Establishing and Implementing the Sony Group Policy for Responsible Supply

Chain of Minerals

Some of the minerals used in production by Sony carry environmental risks along
the extraction process and is promoting human rights. Sony is maintaining its full
commitment to the ethical business conduct and always promoting human rights found
in their Sony Group Code of Conduct which covers their core values and implement
basic policies just like exclusion of any form of forced labour among its employees.
Sony also anticipates all of their electronics manufacturing sites and suppliers to follow
the same standard and implement the Sony Supply Chain Code of Conduct. All of their
suppliers are asked to comply with the Code given to them. In October 2017, Sony
established their Sony Group Policy for Responsible Chain of Minerals.

As stated in the policy, Sony promised that for them to avoid worsening the
problems or human rights abuses through its sourcing practices, they identify certain
minerals that can be the source of conflict and high risk areas from the point of view of
the corporate social responsibility (High-Risk Minerals). One of their policies is to stop
purchasing any products or materials that is considered to be High-Risk Minerals that
can be the cause of problems or serious human rights abuses in their chain of custody.
They identified these elements as High-Risk Minerals, namely: tantalum, tin, gold,
tungsten, and cobalt.

To be sure that they are complying with the policy they are requiring their
suppliers to source minerals from smelters that is determined that has no contribution to
trigger a problem. They designed an internal due diligence framework to determine the
origin and chain of custody of all the high risk minerals in their supply chain. This
framework is designed to follow to the OECD Due Diligence Guidance for Responsible
Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

They actively cooperate with industry groups and involve in multi-stakeholder

processes. As a member of the Responsible Minerals Initiative (RMI) made by the
Responsible Business Alliance (RBA), they supports RMI’s exertions to measure the
environmental and impact of it socially in the extraction and processing of raw materials
and lessen these impacts.

Sony's stakeholders are concerned with sustainability issues, as well as for

ethics and respect for human rights and the environment, when it comes to raw
materials procurement. Sony partners with its suppliers to address issues of human
rights, working conditions, health and safety, and environmental protection at
manufacturing sites, as well as raw material sourcing.
To strengthen efforts to establish a sustainable and responsible supply chain,
Sony Corporation is committed to executing its activities in a socially and
environmentally responsible manner, and to sourcing from suppliers that share their
values.
As part of their ongoing sustainability efforts in mineral sourcing, they collaborate
with their suppliers to help ensure fair and responsible procurement of the minerals
used in the products and resolve concerns related to human rights, working conditions,
health and safety, and environmental conservation in their supply chain. We also
believe that simply removing trade from conflict-affected and high-risk areas will not be
the optimal approach to help solve these issues, and they should adopt alliances with
governments, non-governmental and business organizations, as well as suppliers, to
proactively assist in the efforts to achieve a workable solution.
The Sony Group Code of Conduct (Ethics)

Sony promotes innovation through its dedication to conducting business ethically

and responsibly. The ethical culture of Sony is based on responsibility for the core
ethical values of Fairness, Honesty, Honor, Respect and Responsibility that govern how
Sony staff work with colleagues, business partners and the communities where Sony is
doing business to fulfill Sony's mission & values.

The Sony Group Code of Conduct is the core of Sony's ethics and compliance policy
and underlines a common responsibility to strengthen and advance the ethical culture of
Sony and protect the reputation of Sony. The Code refers to all members, officers and
employees of Sony's boards ("Sony Group personnel").

Sony’s Core Ethical Values

Sony updates the Code from time to time as part of its ongoing effort to maintain
the effectiveness of the Code, and to provide clear guidance and resources on relevant
issues. Sony also acknowledges its responsibility as a member of a global society and
the Code reflects the principles laid down in global ethical guidelines. (among others):

 Organization for Economic Co-operation and Development (OECD)

Guidelines for Multinational Enterprises
 The United Nations Global Compact

 The United Nations Universal Declaration of Human Rights

 The Guiding Principles on Business and Human Rights and Sustainable

Development Goals (SDGs)

Internal Control

Sony also participated in the creation of (and updates of) and follows the
principles in Keidanren's Charter of Corporate Conduct (Japan Business Federation), an
association of leading companies in Japan. The Code also embodies those standards.
The Code ensures that in every aspect of its business operations, Sony must be faithful
to its core ethical values, and provides guidelines on key risk areas.

 Accurate recordkeeping

 Anti-corruption/bribery

 Antitrust / fair competition

 Avoiding conflicts of interest

 Diversity / discrimination / equal employment opportunity / fair employment /

proper workplace conduct
 Fair dealing (fair business practices)

 Privacy (e.g., data privacy of employees, customers, consumers) and cyber

security
 Protection of human rights

 Financial integrity and anti-fraud

 Speaking up / no retaliation

 Tax law compliance

 Workplace health and safety

The Code was adopted by the Board of Directors of Sony Corporation and by
senior management at all Sony Corporation affiliates (the "Sony Group" or "Sony Group
Companies"). Sony Group leaders are responsible for promoting the Code as part of a
continuing commitment to enhancing Sony's ethical decision-making culture.

The Code, which is available on Sony's website and on the intranet of each Sony
Group member, has been translated into 23 languages to help ensure that employees
and relevant third parties understand it clearly. Sony will give additional translations as
may be needed by changing demographics of the workforce.

All employees of Sony Group and selected third party workers are required to
complete Code of Conduct training within 90 days of hiring or commencing service
provision. Sony also conducts in-depth refresher training on at least one subject of
Code of Conduct each year, with additional tailored training being given more regularly
depending on the risk assessment performance.
Conducting Regular Assessments (Governance)

As part of its efforts to evaluate the compliance of Sony's manufacturing sites

with the Sony Supply Chain Code of Conduct, Sony uses common tools offered by the
Responsible Business Alliance (RBA) to track enforcement, identify progress and carry
out other monitoring activities. In particular, Sony uses the RBA questionnaire as an
annual CSR self-assessment survey at all its electronics manufacturing sites in and
outside Japan to determine compliance in five categories set out in the RBA Code of
Conduct: Labor, Health and Safety, Ethics, Climate, and Management Systems.
Appropriate measures are developed and implemented at manufacturing sites where
self-assessment surveys suggest compliance issues and further evaluation and
improvement in these areas are deemed necessary. In fiscal 2018, 16 manufacturing
sites in Japan, China, Korea, Thailand, Malaysia, UK, Mexico and Brazil completed self-
assessment surveys. The results showed that the probability of non-compliance at all
fabrication sites was low. Where potential violations of the Sony Supply Chain Code of
Conduct are documented by external sources, such as NGOs or media reports, the
fraud site in question defines the facts of the case. If this finding confirms the identified
violations, Sony must ensure appropriate action is taken, including an RBA audit
performed by a third party auditor.

International businesses are under mounting social pressure to undertake due

diligence on human rights for their supply chains. For example, in order to avoid
contemporary forms of slavery such as forced labor in supply chains, the UK introduced
the Modern Slavery Act. In particular, Malaysia has many foreign workers who are
employed at electronic products and component manufacturing facilities. An
international non-governmental human rights organization has issued a report citing
forced employment conditions among foreign workers in the electronics industry in
Malaysia. The practices mentioned include employees being charged with excess
promotions on hiring and potential employees retaining passports for workers, making it
difficult for workers to get back their passports when they need them. These conditions
limit the freedoms of foreign workers living far away from their country of origin, resulting
in forced labor situations.

Sony also employs large numbers of foreign workers at its Malaysian production
sites. In response to social concerns over forced labour, Sony commissioned a third-
party assessment in fiscal 2016 that included a fact-finding survey and risk identification
of foreign workers ' employment and their working conditions at Sony manufacturing
sites in Malaysia. The evaluation was carried out by the non-profit Business for Social
Responsibility, which offers research and advisory services related to corporate social
responsibility to its member companies.

The third-party evaluation was carried out by management interviews, HR

department employees, and foreign workers from Indonesia, Nepal, Myanmar, Vietnam,
and Bangladesh, as well as interviews with temporary staffing agencies serving as
intermediaries for foreign workers whether in their countries of origin or in Malaysia.
Staff from the CSR department in Japan were sent to Malaysia to observe the
evaluation covering the entire process from pre-employment (before leaving home) to
actual recruiting and post-employment conditions (after expiry of the employment
contract). The assessment found no cases that qualified as serious legal breaches, but
established several areas that Sony is actively working to fix for change. For example,
the evaluation found that living conditions could be improved for foreign workers
recruited through temporary staffing agencies in terms of dormitory cleanliness, living
space given and surrounding environment. Sony partners with temporary staffing
agencies to strengthen by initiating follow-up visits to dormitories, and identifying
agencies that have made significant progress and sharing their efforts among agencies.

Most foreign workers, including skilled interns, are working across diverse
sectors in Japan, including manufacturing, agriculture, forestry, fisheries, and
construction, as well as caregivers. With the rise in media coverage, claims of foreign
worker oppression have been recognized as a significant social issue in Japan. Since
fiscal 2017, Sony has been performing surveys of actual work situations and risk
evaluations to track the job status and working conditions of foreign workers at Sony
manufacturing sites in Japan. With the increase in media coverage, allegations of
exploitation of foreign workers have been identified as an important social issue in
Japan. Sony has been conducting surveys of actual work cases and risk assessments
at Sony manufacturing sites in Japan since fiscal 2017 to monitor the employment
status and labour conditions of foreign workers.