Sony 2013 Annual Report Download - page 42

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, officers 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
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 Global Compliance Network
comprised of the Compliance Division at the corporate
headquarters, a global compliance leadership team
and regional compliance ocers 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 Network.
Sony has taken these actions 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
compliance activities across the Sony Group, to empha-
size 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
network, comprised of regional compliance ocers in
each region worldwide, who are charged with exercising
regional control over compliance activities to strengthen
the compliance system throughout the Sony Group.
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
concerning 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
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