Updated on August 29, 2018
Sony established the Sony Supply Chain Code of Conduct to ensure that suppliers understand Sony's expectations in more detail. Suppliers of products and materials to Sony are required to observe this code.
As part of its effort to ascertain supplier compliance with the Sony Supply Chain Code of Conduct, Sony conducts assessments worldwide. To this end, Sony uses the concept of risk assessment to determine risks associated with the country and region in which each supplier is based, as well as risks associated with the scale, status and nature of the supplier's business, and tailors its assessments, such as its CSR self-assessment using questionnaires provided by the Responsible Business Alliance (RBA), to the supplier's risk level.
Sony asks suppliers to assess themselves using RBA questionnaires. The assessments, conducted via RBA Online, are repeated each year for major OEM suppliers with whom Sony does sizable business. Based on the results of these assessments, Sony evaluates the degree to which suppliers are complying with the Sony Supply Chain Code of Conduct and whether violations have occurred at each of the suppliers' factories. As part of its risk assessments, Sony conducts on-site assessments of suppliers it deems to be subject to risks in order to confirm how their factories are being managed.
For example, if suppliers employ students, Sony's internal procedures provide that Sony directly visits their factories to check whether any workers are younger than the legal age limit in that country, and to confirm whether the health and safety of younger workers are being affected by their jobs due to long working hours, working night shifts, and other factors. Likewise, if suppliers employ foreign workers, Sony's internal procedures provide that Sony confirms whether such workers are subject to forced labor, whether dormitory facilities provided to those workers meet international standards, and whether the working environment is clean and safe. By inspecting factories and providing direction in this way, Sony ensures that suppliers are making every effort to comply with CSR standards.
In fiscal 2017, Sony completed assessments of 224 suppliers including document assessments of 122 suppliers. The document assessments identified five high-risk suppliers, which Sony then worked with to make improvements. Sony also conducted on-site assessments of 13 suppliers for possible non-compliance with the Sony Supply Chain Code of Conduct. In particular, the assessments identified issues with suppliers in Malaysia, which has a high percentage of foreign workers. Sony worked with the suppliers to address issues with the management of passports and the working hours and wages of foreign workers. Additionally, Sony worked with suppliers to establish occupational health and safety management systems where such infrastructure was inadequate.
In cases where any possibility of violations of the Sony Supply Chain Code of Conduct is reported via external sources, such as NGOs or media reports, Sony cooperates with the supplier in question to confirm the facts of the case expeditiously and objectively. Specifically, Sony may request that the supplier's manufacturing site undergo a third-party RBA audit. In the event that any deficiencies are discovered, the supplier is required to develop an improvement plan, and Sony monitors the supplier's performance in the form of follow-up audits to ensure the progress of initiatives. In cases where any possibility of violations is reported at a secondary supplier, Sony works with the primary supplier to ensure that remedial action is carried out.
Sony requires that its primary suppliers ensure that the Sony Supply Chain Code of Conduct is observed by secondary and further suppliers. Primary suppliers conduct self-assessments to verify their understanding of the Sony Supply Chain Code of Conduct and to ensure that it has been communicated internally and is being complied with. Additionally, primary suppliers communicate the Sony Supply Chain Code of Conduct to their own supply chains and require compliance.
Sony provides support to suppliers in order to improve their initiatives. In Southeast Asia and China, local liaison officers assigned to communicate directly with suppliers are provided with the educational and training opportunities needed to serve as CSR specialists at local sites. These CSR specialists strive to ensure that suppliers make continuous efforts to improve management systems and other organizational structures, by communicating with them and providing direct guidance on ways to improve.
In fiscal 2016, Sony launched a fire prevention initiative to support safety management at supplier facilities. Under the initiative, Sony provides suppliers with a document describing actual fire incidents, including the causes and lessons learned, together with a fire prevention checklist, to facilitate improvements to safety management. In fiscal 2017, Sony also conducted on-site assessments to verify the safety management at supplier plants. The assessments identified a number of inadequacies that were subsequently addressed, including unidentifying fire pump control panels and non-closing fireproof doors.
Sony has established a Supplier Hotline which suppliers may use to report conduct by a Sony Group company executive or employee that violates laws, regulations, the Sony Group Code of Conduct, or the Sony Supply Chain Code of Conduct, as well as conduct that violates the company's agreements with suppliers. The hotline is part of a framework that Sony is focused on establishing to facilitate sharing of concrete information on cases where the conduct of a Sony Group company executive or employee has been identified to be in violation (or possible violation) of any laws, regulations, the Sony Group Code of Conduct, the Sony Supply Chain Code of Conduct or an agreement between Sony and a supplier.