Updated on August 29, 2019

Promoting a Speak Up/Listen Up Culture

Sony believes that a "speak-up/listen up" culture — where employees are encouraged to raise concerns and feel confident that they can do so without fear of retaliation — is a key to early detection and prevention of ethical and regulatory problems.

Multiple Reporting Channels

Sony has an open reporting program and provides many different types of resources to employees to enable them to raise concerns, including the Sony Group Ethics & Compliance Hotline (“Hotline”). The Hotline is available online (in 27 different languages) or by phone, 24 hours a day, seven days a week. The phone lines are staffed by specially trained third-party representatives, and translators are available to assist when needed, in up to 52 different languages. All information provided to the Hotline is handled confidentially. Calls to the Hotline are not recorded or traced, and reporters may remain anonymous to the extent permitted by law.

How Sony Promotes Speak-Up Resources

Sony continuously promotes the need to raise concerns and the resources Sony has made available for employees to raise concerns to. For example, the Sony Group Code of Conduct clearly states that speaking up is the responsibility of every employee to protect their colleagues and Sony. The Code of Conduct training provides guidance on the importance of reporting concerns, and is supplemented by ongoing quarterly messages highlighting Sony’s open reporting program.
Sony also provides training to its managers on how to create an environment where employees feel comfortable speaking up when they observe unethical behavior, how to handle reports and how to prevent retaliation since Sony understands that the employees may prefer to raise concerns with their manager in the first instance.

Sony does not tolerate retaliation against anyone who participates in an investigation or raises a concern in good faith and vigorously enforces and promotes its policy against retaliation.

How Sony Operates the Hotline

In FY 2018, the Hotline received approximately 400 reports covering issues primarily relating to employment, labor, work environment and information management. Approximately 69% of the reports raised issues related to employees, diversity and workplace respect.

All issues raised through the Hotline are promptly reviewed for investigation and, if supported by the findings, disciplinary or corrective action is taken. 38% of reports received in FY 2018 were substantiated and many resulted in remediation. Sony provides information about its reporting statistics to senior management and the Audit Committee of Sony Corporation to help assure effective oversight.

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