Sony Financial Holdings


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Corporate Governance


Basic Stance on Compliance

Sony Financial Holdings' broad definition of compliance is that it encourages all executives and employees to deepen their understanding of the Company' s corporate philosophy and relevant laws and regulations, enforces compliance with these laws and regulations, and manages business operations transparently and properly based on a strong sense of ethics in order to ensure sound and proper operations. Sony Financial Holdings considers compliance to be one of its top management priorities and, accordingly, it has systems in place to ensure that all executives and employees are fully aware of their duties and responsibilities.
While Group companies are responsible for establishing systems to enhance the effectiveness of compliance according to their specific industry and scale of business operations, Sony Financial Holdings, as a financial holding company, undertakes the ongoing monitoring and promotion of the Group companies' compliance by providing advice, as needed, from the viewpoint of Group management.

Compliance Systems at Sony Financial Holdings

Sony Financial Holdings’ Board of Directors formulated a Compliance Manual* and a Compliance Program**. Sony Financial Holdings strives to monitor adherence to stated practices and their implementation at all times, while proactively putting a compliance system in place for itself and for Group companies.

  • * The Compliance Manual outlines Sony Financial Holdings’ compliance system, as well as the Group’s corporate philosophy, which executives and employees must understand, and laws and regulations, which they must comply with. The manual also establishes measures for handling any contravention of compliance practices, and for confirming compliance status.
  • ** The Compliance Program is drafted annually, in principle, and defines a specific action plan for confirming compliance status, conducting training and for other related items.
Compliance System of the Sony Financial Group

Compliance Meetings

Sony Financial Holdings holds regular compliance meetings with Group companies to conduct preliminary consultations and exchange information about the status of compliance dissemination and other issues. Members of the meeting include Sony Financial Holdings and Sony Financial Group company executives, general managers and other staff in charge of compliance, depending on the agenda. The results of these discussions are reported to the Board of Directors and at other important meetings.

Internal Hotline System

If executives and employees of Sony Financial Holdings and its Group companies, as well as temporary employees and the employees of business partners, believe that business policies, operating activities or other activities of the companies breach (or could breach) respective laws and regulations or internal regulations, they can report their concerns by choosing and notifying the appropriate hotline desk at Sony Financial Holdings or at any Sony Financial Group company, or the Sony Group hotline desk. Sony Financial Holdings implements appropriate measures to protect those who contact these desks, while strictly managing and responding to the information provided.


Sony Financial Group Basic Policy on the Prevention of Insider Trading (Summary)

The companies in the Sony Financial Group (the "Group") formulate internal rules pertaining to the buying and selling by the Group companies' executives and employees of the shares and other securities in Sony Financial Holdings, Sony Corporation, other Sony Group companies and business partners of the Group companies. The Group companies comply with these internal rules and laws and regulations pertaining to the prevention of insider trading.

The Group companies establish structures to help prevent insider trading. In addition, as a financial holding company Sony Financial Holdings conducts monitoring to ensure that the Group companies’ structures are sufficient and determine whether they are functioning effectively to prevent insider trading, and takes appropriate measures as necessary.


Conflicts of Interest Policy (Summary)

Sony Financial Holdings has formulated a Conflicts of Interest Policy and established a structure under the provisions of the Banking Act, the Insurance Business Act, and the Financial Instruments and Exchange Act of Japan. The overall goal is to ensure that customers' interests are not harmed by Sony Financial Group companies.


Basic Policy on Eradicating Anti-social Forces

Basic Group Policy on Eradicating Anti-social Forces

The Sony Financial Group recognizes the importance of strictly avoiding any association with anti-social elements from the perspectives of social responsibility, compliance and corporate defense. Accordingly, the Group has formulated this basic policy to enforce its initiatives to shut out anti-social forces.

  1. Organizational response
    Rather than at the individual or departmental level, the Group responds to anti-social forces at an all-organizational level, from top management downward, and ensures the safety for all executives and employees who respond.
  2. Cooperation with external organizations
    To obtain appropriate counsel and cooperation, the Group collaborates closely on an ongoing basis with outside specialists, including the police, centers for the elimination of violent groups and attorneys.
  3. Refusal of all relationships, including transactions
    The Group refuses to have any relationships with anti-social forces, including transactional relationships.
  4. Civil and criminal legal approaches to emergency situations
    The Group strictly rejects unfounded demands by anti-social forces. Furthermore, the Group takes both civil and criminal legal approaches, as necessary.
  5. Prohibition on backroom deals and provision of funds
    The Group conducts absolutely no backroom deals with nor provides funds to anti-social forces.

Structures for Eradicating Anti-social Forces

  • Sony Financial Holdings set up a department for dealing with anti-social forces and appointed a person responsible for thwarting unreasonable demands.
  • Sony Financial Holdings collects information on anti-social forces by cooperating with specialized external organizations.


Privacy Policy

Sony Financial Holdings has formulated a Privacy Policy governing the handling of personal information. It sets out Sony Financial Holdings' policies on the acquisition and use of personal information for specific purposes. Sony Financial Holdings has also established Rules on Information Security that set out specific security control protocols. Sony Financial Holdings monitors the effectiveness of Sony Financial Group companies' security control protocols.

Sony Financial Holdings and its Group companies formulate and revise the Privacy Policy, and set up an organization to protect personal information, to which they appoint persons responsible. Sony Financial Holdings and its Group companies also prepare a set of rules and a manual, as well as training programs on the handling of personal information and information security. These initiatives allow Sony Financial Holdings and its Group companies to maintain entrusted personal information so that it is accurate and up-to-date to the extent necessary for the purposes of its use, and to protect personal information through steps to prevent unauthorized access, leakage, falsification, loss, destruction and other incidents.

View more about our Privacy Policy