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Updated on August 21, 2015

Sony Group Ethics and Compliance System

The company's Global Compliance Network, which is responsible for active development and implementation of our compliance program, is comprised of a compliance department at the corporate headquarters, regional compliance networks, a global compliance leadership team and a compliance monitoring team. The compliance department at our corporate headquarters (currently, the Legal & Compliance Department) establishes compliance policies and structures for all Sony Group companies. There is also a regional compliance office in each of the following regions: Americas, Europe, Japan, East Asia*1 and Pan-Asia*2. Regional Compliance Officers ("RCOs") and legal/compliance personnel from Sony Group companies in each of these regions are charged with implementation of Sony's global compliance programs as well as any additional risks relative to the operations of the specific regional business unit and/or local culture. RCOs have the authority to issue instructions concerning compliance activities in their respective regions and, by coordinating with one another, they maintain a comprehensive global compliance structure. The Compliance Leadership team assists the Legal & Compliance Department by identifying, developing and implementing best-practice compliance strategies and compliance-related measures, and the Compliance Monitoring team monitors and evaluates compliance program activities on an on-going basis. The Sony Corporation Audit Committee receives monthly reports of compliance program and Hotline activities, as well as periodic in-person updates.

Coverage area of East Asia compliance office: Mainland China, Hong Kong, Taiwan and South Korea
Coverage area of Pan-Asia compliance office: Southeast Asia, Middle East, Africa and Oceania

The Americas Office is responsible for Sony Corporation of America, the Sony Pictures Entertainment Group, and the Sony Music Entertainment Group, as well as Electronics Group companies in the America's Region. The Europe, East Asia and Pan-Asia Offices are responsible for the Electronics Group companies in their respective regions. The Japan Office is responsible for Sony Corporation, the Sony Computer Entertainment Group, and Sony Financial Holdings Group, in addition to the Electronics Group Companies in Japan.

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