Updated on August 29, 2019
Sony prohibits any form of corrupt practices. Sony believes that corruption negatively impacts the economy and must be eliminated to build a sustainable, inclusive and transparent society. Sony closely monitors global anti-corruption law enactment and enforcement trends to ensure that Sony’s global compliance program and internal controls properly address these evolving risks.
Sony’s Anti-Corruption Procedures
All Sony Group personnel are required to read, understand and follow the Sony Group Anti-Bribery Policy and the Sony Group Code of Conduct, which include anti-corruption expectations for all personnel. Sony’s approach to compliance in this critical area is multifaceted. Key features include:
Sony’s corporate policies and procedures prohibit improper payments in every transaction, whether with a government or with a private party. The Sony Group Anti-Bribery Policy was most recently revised in 2018, and establishes policies and procedures that all Sony Group personnel must adhere to when interacting with officials of various governments around the world, including strict limitation on the type of expenditures that are permitted and pre-approval requirements.
Third parties who will interact with governments on Sony’s behalf, joint venture partners, and parties to acquisitions and certain investments are subject to due diligence and legal pre-approval and relevant third parties must agree to abide by Sony’s anti-bribery policy.
Sony provides extensive training and support to assist local management with policy compliance. All employees receive training when hired on the Sony Group Code of Conduct, which includes anti-corruption expectations. More focused anti-corruption training, which includes training on Sony’s specific policy pre-approval and due diligence requirements is provided to selected employee groups (i.e. senior management, finance, legal, marketing, sales, real estate, corporate development, tax, audit, anyone involved in procurement and any other employees identified as dealing with government officials). Additionally, live training is provided to legal, finance, other control personnel and higher-risk personnel. Refresher training is provided at least every two years, and more frequently based on risk assessments.
Concerns are promptly investigated and remediated and remediation and testing activities are monitored until completed.
Sony has implemented robust internal controls and accounting processes designed to detect and prevent violations of company policy relating to improper payment risks and to ensure accurate books and records.
Sony conducts periodic anti-bribery assessments and audits of the business to raise overall awareness, detect potential misconduct and monitor compliance with anti-corruption laws and policy.
Sony continues to leverage opportunities to share learnings and successful practices across its system.