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Updated on August 23, 2017

Sony Group Ethics and Compliance Network

All Sony Group personnel have personal responsibility for ethical business conduct and compliance with the law. To support a culture of ethical decision making, Sony established a global ethics and compliance network. This network is comprised of the Sony Corporation Law & Compliance Department at headquarters, regional compliance networks for each geographic region, a global compliance leadership team and a compliance monitoring team. The Sony Corporation Law & Compliance Department establishes group-wide compliance policies and procedures to support ethical decision making and to manage legal/regulatory risks applicable to all Sony Group companies. 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 program activities on an on-going basis.

A regional compliance network has also been established for each geographic region: the Americas, Europe, Japan, East Asia*1 and Pan-Asia*2. A Regional Compliance Officer ("RCO") leads each regional network to ensure that senior management and the legal/compliance personnel for the Sony Group companies in the Region have implemented Sony's global compliance programs as well as any additional policies and procedures necessary to comply with applicable local law. RCOs have authority to issue instructions concerning compliance activities in their respective regions and, by coordinating with one another, they help assure and maintain an effective global compliance program.

The Sony Corporation Audit Committee receives monthly reports and periodic in-person updates about the compliance program activities, including information regarding the Hotline, to ensure effective oversight of the program.

*1
Coverage area of East Asia compliance office: Mainland China, Hong Kong, Taiwan and South Korea
*2
Coverage area of Pan-Asia compliance office: Southeast Asia, Middle East, Africa and Oceania

*3
The Americas Office is responsible for Sony Corporation of America, the Sony Interactive Entertainment Group, the Sony Pictures Entertainment Group, and the Sony Music Entertainment Group, as well as the 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 and Sony Financial Holdings Group, in addition to the Electronics Group Companies in Japan.

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