Updated on August 29, 2018

Promoting a Speak Up/Listen Up Culture

We believe that our "speak-up/listen up" culture — where our 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

We have an open reporting program that provides many different types of resources to our employees to raise concerns to, including the Sony Group Ethics & Compliance Hotline (“Hotline”). The Hotline is available online (in 31 different languages) or by phone 24 hours a day, seven days a week. Hotline operators are specially trained third-party representatives, and translators are available to assist when needed in up to 51 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 we promote our speak-up resources

We continuously promote the need to raise concerns and the resources we have made available for our employees to raise concerns to. For example, the Sony Group Code of Conduct clearly states that speaking up is the responsibility of every one of us to protect our colleagues and Sony. Also, our Code of Conduct training provides guidance on the importance of reporting concerns, and our training program is supplemented by ongoing quarterly messages which highlight our open reporting program.

We also provide training to our 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 we understand that our employees may prefer to raise concerns with their manager in the first instance.

We strongly promote and enforce our policy against retaliation. Sony does not tolerate retaliation against anyone who participates in an investigation or raises a concern in good faith.

How we operate the Hotline

In FY 2017, the Hotline received approximately 300 reports covering issues primarily relating to employment, labor, work environment, information management and possible conflicts of interest. Approximately 69% of the reports raised issues related to Employees, diversity and workplace respect. Our overall number of reports increased by 17%, and the number of reports per 100 employees increased by 30%.

All issues raised through the Hotline are promptly reviewed for investigation and, if supported by the findings, disciplinary or corrective action is taken. 42% of reports received in FY 2017 were substantiated and many resulted in remediation. We provide information about our reporting statistics to senior management and the Audit Committee of Sony Corporation to help assure effective oversight.

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