Making behavioral guidelines in accordance with the times that are easy for everyone to understand, use, and act accordingly

The Code of Conduct, which was first created nearly twenty years ago, contained all the basic rules of what should be done and was designed to be easy to understand. However, there have been many advances in society, including technology and other areas, that have led to various changes in the six years since the last revision in 2018.

"For example, when we talk about our advertising and sales, what was being done in the old days of TV commercials is completely different from what we are doing in today's data-driven digital marketing. Technology is also changing rapidly, and what is acceptable and what is not can have a significant impact on how to run a real business."

In light of these changes, the Code was made to reflect the current trends of the world and technology in order to make behavioral guidelines in accordance with the times. The entire content of the Code was reviewed, resulting in adding new items such as "Use Technology Responsibly," to address the ethical implications of advanced technology, which has been the subject of recent discussion.

Over time, Sony's business portfolio has changed as well. In 2003, when the first Code of Conduct was formulated, Sony's business was focused on electronics, but today various entertainment businesses account for more than half of Sony's sales. The members involved took into consideration the diversity of Sony's businesses as they worked to make a Code of Conduct that employees in all business units around the world can easily understand, follow and act appropriately.

"The previous Code of Conduct still had parts written in a way that made people think of electronics, but now, it needs to be balanced with our six main business segments. We paid attention to the wording in such a way that the people in each company could see it as their own."

Hattori also explains that, in the world of corporate compliance, having a set of rules that everyone follows will help protect the company and its employees in case something happens, however, it is no longer good enough to just have the rules. There is a recent trend to make such rules easy for employees to use, understand, and follow and act, and thus the rules are generally becoming simpler. Therefore, with the full support of the compliance officers in regions and businesses and members of the relevant departments, the language of the Code was discussed, reviewed and rewritten multiple times.

"We agreed that we should outline important principles, and also add supplementary information so that people can take actions accordingly in each business situation, and discussed what guidance would be more useful, such as ‘If you have any concerns regarding advertising and marketing, please contact your legal department.'"

Passing down a culture that values trust

Hattori, who joined Sony two years before the Code of Conduct was issued, remembers the then-legal executive, whom she greatly admired, writing the code himself in his office.

"I am very grateful and feel fortunate to become involved in the revision work. The code was written by someone who made me think, ‘If I could be like him, I would really enjoy being in legal work.'"

In revising a work with such legacy, Hattori and the other members were conscious of maintaining a sense of continuity.
"The Code of Conduct was established in 2003. It was documented then, but Sony's emphasis of trust in its brand and its culture of ethics goes back even further."

In considering how to convey this sense of continuity, the members came across the words of Morita. Hattori recalls that finding an internal speech from Morita that appeared in the company's newsletter "Times" in 1990 was one of the most memorable moments of the project.

"We thought the founders must have said something about our ethical culture, and we researched and found this speech. All of these words resonate with those of us who work in compliance. Of course, Sony's present is important, and we must move forward into the future, but I would like to bring attention to how Sony's culture, which is full of positive energy, has been carried forward from the past through our Code of Conduct."

Revision as a starting point

One of the responsibilities of the Ethics & Trust Department is to prevent corporate fraud within Sony Group. Having spent her career in the legal and compliance field and having been exposed to many cases both internally and externally, Hattori is determined to help prevent fraud.

"It is possible that something done by someone somewhere in the Group could seriously damage the Sony brand as a whole. I would never want that to happen. However, I think it does not match with our culture to be too restrictive and tell people ‘don't do this' or `don't do that.' As stated in Sony's Purpose & Values, we are a company that thrives on positive power and creativity, so I believe that delivering the values that Sony has cherished, such as trust in the brand and ethics, through a Code of Conduct along with that positive energy is more likely to inspire good employee behavior."

Hattori also emphasizes that the starting point is now, after the revisions have been completed.

"I believe that people reading the Code of Conduct and thinking about its contents will spark new discussions and make employees more familiar with the importance of trust in brands and ethics. We encourage all employees to read the Code of Conduct and use it as an opportunity to reflect on what they should do. We also hope that people outside the company will see that our actions are based on these values, that we value your trust, and that we care about building long-term relationships."