Sony 2012 Annual Report Download - page 48

Ethical business conduct and compliance with appli-
cable laws and regulations are fundamental aspects
of Sony’s corporate culture. To this end, Sony has
established a Global Compliance Network com-
prised of the Compliance Division at the corporate
headquarters, a global compliance leadership team
and regional compliance oces around the world.
Additionally it has adopted and implemented the
Sony Group Code of Conduct and set up Compliance
Hotline systems through its Global Compliance Net-
work. Sony has taken these ac tions 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
Division, charged with exercising overall control over compli-
ance activities across the Sony Group, to emphasize the
importance of business ethics and compliance with applicable
laws, regulations and internal policies. The Compliance
Division establishes compliance policies and structures for
the Sony Group.
In July 2003, Sony established a regional compliance net-
work, comprised of offices in the Americas, Europe, Japan,
East Asia*1 and Pan-Asia*2, which are charged with exercising
regional control over compliance activities to strengthen the
compliance system throughout the Sony Group.
*1 Coverage area: Mainland China, Hong Kong, Taiwan and South Korea
*2 Coverage area: Southeast Asia, Middle East, Africa and Oceania
Sony Group Code of Conduct and Internal
Hotline System
In May 2003, Sony adopted the Sony Group Code of Conduct,
which sets the basic internal standards to be observed by all
directors, ocers and employees of the Sony Group, in order
to emphasize and further strengthen corporate governance,
business ethics and compliance systems throughout the Sony
Group. In addition to legal and compliance standards, the
Code of Conduct sets out the Sony Group’s basic policies con-
cerning ethical business practices and activities on such topics
as respect for human rights, safety of products and services,
environmental conservation and information disclosure. The
Code of Conduct has been adopted and implemented by
each Sony Group company globally and is the subject of
frequent “tone from the top” messaging and other training.
Compliance
Sony Group Code of Conduct
Established May 2003
[Scope of Application: Companies]
Standards applicable to Sony Corporation, as well as any company
more than 50% of whose outstanding stocks or interests with
voting rights is owned directly or indirectly by Sony Corporation,
and such other companies as determined by the Board of Directors
of Sony Corporation
[Scope of Application: Personnel]
Standards applicable to all Sony Group directors, ocers and
employees
[Headings]
1. General Standards
1-1 Compliance with Laws as well as Internal Rules and Policies;
Honest and Ethical Business Conduct
1-2 Relationship with Stakeholders
1-3 Appreciating Diversity
1-4 Avoiding Structural Conflicts of Interest
1-5 Communication of Concerns and Alleged Violations
2. Respect for Human Rights
2-1 Equal Employment Opportunity
2-2 No Forced Labor/Child Labor
2-3 Sound Labor and Employment Practices
2-4 Work Environment
3. Conducting Business with Integrity and Fairness
3-1 Product and Service Safety
3-2 Environmental Conservation
3-3 Fair Competition
3-4 Advertising
3-5 Public Disclosure
3-6 Personal Information
3-7 Intellectual Property
3-8 Confidential and Proprietary Information
3-9 Fair Procurement
3-10 Gifts and Entertainment
3-11 Recording and Reporting of Information
4. Ethical Personal Conduct
4-1 Insider Trading
4-2 Personal Conflicts of Interest
4-3 Corporate Assets
4-4 Media Relations and Public Statements
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