UKMSA 20160908 Sign R

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Sony Group Statement on U.K. Modern Slavery Act
We make this Statement pursuant to Section 54 of the United Kingdom (UK) Modern Slavery Act
2015 (the “Act”) to identify actions we have taken on a Sony Group-wide basis during the financial
year ending March 31, 2016 to prevent slavery and human trafficking from occurring in our supply
chains or our business. Although not all Sony Group1 companies are subject to the Act, we have
undertaken a Group-wide approach to our human rights commitment, and make this Statement on
behalf of all Sony Group companies (sometimes collectively referred to as “Sony”).
Our Human Rights Commitment
Slavery and human trafficking can occur in many forms, such as forced labor, child labor, domestic
servitude, sex trafficking, and related forms of workplace abuse. In this Statement, we use the
terms “slavery and human trafficking” to include all forms of slavery, servitude and forced or
compulsory labor and human trafficking.
Sony is committed to maintaining and improving systems and processes to help ensure that there
are no human rights violations related to our own operations or our supply chains. We have
invested significant resources and have collaborated with stakeholders, suppliers and industry
associations to develop and implement programs designed to prevent slavery and human trafficking
in our operations and supply chain, particularly in our electronics manufacturing supply chain,
which, as noted below, is our area of higher risk.
Sony Group Code of Conduct. Our commitment to human rights is set out in the Sony Group Code
of Conduct, which is applicable to all Sony employees, officers and directors (the “Code of
Conduct”). The Code of Conduct is available at http://www.sony.net/code. The Code of Conduct
prohibits any form of forced, involuntary or child labor in our operations, requires all Sony Group
companies to adopt sound labor and employment practices and to at all times treat their employees
in accordance with applicable laws. Each Sony Group company must take appropriate steps to
assure compliance with the Code of Conduct, including establishing appropriate disciplinary
procedures, which may include termination of employment, for violations of the Code of Conduct.
In addition, in accordance with our Code of Conduct, all Sony Group suppliers, contractors and
original equipment manufacturers are expected to uphold the Sony Group’s policies regarding

1

For this purpose, a Sony Group company includes any company where 50% or more of the voting

rights are directly or indirectly controlled by Sony Corporation.

compliance with applicable laws and respect for human rights.
Our Code has been translated into 26 languages.

1. Our Business and Supply Chain
Sony is engaged in the development, design, manufacture, and sale of various kinds of electronic
equipment, instruments, and devices for consumer, professional and industrial markets such as
smartphones, tablets, videogame consoles, digital cameras, televisions, audio and video recorders
and players, semiconductor and devices, peripherals and accessories (collectively, our “electronics”
products). There are 20 Sony-operated manufacturing sites for our electronics products, which are
located in Japan, China, South Korea, Singapore, Thailand, Malaysia, UK, Mexico and Brazil. We
also contract with third parties to manufacture certain electronics products on our behalf. We
procure materials and component parts for those products from suppliers located throughout the
world.
In addition, Sony is engaged in the production, acquisition and distribution of motion pictures and
television programming, the operation of television and digital networks and the development,
production, manufacture and distribution of recorded music and the management and licensing of
the words and music of songs. Sony is also engaged in the licensing, development, publishing,
manufacture and distribution of videogames in physical and digital formats and the operation of a
digital network supplying videogames and other digital content and services to consumers. Further,
Sony is engaged in various financial services businesses, including life and non-life insurance
operations through its Japanese insurance subsidiaries and banking operations through a Japanese
internet-based banking subsidiary. Sony is also engaged in a network services business and an
advertising agency business in Japan.
As of March 31, 2016, Sony had approximately 125,300 employees and operated in 82 countries.
2. Risks of Slavery and Human Trafficking in our Business and Supply Chains
We employ rigorous hiring procedures and have implemented robust employment policies and
other controls to mitigate the risk of slavery and human trafficking in our own business
operations.
We engaged BSR, an independent, non-profit, global organization devoted to building a just and
sustainable world, to help us evaluate risks of slavery and human trafficking in our business
operations and related supply chains. From BSR’s assessment, we determined that our electronics
manufacturing supply chain was at higher risk for potential human rights abuses than our business

operations and supply chains of our remaining business segments, which were determined to be
low-risk for these abuses. We are therefore prioritizing our electronics manufacturing operations
in our group-wide efforts.
3. Supplier Compliance Procedures and Adherence to Our Values
Supply Chain Code.

We are committed to working with our suppliers and other stakeholders to

understand further potential areas of risk and increase transparency and we seek to use our
influence to help mitigate any negative impacts identified.

Sony is a founding member of the

Electronic Industry Citizenship Coalition® (EICC®), a non-profit coalition of electronics
companies committed to supporting the rights and well-being of workers and communities in the
global electronics supply chain. Sony has adopted the Sony Supply Chain Code of Conduct (the
“Supply Chain Code”) for our electronics products suppliers. The Supply Chain Code, which
incorporates the EICC Code of Conduct, establishes standards designed to, among other things,
ensure that human rights of workers are upheld and that workers are treated with respect and
dignity by suppliers.

In particular, the Supply Chain Code prohibits forced, bonded or

indentured labor, involuntary prison labor, slavery and human trafficking. The Supply Chain Code
is available at http://www.sony.net/SonyInfo/csr_report/sourcing/supplychain/index2.html.
The Supply Chain Code is aligned with the UN Guiding Principles on Business and Human
Rights, the ILO Declaration on Fundamental Principles and Rights at Work and the UN
Declaration of Human Rights.
Contract Terms. Sony’s global master purchase agreement with direct products, parts,
components and accessories suppliers in our electronics manufacturing operations entered into
after 2011 require such suppliers to comply with all applicable labor and employment laws and
ethical standards (including laws and standards related to working hours, working conditions,
wages, benefits, employee health and safety, child labor, freely chosen employment, humane
treatment, freedom of association and non-discrimination) and our standard guidelines and
requirements including the Supply Chain Code.

4. Ongoing Monitoring and Assessment of Electronics Manufacturing Operations and
Supply Chain
Internal Leadership. Sony’s corporate social responsibility, procurement and production groups
take the lead in promoting Sony’s responsible sourcing practices, including practices designed to
prevent slavery and human trafficking. Our corporate social responsibility group communicates
with external stakeholders to monitor trends and best practices and our procurement and production
groups are responsible for overall policy implementation in our electronics manufacturing

operations.
Self-assessments.

Assessments and audits are an integral part of our overall supply chain

management process. We conduct a self-assessment utilizing the EICC Self-Assessment
Questionnaire at all of our own electronics manufacturing sites every year to monitor the adherence
to the Code of Conduct and the Supply Chain Code. The self-assessment questionnaires completed
by all 20 manufacturing sites for fiscal year 2015 did not identify any areas of major
non-conformance to our standards.

Pursuant to our internal procedures, in the event any

non-conformance is identified, an improvement plan is put in place to ensure conformance to the
standards set by these Codes.
Supply Chain Assessments and Audits. Since 2008, Sony has also conducted assessments of all
direct electronics suppliers utilizing the EICC Self-Assessment Questionnaire and risk assessment
tool to help us identify suppliers in our electronics manufacturing supply chain who are at risk for
slavery and human trafficking. We use the Questionnaire and risk assessment tool to determine
additional supplier follow-up. For example, if a supplier employs foreign migrant workers, Sony’s
internal procedures provide that Sony will inspect the workplace to determine if such workers are
subject to forced labor, whether dormitory facilities provided to those workers meet international
standards, and whether the working environment is clean and safe. We repeat the assessment each
year for our major electronics suppliers. During our 2015 fiscal year, we completed assessments for
260 suppliers.

From these assessments, we identified 5 suppliers and conducted on-site

inspections at those suppliers’ facilities.
We also review media and NGO reports to help determine our highest-risk suppliers. Our
highest-risk suppliers are required to undergo audits conducted by an independent third party
utilizing the EICC framework for third party audits. This framework includes an assessment of
labor practices.
In the event any deficiencies are discovered during any such assessment and/or audit, the supplier is
required to develop an improvement plan to remediate the deficiencies. Sony monitors the
supplier’s performance against this plan. Sony procedures provide that, if the supplier does not
show satisfactory improvement, Sony will reconsider its relationship with the supplier and may
discontinue new business until the supplier makes the required improvements.
Grievance Mechanism. Sony employees are encouraged to raise any concerns and have multiple
channels to do so, including an ethics hotline that is available in the local language and staffed by
independent third party operators. Sony protects good faith reporters from retaliation. Sony also

operates a hotline for external stakeholders to report violations of the Supply Chain Code.
Sony investigates allegations expeditiously and objectively. If a violation by a supplier is
confirmed, Sony requires the supplier to take corrective action. If a supplier refuses to cooperate
with the audit or take corrective action, Sony’s internal procedures provide that Sony will
reconsider the business relationship. If the violation involves an indirect supplier, Sony’s internal
procedures also provide that Sony will work with its direct supplier to obtain corrective action by
such indirect supplier.
5. Training
All Sony Group employees are required to receive initial and periodic refresher training on the
Code of Conduct to help ensure an understanding of internal policies. The procurement staff for our
electronics manufacturing operations receives additional training on the Supply Chain Code
standards, how to identify risks of slavery and/or human trafficking, and how to conduct an
effective supplier assessment.
During our on-site supplier assessment, our staff members provide training to our suppliers on the
Supply Chain Code and share Sony’s experience on how socially responsible practices benefit
business operations, such as increased productivity and lower turnover.
Pursuant to the delegation of authority approved by the Board of Directors of Sony Corporation,
this Statement has been approved by Masashi Imamura, Executive Vice President and Corporate
Executive Officer in charge of Manufacturing, Logistics and Procurement, and Shiro Kambe,
Executive Vice President and Corporate Executive Officer in charge of Legal, Compliance and
CSR.

Masashi Imamura

Shiro Kambe

Executive Vice President and
Corporate Executive Officer in charge of
Manufacturing, Logistics and Procurement
September 2016

Executive Vice President and
Corporate Executive Officer in charge of
Legal, Compliance and CSR
September 2016



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