Updated on January 7, 2019

The Sony Group Code of Conduct

Sony promotes innovation through our commitment to the superb standards of ethical and responsible business conduct. Our culture is built upon accountability to our core ethical values of Fairness, Honesty, Integrity, Respect and Responsibility. This is the way we work with our colleagues, business partners and the communities in which we do business to fulfill Sony’s Purpose & Values.

Those standards of ethical and responsible business conducts are set forth in the Sony Group Code of Conduct. It underlines our shared obligation to enhance and advance our ethical culture and protect our reputation. It applies to all Sony directors, officers, employees and relevant third party staff (“Sony Group personnel”).

Our Core Ethical Values

We recently updated and improved the Code as part of our continued effort to enhance its usefulness and provide clear direction and resources on relevant topics. The enhanced Code includes a message from Kenichiro Yoshida, our President and CEO.

Sony recognizes its responsibility as a member of a global society. The updated Code reflects ethical principles set out in global guidelines. Those guidelines 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 and recent 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 embodied in our Code.

Our Code confirms that we must be true to our core ethical values in every aspect of our 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 our 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

How we implemented the Code

The improved Code was adopted by the Sony Corporation Board of Directors and is in the process of being adopted 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 our ongoing commitment to improving our culture of ethical decision making.

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

We recently updated our Code of Conduct training course to align with the changes to our Code. 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. We also provide in-depth refresher training on at least one Code of Conduct topic every two years, with additional targeted training provided more frequently based on the results of our risk assessments.

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