- Basic Stance
- Management System
- Directors and Audit & Supervisory Board Members
- Risk Management
Basic Stance on Compliance
Sony Financial Holdings' broad definition of compliance is that it enforces compliance with these laws, regulations, and social norms and manages business operations transparently and properly based on a strong sense of ethics. Sony Financial Holdings considers compliance 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 observe. 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 40 reports were received by the hotline desk at Sony Financial Holdings and Group companies in fiscal 2017, the majority of which were related to the workplace environment, the organization’s management and the course of business operations. 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.
Conflicts of Interest Policy (Summary)
Sony Financial Holdings has formulated a Conflicts of Interest Policy to ensure that customers' interests are not harmed by Sony Financial Group companies. The director in charge of the Compliance Department, as the manager responsible for managing confl icts of interest, shall require Group companies to take the following actions when he/she deems them necessary based on reports from Group companies, customer complaints or other sources.
- Sever the flow of information between divisions that have potential confl icts of interest
- Suspend the transaction concerned, or change the terms and conditions or method of the transaction
- Disclose the fact or the possibilities of a confl ict of interest to customers
- Take other actions deemed necessary
Sony Financial Holdings shall retain records that specify transactions to be managed and that are associated with actions taken to properly protect customers, for five years.