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43
Ethical business conduct and compliance with applicable laws
and regulations are fundamental aspects of Sony’s corporate
culture. To this end, Sony has established a Compliance Offi ce
at its corporate headquarters and regional offi ces around the
world, adopted and implemented the Sony Group Code of
Conduct, and set up Compliance Hotline systems through its
global compliance network—all in order to reinforce the
company’s worldwide commitment to integrity and help assure
resources are available for employees to raise concerns or
seek guidance about legal and ethical matters.
Strengthening the Compliance System
In July 2001, Sony Corporation established the Compliance Offi ce,
charged with exercising overall control over compliance activities
across the Sony Group, to emphasize the importance of business
ethics and compliance with applicable laws, regulations and internal
policies. The Compliance Offi ce establishes compliance policies
and structures for the Sony Group and performs crisis management
functions.
In July 2003, Sony established a regional compliance network
comprised of offi ces in the Americas, Europe, Japan,1 East Asia2
and Pan-Asia,3 which are charged with assisting the Compliance
Offi ce at Sony Corporation and exercising regional control over
compliance activities to strengthen the compliance system
throughout the Sony Group. Offi cers responsible for compliance in
each region have the authority to issue instructions concerning
compliance to Sony Group companies in their respective regions
and, by cooperating with one another, are working to establish and
maintain a comprehensive global compliance structure.
1 Coverage area of Japan compliance offi ce: Japan, South Korea and Taiwan
2 Coverage area of East Asia compliance offi ce: Mainland China and Hong Kong
3 Coverage area of Pan-Asia compliance offi ce: Southeast Asia, Middle East,
Africa and Oceania
Sony Group Code of Conduct
In May 2003, Sony adopted the Sony Group Code of Conduct,
which sets the basic internal standards to be observed by all
directors, offi cers and employees of the Sony Group in order to
emphasize and further strengthen corporate governance, business
ethics and compliance systems throughout the entire Sony Group.
This Code of Conduct sets out, in addition to legal and compliance
standards, the Sony Group’s basic policies concerning ethical
business practices and activities on such topics as respect for
human rights, safety of products and services, environmental
conservation and information disclosure.
Internal Hotline System
With the adoption of the Sony Group Code of Conduct, Sony also
established the Sony Group Compliance Hotline system as a
resource for employees to report concerns or seek guidance about
possible violations of laws or internal policies, and to allow the Sony
Group to respond swiftly to potential risks of such possible viola-
tions. The Sony Group Compliance Hotline system is available in
the Americas, Europe, Japan, East Asia and Pan-Asia, and is ready
to receive the concerns of any Sony Group employee in any part
of the world through a telephone call, e-mail or letter.
During fi scal 2007, the Sony Group received approximately
340 hotline contacts covering issues relating to employment, labor,
work environment, information management, environmental
protection, possible confl icts of interest and thefts. All contacts
received are investigated for the purpose of verifi cation and appro-
priate action. In certain cases, these contacts have led to a review
of internal procedures and the strengthening or enforcement of
internal rules.
Educating Employees about the Sony Group Code of Conduct
and the Internal Hotline System
To ensure that all employees are aware of the Sony Group Code of
Conduct and the internal hotline system, Sony Group companies
inform their employees about the Code and hotline through the
ongoing dissemination of e-mails, booklets, wallet cards, posters,
postings on the company’s intranet and/or feature articles in internal
newsletters.
Education and training sessions that use e-learning, case
studies and other approaches presenting real-life examples also
provide instruction both on business ethics generally and on
individual aspects of the Sony Group Code of Conduct that are
crucial to some or all of the Sony Group. Examples include educa-
tion programs regarding fairness in competition and business
dealings, and training to avoid discrimination and harassment in
the workplace.
Compliance
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