Updated on August 29, 2018

Ethics and Compliance Program

Our global ethics and compliance program strongly supports our ethical business culture. Through our global and regional compliance network, which covers all Sony Group companies, we provide frequent trainings and messaging on ethics and compliance.

The Sony Corporation Legal & Compliance Department is responsible for establishing our group-wide compliance program and providing oversight of our global compliance team members, who are embedded in our business units.

The basics of our program

Our program starts with “Tone from the Top.” Our senior management continuously and repeatedly communicate the importance of being true to our core ethical values. Their commitment is supported by a robust ethics and compliance program aligned with integral business processes including policies and procedures, training, ongoing risk assessments, surveys, third-party risk management and audits. We continuously benchmark best practices and improve our program as a member of Ethisphere’s Business Ethics Leadership Alliance, a globally recognized membership organization of leading companies organized to share best practices in governance, risk management, compliance and ethics.

Our program includes mandatory ethics and compliance communications and training to be provided to all employees and relevant third parties. All Sony employees and relevant third parties are required to complete Code of Conduct and Proper Workplace Conduct training within 90 days of hire or the commencement of provision of service. Information security training must be completed by all Sony Group personnel within 60 days of hire. Sony Group personnel are also required to complete a risk-based compliance training curriculum based upon role and responsibilities.

  • Key Compliance Trainings (assigned based upon risk assessments) include:
    • Anti-Bribery
    • Customer Due Diligence
    • Antitrust and Fair Competition
    • Import / Export Trade Compliance

Global Ethics and Compliance Network

The Sony Corporation Legal & Compliance Department works with our global compliance team members and local business unit leaders to conduct comprehensive risk assessments and implement compliance policies, procedures and internal controls to prevent and detect unethical behavior. It provides oversight of the investigation of and follow-up on any incidence of policy non-compliance or potential violation of law.

Also, we have the Compliance Monitoring function, which measures the effectiveness of our overall compliance program by conducting periodic assessments of program implementation as well as compliance audits and validations of our controls.

The Sony Corporation Board of Director’s Audit Committee provides ultimate oversight of our program and receives monthly reports and periodic in-person updates about the compliance program activities. Reports to the Board’s Audit Committee provide program performance results, compliance hotline metrics, employee training data, and new program and communications initiatives, as well as updates on global regulatory developments.

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