Sony 2012 Annual Report Download - page 49

Information Security and Personal Information
Management
Sony has established an Information Security and Privacy
organization headed by a Chief Information Security Ocer
(CISO) reporting directly to a Sony Corporation Corporate
Executive Ocer. Sony also has established the Sony Global
Information Security Policy and its related subordinate rules,
the Sony Global Information Security Standard, and the Global
Basic Principles on Personal Information, which set forth
Sony’s commitment to information security and privacy and
define policies to be followed by all Sony personnel. The CISO
and his organization are charged with maintaining and imple-
menting these policies. This organization coordinates with
individuals responsible for information security and privacy at
Sony Group companies globally to create a Groupwide infor-
mation security and personal information management sys-
tem. Under the supervision of the CISO, Sony continuously
reinforces internal rules and business processes to further
strengthen the information security management framework
of the Sony Group and contribute to the protection of personal
information. Recognizing that employee awareness of
information security is vital, Sony requires training programs
for its employees to increase their understanding and
improve the overall level of information security.
Following the adoption of the Sony Group Code of
Conduct, Sony also established a Sony Group Compliance
Hotline system as a resource for employees to repor t
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 violations. The Sony
Group Compliance Hotline system is available worldwide.
The Sony Group Compliance Hotline system is directly
linked to the Corporate Executive Ocer in charge of Compli-
ance. The Compliance Hotline is operated independently from
the ordinary line of command, and callers who report issues
in good faith are protected from any possibility of retaliation
for the report. Summaries of hotline calls, results of investiga-
tions and updates on the operation of the system are reported
to senior management and the Audit Committee.
Compliance Monitoring Program
A compliance monitoring program helps to ensure thorough
global adherence to the Company’s Code of Conduct, internal
policies, and training and other protocols. The program relies
on self-assessments, compliance audits and internal audits,
along with monitoring of hotline and other reporting.
Sony Group Anti-Bribery Program
Among other policies, Sony has adopted the Sony Group Anti-
Bribery Policy, which builds on the anti-bribery and accurate
record-keeping requirements in the Sony Group Code of Con-
duct to help ensure that Sony Group personnel do not violate,
or appear to violate, any applicable anti-corruption laws or
regulations. This Policy reflects Sony’s strong commitment to
business integrity and, in particular, establishes practices and
procedures that must be followed to help ensure integrity in
Sony’s dealings with government ocials, as well as training
requirements.
Global Compliance Network
Global Compliance Network
General Counsel
Compliance Division
Group Compliance Dept.
Americas
Regional Compliance
Oce
Regional Subsidiaries
Compliance Ocer Compliance Ocer Compliance Ocer Compliance Ocer Compliance Ocer
Subsidiaries
in the Americas
Subsidiaries
in Europe
Subsidiaries
in Japan
Subsidiaries
in East Asia
Subsidiaries
in Pan-Asia
Europe
Headquarters
Regional Compliance Ocers
Global Strategy Leader
Audit & Monitoring Strategy Leader
Training Strategy Leader
Compliance Leadership Team
Japan East Asia Pan-Asia
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