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 Group
Sony Financial Holdings has established the Sony Financial Group Code of Conduct (hereinafter referred to as the “Sony Financial Group Code of Conduct”) that all executives and employees must observe. In addition, Sony Financial Holdings’ Board of Directors is responsible for establishing and maintaining Sony Financial Holdings’ compliance system by formulating a Compliance Manual* and a Compliance Program**, as well as working proactively to ensure its proper operation.
Group companies have also adopted their Code of Conducts based on the Sony Financial Group Code of Conduct, while putting in place and developing their compliance systems on their own. Sony Financial Holdings provides guidance and support to ensure proper operation of the compliance systems 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. 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.
Compliance System of Sony Financial Group
Specific Initiatives for Thorough Compliance
Sony Financial Group strives to ensure thorough implementation of compliance measures through regular dissemination of messages from top management, and works on various measures to promote compliance, including training for all executives and employees.
Primary domains of focus of compliance initiatives
Internal Hotline System
If executives and employees of Sony Financial Group, as well as temporary employees and the employees of business partners, think 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 70 reports were received by the hotline desk at Sony Financial Holdings and Group companies in fiscal 2018, 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 Legal & 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.
Anti-money Laundering and Countering Financing of Terrorism
Sony Financial Group gives high priority to anti-money laundering and countering financing of terrorism as an important management, and has formulated the Basic Group Policy on Anti-money Laundering and Countering Financing of Terrorism. Sony Financial Group gives the necessary authorization and allocates resources in a top-down manner, and proactively instills an awareness regarding anti-money laundering and countering financing of terrorism among all executives and employees.