Updated on August 29, 2019
As part of its efforts to ascertain Sony manufacturing sites’ compliance with the Sony Supply Chain Code of Conduct, Sony uses standard tools provided by the Responsible Business Alliance (RBA) to check compliance, assess improvements, and implement other monitoring activities. Specifically, Sony utilizes the RBA questionnaire as an annual CSR self-assessment survey at all of its electronics manufacturing sites in and outside of Japan to evaluate compliance in five categories designated by the RBA Code of Conduct: labor, health and safety, ethics, environment, and management systems. At manufacturing sites where self-assessment surveys indicate issues with compliance and further evaluation and improvement in these areas are deemed necessary, appropriate measures to improve compliance are developed and implemented. In fiscal 2018, 16 manufacturing sites in Japan, China, Korea, Thailand, Malaysia, UK, Mexico and Brazil completed self-assessment surveys. The results showed that risk of non-compliance was low at all manufacturing sites. In cases where any possibility of violations of the Sony Supply Chain Code of Conduct is reported by external sources, such as NGOs or media reports, the manufacturing site in question determines the facts of the case. If this determination confirms the reported violations, Sony ensures that appropriate action is immediately taken, including an RBA audit conducted by a third-party auditor.
There is mounting social pressure on global corporations to conduct human rights due diligence for their supply chains. For example, the United Kingdom enacted the Modern Slavery Act to prevent modern forms of slavery such as forced labor in supply chains. Malaysia in particular has many foreign workers who are employed at manufacturing facilities for electronic products and components. An international human rights non-governmental organization has issued a report citing forced labor conditions among foreign workers in Malaysia's electronics industry. The practices cited include workers being charged excess commissions upon hiring and employers retaining workers' passports, making it difficult for workers to get their passports back when they needed them. These conditions limit the freedoms of foreign workers who are living away from their home countries, leading to forced labor conditions.
Sony also employs many foreign workers at its manufacturing sites in Malaysia. In response to social concerns over forced labor, Sony commissioned a third-party assessment involving a fact-finding survey and risk identification regarding employment of foreign workers and their labor conditions at Sony manufacturing sites in Malaysia in fiscal 2016. The assessment was conducted by the non-profit Business for Social Responsibility, which provides its member companies with research and consulting services relating to corporate social responsibility.
The third-party assessment was implemented by interviewing management, HR department staff, and foreign workers from Indonesia, Nepal, Myanmar, Vietnam, and Bangladesh, as well as interviewing temporary staffing agencies acting as intermediaries for foreign workers either in their home countries or Malaysia. Personnel from the CSR department in Japan were dispatched to Malaysia to observe the assessment, which covered the entire process from before hiring (prior to leaving the home country) to actual hiring and conditions after termination of employment (after expiry of the employment contract). The assessment did not find any cases that qualified as serious legal violations, but identified some areas for improvement that Sony is currently working to address. For example, the assessment found that living conditions for foreign workers hired through temporary staffing agencies could be improved in terms of the cleanliness of dormitories, living space provided, and surrounding environment. Sony is working with temporary staffing agencies to make improvements by implementing follow-up visits to dormitories, as well as recognizing agencies that have made positive improvements and sharing their initiatives among agencies.
Many foreign workers including technical intern trainees are employed in Japan across various industries, including manufacturing, agriculture, forestry, fisheries, and construction, and as caregivers. With the increase in media coverage, allegations of foreign worker exploitation have been recognized as an important social issue in Japan. Since fiscal 2017, Sony has been conducting surveys of actual work conditions and risk assessments to monitor the employment status and labor conditions of foreign workers at Sony manufacturing sites in Japan. The assessments check whether the site has any foreign workers or not (in either direct or indirect employment) and confirm the hiring processes and labor conditions. The surveys of actual conditions are conducted for select manufacturing sites. In fiscal 2018, at some manufacturing sites, Sony requested on-site business partners to conduct a survey on the employment of foreign workers and asked those partners for cooperation in compliance with the Sony Supply Chain Code of Conduct.