In July 2001, Sony Corporation established a compliance department responsible for exercising global direction and oversight of compliance activities across the Sony Group, to emphasize the importance of business ethics and compliance with applicable laws, regulations and internal policies. The organization (currently, the Legal & Compliance Department) establishes compliance policies and structures for the Sony Group.
To implement this mandate more effectively, in July 2003, Sony established a regional compliance network, comprised of regional compliance officers in the Americas, Europe, Japan, East Asia*1 and Pan-Asia*2, who 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 coordinating with one another, are working to establish and maintain a comprehensive global compliance structure.
The Compliance Audit & Monitoring function was established as part of the compliance network in April 2008 to support the company's global compliance initiatives and monitor and evaluate compliance program activities. To further reinforce global compliance efforts, a Compliance Leadership Team was formed in September 2009 as an additional component of the global compliance network. The Compliance Leadership Team assists 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.