Updated on August 29, 2019

Ethics and Compliance Program

Sony’s global ethics and compliance program strongly supports its ethical business culture. Through its global and regional compliance network, which covers all Sony Group companies, Sony provides frequent trainings and messaging on ethics and compliance.
The Sony Corporation Legal ,Compliance & Privacy Department is responsible for establishing the group-wide compliance program and providing oversight of the global compliance team members, who are embedded in Sony’s business units.

The Basics of Sony’s Program

Sony’s program starts with “Tone from the Top.” Senior management continuously and repeatedly communicates the importance of being true to Sony’s 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, program assessment and surveys, third-party risk management, monitoring and audits. Sony continuously improves its program in accordance with regulatory guidance and other leading practices that organizations with mature compliance programs have found to be effective.

Sony’s 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. Sony Group personnel are also required to complete a risk-based compliance training curriculum based upon roles and responsibilities.

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

Global Ethics and Compliance Network

The Sony Corporation Legal ,Compliance & Privacy Department works with 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.

Sony also has a Compliance Monitoring function, which measures the effectiveness and maturity of Sony’s overall compliance program by conducting periodic assessments of program design and implementation. It also conducts risk-based compliance audits and validations of controls.

The Sony Corporation Board of Director’s Audit Committee provides ultimate oversight of Sony’s 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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