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Updated on May 31, 2016

Responsible Sourcing of Raw Materials

Our stakeholders care about sustainability issues, including biodiversity, ethics and respect for human rights related to the sourcing of raw materials. Sony is working with its suppliers to address issues related to human rights, labor conditions, health and safety, and environmental protection at the production sites, as well as in its procurement of minerals and other raw materials.

Sony's Conflict Minerals Policy

The Democratic Republic of the Congo (DRC) and its adjacent countries have been mired in conflict with armed groups perpetuating human rights abuses in that region. These armed groups have been trading in certain minerals commonly found in that region to finance their activities. These four minerals - columbite-tantalite, also known as coltan (tantalum), cassiterite (tin), gold and wolframite (tungsten) - are commonly found in many products, ranging from jewelry to electronics to airplane components. To the extent these minerals are found to be financing armed activities, these four minerals are commonly referred to as "conflict minerals."

In order to ensure transparency and reporting, the United States enacted the Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which first became effective in January 2013. This law requires companies that issue shares on a US stock exchange, such as Sony, to conduct an inquiry into the origin of tin, tantalum, tungsten and gold in their supply chains. If these minerals come from the DRC or its adjacent countries, or if their country of origin is uncertain, then the company must conduct a more thorough review of its supply chain in an attempt to determine whether the supplies supported armed groups in the DRC. On May 31, 2016, Sony submitted its third report to the U.S. Securities and Exchange Commission (SEC) based on its review of its supply chain activities for calendar year 2015.
It is Sony's policy to refrain from knowingly purchasing any products, components or materials that contain conflict minerals so that we can avoid contributing to conflict through our sourcing practices (Our policy is available on our CSR web site, link below). To help ensure compliance with our Conflict Minerals Policy, we have designed an internal due diligence framework to determine the country of origin and chain of custody for any conflict minerals in our supply chain. Our due diligence framework is designed to conform, in all material respects, with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. We endeavor to ensure that our products do not contain tin, tantalum, tungsten or gold from sources that benefit armed rebel groups in the DRC or the adjoining region, while at the same time making sure that we are still able to source responsibly from that region and avoid a de facto embargo, by requiring our suppliers to source materials from smelters determined to be compliant with the Conflict-Free Smelter (CFS) Program* of the Conflict-Free Sourcing Initiative (CFSI), which was established by the Electronic Industry Citizenship Coalition (EICC)/Global e-Sustainability Initiative (GeSI), or other smelters that have been determined to be conflict-free smelters or determined to be conflict-free under other trusted traceability projects.

CFS Program: A voluntary program in which an independent third party evaluates a smelter's procurement activities and determines if the smelter has demonstrated that all the materials it processed originated from conflict-free sources

Sony's Activities to Support Supply Chain Transparency and Reporting

Tungsten, tantalum, tin and gold enter global supply chains from the DRC as well as numerous other supplying countries. Determining the mine of origin for these minerals requires the cooperation of many levels of suppliers and intermediaries in the supply chain. Sony's conflict minerals program is aimed at continuous improvement of our understanding of our supply chain and risk reduction over time. Our expectation is to make progress in the early years of this program, and achieve increased transparency over time based on our efforts to obtain increased supplier cooperation.

Sony began exercising due diligence regarding our use of tin, tantalum, tungsten and gold in selected product categories in August 2011. We expanded our inquiry to the entire Group in 2013. In 2014 we exercised due diligence on our supply chain by investigating whether tin, tantalum, tungsten or gold were present in any Sony products manufactured or contracted to be manufactured during 2014. If any of these minerals were determined to be necessary to the functionality or production of any products manufactured by Sony or a subcontracted manufacturer, during this period, we assessed the country of origin and the smelters at the product level through a supplier survey sent to all relevant suppliers, utilizing the Conflict Minerals Reporting Template of the CFSI. The smelters identified by our direct suppliers were then compared against the conflict-free smelter list prepared by the CFSI, to further enhance the accuracy of Sony's findings.

Sony identified a total of 214 smelters and refiners as potential sources of four minerals and, of those 214 smelters and refiners, 171 smelters and refiners were validated as Conflict-Free Smelters (CFS) or are now under the CFSI audit process. Thirteen of these CFS in our supply chain were reported to procure materials from the DRC and its adjacent countries. While the results of Sony's due diligence did not reveal that any of the tin, tantalum, tungsten or gold in our electronics products were sourced from the DRC or any of its adjacent countries nor that they financed or benefited armed groups in these countries, we concluded that we lack sufficient information at this time to definitively determine the country of origin of all such minerals in our electronics products.

Please refer to the smelter list in the aforementioned Sony report to the SEC, which includes smelters confirmed as conflict-free through Sony's traceability program.
Participation in Industry Groups and the Public-Private Alliance

Sony recognizes that effective change requires a joint effort. We have joined in multi-stakeholder dialogue about conflict minerals with nongovernment organizations (NGOs) and peer companies. Sony actively participates in and supports industry groups and alliances that seek to identify and prevent or mitigate the adverse impact associated with mineral extraction in high-risk areas, including the EICC, and has funded a range of programs addressing this issue. The EICC was founded with the objective of addressing social and environmental issues in the electronics supply chain.

In 2011, the EICC launched the CFS Program to provide leadership to the industry in this area. With the aim of promoting collaboration with other industries and multiple stakeholders, in August 2013 the EICC/GeSI launched the CFSI. Sony utilizes the frameworks developed by the EICC and other alliances as part of its efforts to ensure responsible sourcing of tin tantalum, tungsten and gold.

Sony also supports and contributes to such industry initiatives as the traceability project for tin launched in 2010 by ITRI, a tin industry organization, to validate that the metals used in its products are not contributing to conflict and come from sustainable sources. In addition, Sony participates in the Public-Private Alliance for Responsible Minerals Trade (PPA), a joint effort of government, industry and civil society organizations led by the U.S. government to support responsible mineral trade from the Great Lakes region of Central Africa. Since its establishment, the PPA has supported the creation of a pilot supply chain management system that includes certifying conflict-free mines, that is, mines that engage in responsible trade practices. The PPA also provides a platform for coordination among government, industry and civil society actors seeking to support conflict-free sourcing and self-sustaining trade from the DRC and the Great Lakes Region, and serves as a resource for companies seeking information regarding how to source responsibly.

Moreover, as part of our overall effort to achieve conflict-free supply chains, Sony promotes active, ongoing dialogue with civil society organizations, industry groups and other external stakeholders for further improvement of conflict-free sourcing practices. For example, CFSI holds workshops for discussions periodically with NGOs, socially responsible investors, local government representatives and other stakeholders, in which Sony participates. Such workshops have been held on more than 10 occasions in various countries and regions, including Europe and North America. Sony also works to support the industry initiatives of the Japan Electronics and Information Technology Industries Association (JEITA).
Expectations for Sony Suppliers of Tin, Tantalum Tungsten and Gold

We require our direct suppliers to comply with the Sony Group Conflict Minerals Policy and to fully cooperate with our due diligence efforts regarding sourcing tantalum, tungsten, tin or gold in accordance with the terms of this Policy. In addition, to ensure that products, components or materials delivered to Sony do not contain any conflict minerals, we expect our suppliers to have in place pertinent policies, a due diligence framework and a management system consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.
Risk mitigation plan

In the event that Sony confirms that any of its products, components or materials may contain conflict minerals, Sony, in collaboration with relevant suppliers, shall take actions reasonably necessary to eliminate such minerals from such products, components or materials and shall request that the suppliers makes necessary improvement to its sourcing practices. This includes adoption of a conflict-free sourcing policy, increased responsiveness and accuracy of the supplier survey, and increased use of the four minerals sourced from smelters or refiners participating in the CFS program. Further, in the event that Sony confirms that a supplier has failed to cooperate sufficiently with a due-diligence investigation, fails to follow Sony requests for remediation or has otherwise violated this policy, Sony shall take necessary actions, including without limitation, termination of business with such supplier by stopping new orders.

Sony has also established a hotline to allow any interested party to voice concerns regarding the circumstances of mineral extraction, trade, handling and/or export in conflict-affected and other high-risk areas. In addition to our internal risk assessments, the hotline will help to allow us to be alerted to risks in our supply chain.

Supporting sustainable tin mining practices in Indonesia through the IDH-project

Reports of unsafe working conditions and environmental concerns in Indonesia's tin industry are concerning and are a major factor for why Sony has been one of the members in the Sustainable Trade Initiative (IDH) Tin Working group.
The goal of the IDH Tin Working Group is to positively contribute to addressing the sustainability challenges of tin mining and smelting in Indonesia, while recognizing the economic benefits of the sector in terms of poverty reduction.
Members of the IDH Tin Working Group include global tin users (downstream and midstream industry), the Electronics Industry Citizenship Coalition EICC, the international environmental NGO Friends of the Earth, and the global tin trade association ITRI. The TWG works with local partners from the Indonesian tin industry and the Indonesian government both centrally as well as from Bangka and Belitung.
The TWG started its work in 2013, with a situational analysis conducted to better understand the issues to be addressed in the Tin Mining Industry in Indonesia. The mission of the TWG was to develop solutions in a multi-stakeholder and inclusive way, working closely with key local industry players in 2014 and 2015. Sony will continuously support these efforts through participation in the TWG.

Initiatives Related to Paper Procurement

Sony recognizes that paper resources are limited and strives to reduce the amount of office paper used at sites and limit the number of pages in its product manuals.
Sony also recognizes the impact of illegal logging on biodiversity and considers it important to ensure responsible procurement of lumber and paper products. Sony takes environmental conservation into consideration when purchasing paper materials by adhering to the Sony Group Paper/Printed Material Purchasing Policy.

Sony sources paper from forests certified as responsibly managed and works not only to ensure that the paper it purchases has been produced from forests that are managed in accordance with legal requirements but also to promote the use of paper products certified by the Forest Stewardship Council (FSC), which audits forests based on a range of criteria, including sustainability and uses FSC-certified paper in its corporate printed materials, calendars and business cards.
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