The company's group-wide ethics and compliance hotline system, the Sony Ethics & Compliance Hotline, is a confidential resource for employees to report concerns or seek guidance about possible violations of laws or internal policies. It allows Sony to respond swiftly to any potential violations.
The Hotline is available to all Sony Group personnel, worldwide, at all times, day or night, via the telephone (toll-free) or via the web. Reports to the Hotline are administered by an independent third party that provides specially trained operators with broad language capabilities. Anyone who reports issues in good faith is protected from retaliation for making the report.
Summaries of hotline reports, results of investigations and updates on the operation of the system are provided periodically to senior management and the Audit Committee.
During fiscal 2016, the Hotline received approximately 260 reports covering issues primarily relating to employment, labor, work environment, information management and possible conflicts of interest. Approximately 65% of the reports raised issues related to employment, labor and the work environment.
All reports are promptly investigated by Sony compliance personnel, who are supervised by the Corporate Executive in charge of Compliance. We take appropriate disciplinary and/or remedial action when warranted. Confirmed violations of Sony policies and procedures result in corrective actions which may include training, disciplinary action and/or updating processes and controls.
In 2016, Sony found through the internal investigations triggered, among others, by a report to the Hotline, that some former executives and employees of Sony's affiliated company, Sony LSI Design Inc., paid out company money, and misappropriated a part of it for their own benefit, by placing fictitious orders. In response to the incident, Sony implemented preventive measures such as enhanced internal control and compliance trainings to their officers and employees.