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, enforces compliance with these laws, regulations, and social norms 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 Activities at Sony Financial Holdings
Sony Financial Holdings considers the Sony Group Code of Conduct as the fundamental internal code that all executives and employees must of serve. In addition, 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 putting in place and developing the Sony Financial Holdings compliance system and working proactively to ensure its effective operation. Sony Financial Holdings also provides appropriate guidance and support in order to put in place and develop compliance systems and operate them effectively at 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 behavior that conflicts with laws and regulations or behavior that raises compliance issues, 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.
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 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. A total of approximately 30 reports were received by the hotline desk at Sony Financial Holdings and Group companies in fiscal 2016, the majority of which were related to the workplace environment. Sony Financial Holdings implements appropriate measures to protect those who contact these desks, while strictly managing and responding to the information provided.
Prevention of Insider Trading
Sony Financial Holdings has established a Basic Group Policy on the Prevention of Insider Trading, whereby a structure for the prevention of insider trading has been developed at Sony Financial Holdings and Group companies.
Sony Financial Holdings monitors whether such framework is adequately in place and working effectively in the prevention of insider trading at Group companies, and takes actions as necessary.
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.