company's compliance priorities and commitment to best practices.