Sony 2013 Annual Report Download - page 43

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 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
violations.
The Sony Group Compliance Hotline system is available
worldwide. It is directly linked to the Corporate
Executive Ocer in charge of Compliance. It 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 investigations 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
As one example of its compliance-related initiatives,
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 Conduct
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 commit-
ment 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.
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
global information security policies and standards, and
global privacy policies, which set forth Sony’s commit-
ment to information security and privacy and define
practices and procedures to be followed by all Sony
personnel. The CISO and his organization are charged
with developing and implementing these policies and
standards globally to ensure network security and the
protection of privacy. This organization coordinates with
individuals responsible for information security and
privacy at Sony Group companies globally to create a
Group-wide information security and personal informa-
tion management system. 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 and privacy is vital, Sony requires training pro-
grams for its employees to increase their understanding
and improve the overall level of information security and
protection for individuals’ privacy.
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