Updated on August 29, 2019

The Sony Group Code of Conduct

Sony promotes innovation through its commitment to ethical and responsible business conduct. Sony’s ethical culture is built upon accountability to the core ethical values of Fairness, Honesty, Integrity, Respect and Responsibility which guide how Sony personnel work with colleagues, business partners and the communities in which Sony does business to fulfill Sony’s Purpose & Values.

The Sony Group Code of Conduct is the cornerstone of Sony’s ethics and compliance program and underlines a shared obligation to enhance and advance Sony’s ethical culture and protect Sony’s reputation. The Code applies to all Sony board members, officers and employees (“Sony Group personnel”).

Sony’s Core Ethical Values

Sony updates the Code from time to time, as part of its continued effort to maintain the Code’s effectiveness and provide clear direction and resources on relevant topics.

Sony also recognizes its responsibility as a member of a global society and the Code reflects principles set out in global ethical guidelines, which include (among others):

  • Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises
  • The United Nations Global Compact
  • The United Nations Universal Declaration of Human Rights
  • The Guiding Principles on Business and Human Rights and Sustainable Development Goals (SDGs)

Sony also participated in the formulation of (and updates of) and observes the standards in the Charter of Corporate Behavior of Keidanren (Japan Business Federation), an alliance of Japan’s leading corporations. These standards are also embodied in the Code.

The Code confirms that Sony must be true to its core ethical values in every aspect of its businesses operations and includes guidance on key risk areas.

  • Accurate recordkeeping
  • Anti-corruption/bribery
  • Antitrust / fair competition
  • Avoiding conflicts of interest
  • Diversity / discrimination / equal employment opportunity / fair employment / proper workplace conduct
  • Fair dealing (fair business practices)
  • Privacy (e.g., data privacy of employees, customers, consumers) and cyber security
  • Protection of human rights
  • Financial integrity and anti-fraud
  • Speaking up / no retaliation
  • Tax law compliance
  • Workplace health and safety

Code Implementation

The Code was adopted by the Sony Corporation Board of Directors and by senior leadership at all affiliates of Sony Corporation (the “Sony Group” or the “Sony Group companies”). Sony Group leaders are responsible for promoting the Code as part of ongoing commitment to improving Sony’s culture of ethical decision making.

The Code, which is available on Sony’s website and on each Sony Group company’s intranet, has been translated into 23 languages to help ensure that it is clearly understood by the employees and relevant third parties. Sony will provide additional translations as may be necessitated by changing workforce demographics.

All Sony Group employees and selected third party staff are required to complete Code of Conduct training within 90 days of hire or the commencement of provision of service. Sony also provides in-depth refresher training on at least one Code of Conduct topic every year, with additional targeted training provided more frequently based on the results of risk assessments.

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