Basic Approach

In recent years, stakeholders have grown increasingly aware of how crucial it is that companies fulfill their overall responsibilities throughout their supply chains. Sony takes these stakeholder concerns seriously and is working closely with its suppliers on initiatives in fields such as human rights, labor conditions, health and safety, and environment. These initiatives cover not only Sony’s own sites, but sites throughout the supply chain from suppliers to mineral mining operations, to production sites operated both by Sony and by contract manufacturers.
Each and every director, officer, and employee complies with the Sony Group Code of Conduct and conducts ethical business practices. Sony is committed to upholding fundamental human rights principles such as the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work, and to respecting internationally recognized human rights of people potentially affected by Sony’s business operations throughout Sony’s value chain. This commitment is established by the Sony Group Human Rights Policy.
Based on this approach, Sony has formulated the Sony Supply Chain Code of Conduct and the Supplier Code of Conduct and works with stakeholders to establish responsible supply chains in its electronics and entertainment businesses.

The Sony Supply Chain Code of Conduct in the Electronics Business

Sony was involved in establishing the Responsible Business Alliance (RBA) Code of Conduct, which indicates electronics industry best practice, and adopted that code to establish the Sony Supply Chain Code of Conduct. Sony actively implements efforts to comply with the code for its manufacturing sites, service suppliers providing services to those sites, contract manufacturers and raw materials/parts suppliers. The RBA Code of Conduct has been translated into 28 languages including English, Chinese, Japanese, Thai, and Malay. The fourth edition of the Sony Supply Chain Code of Conduct has been revised to ensure it is in line with version 8.0 of the RBA Code of Conduct, released January 2024.
Raw materials and parts suppliers are requested to agree to comply with the Sony Supply Chain Code of Conduct as part of the contracts signed when Sony begins doing business with them. As a part of the customer requirements under this Code of Conduct, contract manufacturers and raw materials/parts suppliers must comply with the Green Partner Environmental Quality Approval Program and the Sony Group Policy for Responsible Supply Chain of Minerals. Suppliers are also requested to distribute and comply with the Sony Supply Chain Code of Conduct within their own supply chain. In addition, as a founding member of the RBA, Sony also works to strengthen its supplier assessments, ongoing monitoring, and other initiatives.

Supplier Code of Conduct in Entertainment Business

Sony is committed to enhancing Sony Group’s responsible supply chain activities in the entertainment industry in order to strengthen its supplier programs related to standards for human rights, ethical business practices, safety and environment.

• Sony Pictures Entertainment (SPE): In March 2021, SPE established the Sony Pictures Entertainment Supplier Code of Conduct. SPE provides its Supplier Code of Conduct to relevant vendors and business partners as part of the company's onboarding and due diligence processes. The Code outlines SPE’s expectations regarding ethical business practices, integrity, compliance, and sustainability.
• Sony Music Entertainment (SME): In March 2022, SME established the Sony Music Entertainment Supplier Code of Conduct. In January 2025, the Supplier Code was updated to reflect enhanced expectations around responsible sourcing, sustainability, human rights, and ethical business practices across SME’s global supply chain.
• Sony Interactive Entertainment (SIE): In March 2024, SIE established its Sony Interactive Business Principles. The Business Principles set out SIE’s expectations for its partners to conduct business in an honest, ethical and responsible manner. These Principles are provided to relevant partners as part of the engagement process as well as being generally available on the SIE website.

Sony Group Policy for Responsible Supply Chain of Minerals

Some minerals that are used in Sony products carry human rights and environmental risks in the extraction process. In October 2017, Sony established the Sony Group Policy for Responsible Supply Chain of Minerals, replacing the Sony Group Conflict Minerals Policy that was established in 2014. In the policy, Sony pledges that, in order to avoid contributing to conflicts or serious human rights abuses through its sourcing practices, Sony identifies certain minerals that are sourced in conflict-affected and high-risk areas and that are high-risk for Sony from the perspective of corporate social responsibility (“High-Risk Minerals”). Sony’s policy is to refrain from knowingly purchasing any products, components or materials that contain High-Risk Minerals that contribute to conflicts or serious human rights abuses in the chain of custody.

• Sony Group Human Rights Policy [PDF:150KB]
• Sony Supply Chain Code of Conduct [PDF:485KB]
  
• Sony Group Policy for Responsible Supply Chain of Minerals [PDF:282KB]
• Sony Pictures Entertainment Inc. Supplier Code of Conduct
• Sony Music Supplier Code of Conduct
• Sony Interactive Business Principles
• Stakeholder Engagement > Partnership and Participation in Multi-Stakeholder Frameworks

Metrics and Targets

In order to further strengthen efforts to establish responsible supply chains in its electronics business, in addition to its own manufacturing sites, Sony requests that its suppliers comply with the Sony Supply Chain Code of Conduct and carry out thorough assessments to ensure compliance.
Particularly in countries and regions with large numbers of foreign workers, where necessary, Sony visits the manufacturing sites of raw materials and parts suppliers and implements additional on-site assessments, including interviews with employees, as part of its efforts to reduce human rights risks in its supply chains. Sony remains committed to ongoing efforts to raise awareness, educate, and provide training not only to employees, but also across the supply chain, communicating with suppliers to raise awareness and the capacity to respond effectively to responsible supply chain issues. Sony will work with a variety of stakeholders as it continues to strengthen its countermeasures for high-risk minerals in its procurement.

• Enhance assessment systems to enforce strict compliance with the Sony Supply Chain Code of Conduct in the operations of Sony and its suppliers, and enhance additional on-site assessments of raw materials and parts suppliers by trained procurement personnel, particularly those who employ foreign workers
• In addition to training for employees, enhance awareness-raising activities through communication with suppliers with the aim of ensuring responsible supply chains
• Continue to collaborate with various stakeholders to enhance measures regarding the sourcing of high-risk minerals

Organizational Structure

Under the Senior Executive in charge of Sustainability, Sony Group Corporation’s Sustainability Section plays a central role in promoting actions aimed toward creating a more responsible supply chain, cooperating with procurement and other related departments in our businesses, as well as management departments at manufacturing sites.

Electronics Supply Chain Structure

Sony Group Corporation’s Sustainability Section takes the lead in promoting efforts toward a responsible supply chain in cooperation with other related divisions (sustainability, procurement, production, etc.) and management departments at manufacturing sites.
Under the supervision of the Senior Executive in charge of Sustainability, Sony Group Corporation’s Sustainability Section assesses external trends and communicates with stakeholders, drawing on both to formulate basic company-wide supply chain management policy.
The Senior Executive in charge of Sustainability appoints the management responsible in each relevant business unit. They are then responsible for overall operational compliance for the area in their charge, including compliance with the Sony Supply Chain Code of Conduct, as well as risk assessment, regular monitoring and remedial measures.
In cases where assessments or external sources indicate any possibility of violations of the Sony Supply Chain Code of Conduct or a material legal violation, or in cases where the supplier does not provide adequate cooperation with assessments and audits, the management responsible for implementing the rules work together with Sony Group Corporation’s Sustainability Section and Compliance Section to determine the facts and take action deemed necessary, and the situation is reported to the Senior Executive in charge of Sustainability.

Implementation Framework of the Sony Supply Chain Code of Conduct

Main Initiatives in Fiscal Year 2025

Electronics Business

• Conducted assessment using questionnaire at 11 Sony manufacturing sites and at 620 plants of new and existing manufacturing subcontractors and raw materials/parts suppliers
• In addition to regular assessments, additional on-site assessments by procurement department staff from our own local manufacturing sites at supplier factories in countries and regions considered high risk based on the results of previous assessments
• Raw materials and parts procurement personnel received continuous training on Sony’s sustainable procurement policy and related initiatives, human rights risks in supply chains, and social trends
• Donated to Responsible Minerals Initiatives (RMI’s) the Assessment Fund for RMAP Participating Smelters and Refiners

Supply Chain Management in Electronics Business

Sony is engaged in supply chain management that includes the production sites of our suppliers and contract manufacturers in addition to our own electronics manufacturing sites.

Supply Chain for Electronics Products

Sony develops, designs, manufactures and sells a wide range of electronics and other devices, utilizing an electronics supply chain that stretches across the entire globe.

Electronics manufacturing sites at Sony (as of August 2026)

Ratio of Manufacturing Subcontractors and Raw Materials Suppliers by Geographic Region
(Based on FY2025 Transaction Value)

• Note:Major countries and regions that belong to each category
  • Asia-Pacific: Southeast Asia, India, Oceania, Taiwan Region and South Korea
  • Europe / Other Areas: Europe, Latin America, Africa
  The amount is calculated based on the location of the company registration of supplier

Initiatives at Sony Manufacturing Sites

Sony Supply Chain Code of Conduct Notification

Sony has notified all of its manufacturing sites and their service suppliers regarding edition 4.0 of the Sony Supply Chain Code of Conduct, released in 2024. Sony additionally distributes and provides notification to service suppliers and obtains a declaration of compliance when entering into new contracts or revising the Code of Conduct.

Conducting Regular Assessments

As part of its efforts to ascertain Sony manufacturing sites’ compliance with the Sony Supply Chain Code of Conduct, Sony uses standard tools provided by the RBA to check compliance, assess improvements, and implement other monitoring activities.
Specifically, Sony utilizes the RBA questionnaire as an annual self-assessment survey at its electronics manufacturing sites to evaluate compliance designated by the Sony Supply Chain Code of Conduct in terms of labor, health and safety, ethics, environment, and management systems. At manufacturing sites where self-assessment surveys indicate issues with compliance and further evaluation and improvement in these areas are deemed necessary, appropriate measures to improve compliance are developed and implemented. Additionally, we regularly conduct RBA or other equivalent audits at some manufacturing sites.

Fiscal Year 2025 Results

• Self-assessment surveys have been completed by 11 manufacturing sites in Japan, China, Korea, Thailand, Malaysia and the UK. The results showed no manufacturing sites were considered high risk according to RBA criteria.
• Additionally, some of our manufacturing sites in Japan and Thailand have undergone third-party RBA audits, and have all received Silver Status or higher.
• Sony conducted a document-based risk assessment of 118 identified service suppliers that provide services to its manufacturing sites to ascertain their level of compliance with the Sony Supply Chain Code of Conduct. If any compliance issues are revealed, we review the plan for improvement and follow up to confirm progress.

Sony’s Approach to Manufacturing Subcontractors and Suppliers of Raw Materials and Parts

Sony recognizes the increasing importance of global companies’ responsibility to manage their supply chains responsibly as diligent members of society. This extends beyond our manufacturing sites, including those of parts suppliers and contract manufacturers. Sony works with its suppliers to address issues such as human rights, labor conditions, health and safety, and environmental protection throughout its supply chain in order to ensure a responsible supply chain.

Requesting Compliance and Monitoring Compliance Status with the Sony Supply Chain Code of Conduct

Requesting Compliance

Compliance with the Sony Supply Chain Code of Conduct is included in contracts signed when Sony begins doing business with raw materials and parts suppliers. All suppliers are provided this Code of Conduct upon signing a new contract, and are kept informed of changes through updated documents. Further, Sony regularly reminds suppliers of their responsibilities and obtains a declaration of compliance from them. In fiscal year 2024, Sony announced the revised Sony Supply Chain Code of Conduct to its raw materials and parts suppliers. With the exception of some small contractors, Sony requests compliance from all raw materials and parts suppliers and has received declarations of compliance or confirmed declarations of compliance with equivalent standards from 84% of suppliers (percentage based on number of companies). Sony also carries out assessments through questionnaires for suppliers from which declarations have not been received, and requests corrective action based on the results where necessary.
If the primary supplier is a trading company, Sony requires that the trading company ensures their raw material and parts suppliers comply with the Sony Supply Chain Code of Conduct. Sony acquires a declaration of compliance from the parts manufacturer and manufacturing sites through the trading company and confirms that compliance is implemented.

Supplier Assessment

To ascertain supplier compliance with the Sony Supply Chain Code of Conduct, Sony conducts assessments based on the supplier’s risk level for raw materials/parts suppliers and their manufacturing facilities. If Sony does not deal directly with the manufacturing facility, the assessments are conducted through the trading company or manufacturer that is the primary supplier.
If a manufacturer is suspected to be in violation of the Sony Supply Chain Code of Conduct, in line with the nature of the risk, Sony carries out remote or on-site assessments and third-party audits, and employees and managers are interviewed in person to verify the actual situation, and issues instructions for improvement where necessary.
Assessments are similar to those indicated in RBA Validated Assessment Program (VAP) standards, and include contracts and other documentation, working hours, policies, procedures and health and safety verification. In addition, auditors conduct interviews with employees, enabling them to confirm matters such as the payment of employment-related fees and the occupational health and safety environment at plants through direct communication with employees themselves.
If issues are found, guidance for improvement is provided, and we continue to verify and evaluate subsequent actions taken. Sony’s policy is to review its business relationship with a supplier if a serious violation (such as forced labor, child labor, inhumane working conditions, unlawful discrimination, lack of an emergency and disaster action plan, presence of risks that cause a serious life-threatening accident to a worker, significant environmental pollution issues) of the Sony Supply Chain Code of Conduct is confirmed and the supplier fails to cooperate fully in making improvements.

Risk-Based Supplier Assessment

New Suppliers

Sony conducts assessments based on the supplier’s risk level for all new manufacturing subcontractors and raw materials/parts suppliers and their manufacturing facilities. All direct manufacturing subcontractors and raw materials/parts suppliers and their plants are requested to comply with the Sony Supply Chain Code of Conduct. In addition, applicable plants are assessed using RBA questionnaires or the questionnaire on labor, health and safety, environment, and ethics based on the RBA Code.
In this assessment, questionnaires evaluate compliance with the Sony Supply Chain Code of Conduct specifically in items related to forced labor among foreign and migrant workers, which has become a serious issue worldwide. Supplier response is analyzed to identify potential risks for individual manufacturing plants.
We also utilize third-party screening tools to check for human rights violation risks (human trafficking, child labor, forced labor, etc.) at target supplier sites.

Assessment Flow for New Suppliers

Existing Suppliers

Major manufacturing subcontractors that do sizable business with Sony continue to conduct annual assessments using questionnaires from the RBA. If an assessment indicates a high risk, the manufacturing subcontractor supplier is subject to an on-site audit, which may include an audit by a third-party.
Furthermore, with growing stakeholder interest in the issue of forced labor in the electronics industry supply chain overall, Sony has been strengthening activities related to periodic assessment of existing raw materials and parts suppliers for compliance with the Sony Supply Chain Code of Conduct since 2020. Just as for new suppliers, existing suppliers and their plants are categorized by risk level, based on such factors as the country and region in which they are located and size of business to determine if they fit criteria for assessment. Assessment using RBA questionnaires or the questionnaire on labor, health and safety, environment, and ethics based on the RBA Code is conducted for applicable existing suppliers. Supplier response is analyzed to identify potential risks for individual manufacturing plants.

Assessment Results for Fiscal Year 2025

• Assessments using questionnaires were conducted for 620 plants (84 plants belonging to new suppliers, 536 belonging to existing suppliers).
• Sony provided written instructions for improvement to 36 supplier plants suspected to be in minor violation of the Sony Supply Chain Code of Conduct.
• Sony conducted on-site assessments and third-party audits at 30 supplier plants suspected to be in violation of the Sony Supply Chain Code of Conduct and remote assessment of 2 plants suspected to be in violation. In all cases, in the event that violations were identified, suppliers were asked to make a plan for improvement, manage progress and show evidence-based results.
• In addition to remote and on-site assessment by Sony, 110 plants underwent voluntary third-party audits (RBA VAP). It was confirmed that the highest-priority issues have been corrected or that corrective plans have been formulated.

Assessments of New and Existing Suppliers

Top 5 violations identified through remote/on-site assessment (FY2025)

Examples of Instructions to suppliers for Improvement

■ Working hours
Observation: Overtime hours (over 60 hours/week)
Improvement instructions: Requested a plan for improvement of working hours, and continuously monitored until improvements are completed

■ Occupational Health & Safety Risk Assessment
Observation: Occupational health and safety risk assessment not carried out
Improvement instructions: Provided instruction for identifying and assessing occupational health and safety risks in workplaces and requested the documentation of procedures.

■ Emergency Evacuation Training
Observation: Emergency evacuation training not provided within the past year
Improvement instructions: Requested emergency evacuation training be held at least once per year

Example of Remedy for Affected Workers

In fiscal year 2024, Sony confirmed that a third-party Malaysian supplier has violated the Supply Chain Code of Conduct regarding employment and labor. As there has not been significant progress implementing corrective measures requested by Sony, Sony has discontinued sourcing from the supplier. Sony has worked with the RBA to provide financial support to affected workers.

Additional On-site Assessments by Sony Manufacturing Site Procurement Personnel

Since fiscal year 2024 in Malaysia and fiscal year 2025 in Thailand and China, Sony manufacturing site procurement personnel have carried out additional on-site assessments of local suppliers of raw materials and parts. During these additional on-site assessments, personnel visit the supplier and interview staff and inspect production sites to confirm compliance with the Sony Supply Chain Code of Conduct, particularly in areas regarding human rights and labor practices. In fiscal year 2025, additional on-site audits were carried out at 33 plants in Malaysia, 23 in Thailand, and 9 in China. In all cases, in the event that violations were identified, suppliers were asked to make a plan for improvement, manage progress and show evidence-based results.

Communicating with Suppliers

Sony is deeply committed to communicating with suppliers and is involved in a variety of measures to this effect.

Visualizing Supplier Sustainability Efforts

We check for supplier compliance with the Sony Supply Chain Code of Conduct, which includes their efforts for human rights, ethics, environmental and health and safety initiatives, and this oversight is vital to our supplier selection process. In consideration of the fact that supplier sustainability activities will continue to grow more important, we built and began implementing a system to visually identify and centrally manage supplier sustainability achievement (including compliance with the Sony Supply Chain Code of Conduct, reducing the effect on the environment). We communicate the meaning and social significance of these efforts, providing direct feedback to our suppliers to motivate them toward sustainable endeavors and maintain their compliance with the Sony Supply Chain Code of Conduct.

Purchasing Practices

Presenting suppliers with procurement plans and outlooks helps to mitigate negative impact on recruiting and working conditions. Therefore, we provide a six-month procurement forecast with our primary suppliers in order to secure capacity well in advance. The content of these forecasts is reviewed weekly from the start of mass production. The lead time agreed to between the supplier and Sony is registered in the system and a purchase order is issued according to that lead time. Any major changes to the order are discussed with the supplier in compliance with applicable laws and regulations.

Reducing Human Rights Risks for Foreign and Migrant Workers

In recent years, forced labor among foreign and migrant workers at factories that manufacture electronic products and components has been a global issue. Sony carries out assessments of its own manufacturing sites and its suppliers in countries and regions where there is a risk of violations of the Sony Supply Chain Code of Conduct.

Surveys of Employment Status of Foreign and Migrant Workers at Sony Manufacturing Sites

Sony conducts self-assessments regarding the employment status of its foreign and migrant workforce via the RBA questionnaire. The assessments check whether the site has any migrant workers (in either direct or indirect employment) and confirm the hiring processes and labor conditions.

Evaluation of Labor Conditions for Technical Intern Trainees Employed by On-site Contract Manufacturers at Sony’s Manufacturing Site in Japan

Since 2020, Sony has continued to conduct document assessments of a number of domestic on-site contract manufacturers to verify their hiring processes for technical intern trainees in Japan and the countries in which they were hired, as well as the labor conditions of trainees. The results showed that steps are continually being taken to ensure compliance with the labor standards set out in the Sony Supply Chain Code of Conduct overall. This includes the establishment of a new policy on freely chosen employment and recruitment fees for on-site subcontractors who did not previously have such policies in place, or other improvements. In order to prevent technical intern trainees from paying fees, we request that on-site contract manufacturers comply with the Sony Supply Chain Code of Conduct, obtaining a declaration of compliance.

On-site Audits of Supplier Manufacturing Plants

In addition to regular assessment of raw materials and parts suppliers, Sony started carrying out additional on-site assessments of applicable supplier manufacturing plants in sequence in 2024. Matters related to labor practices and employment-related fees are assessed, including through interviews with foreign and migrant workers. In the event that instances of non-compliance with the Sony Supply Chain Code of Conduct are identified through these additional on-site assessments, Sony requests that the supplier concerned implement corrective actions.

Participation in the Responsible Business Alliance (RBA)

Supply chains overlap considerably in the electronics industry, with multiple manufacturers of finished products sharing the same subcontractors and parts suppliers. Accordingly, there are fears that the introduction of independent, company specific standards for socially responsible management will cause confusion and constitute a significant burden on companies in the supply chain.
With the aim of improving processes in the electronics industry supply chain, in 2004 Sony and other companies established the Electronic Industry Citizenship Coalition (EICC, currently the RBA). The alliance then developed the RBA Code of Conduct (formerly the EICC Code of Conduct) incorporating best industry practices.
The RBA is working with its member companies to develop tools that help to establish and manage codes of conduct, Web-based systems, and skills development programs for suppliers. As of October 2025, the RBA consisted of more than 270 participating companies from Europe, the Americas and Asia, and members included manufacturers and OEM companies. The RBA has membership categories for different levels of engagement and has granted Full Member status to Sony, its highest membership category. Additionally, Sony has worked as a member of the RBA Board of Directors from 2020 to 2024.
The RBA promotes corporate social responsibility (CSR) in supply chains through the Responsible Minerals Initiative (RMI), which addresses issues with minerals procurement, the Responsible Labor Initiative (RLI), which addresses human rights issues such as forced labor, and other programs.

• Stakeholder Engagement　Participation in Partnerships and Frameworks
• Responsible Business Alliance

Responsible Sourcing of Minerals

In recent years, stakeholders have become increasingly concerned about violations of the human rights of workers and environmental issues in the sourcing of mineral resources essential for the manufacture of electronic products. Sony is working with its suppliers to address issues related to human rights, labor conditions, health and safety, and environmental protection at production sites, as well as in its procurement of minerals.

OECD Due Diligence Guidance Initiatives

Sony exercises due diligence on the source and chain of custody of High-Risk Minerals in our supply chain to determine supplier compliance with our policy. We follow the Organization for Economic Cooperation and Development (the “OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from conflict affected and high-risk areas (the “OECD Guidance”) or other internationally recognized framework when conducting such due diligence.

Sony Group Policy for Responsible Supply Chain of Minerals and Expectations of Suppliers

In October 2017, Sony established the Sony Group Policy for Responsible Supply Chain of Minerals, replacing the Sony Group Conflict Minerals Policy that was established in 2014. Sony requires its suppliers to source High-Risk Minerals from smelters determined to be compliant with the Responsible Minerals Assurance Process (the “RMAP”)* protocols established by the Responsible Minerals Initiative (the “RMI”), or other smelters that have been determined not to be contributing to conflicts or serious human rights abuses under other trusted traceability projects.

• *Responsible Minerals Assurance Process (RMAP): A program in which a third party certifies that the minerals handled by the smelter are from sources that do not fund armed conflict or engage in human rights violations.

• Sony Group Policy for Responsible Supply Chain of Minerals [PDF:449KB]

Identification of High-Risk Minerals

Sony conducts risk assessments to determine if high-risk minerals could be contained in our products. These assessments are carried out from four main perspectives: legal and regulatory requirements, the importance of particular business activities, requests from stakeholders and social and environmental corporate responsibility (such as child labor, forced labor, indigenous rights, conflicts, etc.). Changes to high-risk minerals are considered based on the results of regular assessments.
Tantalum, tin, gold, tungsten and cobalt were identified as high risk.

Addressing Issues with Tantalum, Tin, Gold and Tungsten (Four Minerals)
Survey and Results on Use of the Four Minerals

The four minerals are commonly found in many products, ranging from jewelry to electronics and airplane components, and enter global supply chains from numerous countries. Determining the mine of origin for these minerals requires the cooperation of many levels of suppliers and intermediaries in the supply chain. Sony is committed to working with suppliers to continuously improve supply chain transparency and reduce risk.
Investigation on the origin of the four minerals used by the Sony Group overall is conducted as follows.
1. Every survey year, Sony checks each business group to see if there is any possibility for the four minerals being used in its products
2. Sony further looks for the presence of the four minerals in the products of the identified business group that are manufactured or outsourced for manufacturing by Sony in the survey year and identifies target products
3. The survey is conducted using the RMI Conflict Minerals Reporting Template (CMRT), the industry standard, and target suppliers are asked to participate by filling out a survey response for each product concerned in order to identify the smelters or countries of origin for the procured minerals concerned
4. The smelters indicated in the survey responses are then carefully compared to the RMI smelters list
In the 2025 survey, Sony identified a total of 330 smelters and refiners as potential sources of the four minerals and, of those, 224 smelters and refiners were compliant with RMAP* or were contained in the London Bullion Market Association Good Delivery List or certified by the Responsible Jewellery Council (RMAP compliant).

• *Includes smelters under RMAP assessment.

Response for Sony Suppliers of the Four Minerals

If it is determined that any of the four minerals are used in the manufacture of products, Sony requires relevant suppliers to comply with the Sony Group Policy for Responsible Supply Chain of Minerals and to fully cooperate with its due diligence efforts regarding sourcing the four minerals in accordance with the terms of this policy. In addition, Sony expects suppliers to have pertinent policies, a due diligence framework and a management system consistent with the OECD guidance in place for products, components and materials delivered to Sony. As a part of these measures, Sony is working to propel action from suppliers who have yet to establish mineral supply chain policy.

Mitigating Risk in the Supply Chain

In the event that Sony confirms that any of its products, components or materials may contain minerals in violation of Sony Group Policy for Responsible Supply Chain of Minerals, Sony, in collaboration with relevant suppliers, shall take actions reasonably necessary to eliminate such minerals from such products, components or materials and shall request that the supplier makes necessary improvement to its sourcing practices.
This includes adoption of a mineral supply chain policy, increased responsiveness and accuracy for surveys on the use of the four minerals, and use of the four minerals sourced from smelters or refiners participating in the RMAP program, or who are otherwise recognized as not contributing to conflict or human rights violations through other trusted mineral traceability projects. Further, in the event that Sony confirms that a supplier has failed to cooperate sufficiently with a due diligence investigation, fails to follow Sony’s requests for remediation or has otherwise violated this policy, Sony shall take necessary actions, including without limitation, termination of business with such supplier by stopping new orders. As part of its efforts to promote RMAP-conformance among smelters, Sony works to encourage smelters identified in its own investigations that are not in compliance with the RMAP to come into compliance.
In 2025, 98 suppliers specified in their CMRT that they source from smelters that were not listed as conformant or were unwilling to undergo an RMAP assessment or similar assessment from a trusted traceability project. As a result of an improvement request by Sony, 52 suppliers conducted investigations and responded that the non-compliant smelters were not in fact in their supply chains, while we continue to request improvement from the remaining 46 suppliers.

Addressing US Law on Conflict Minerals

The Democratic Republic of the Congo (DRC) and adjacent countries have been mired in conflict with armed groups perpetuating human rights abuses in that region. These armed groups have been trading in certain minerals commonly found in that region to finance their activities. Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act in the United States, which first became effective in January 2013, defines the four minerals that are determined to be financing conflict in the DRC as “conflict minerals”. This law seeks to ensure transparency and reporting related to conflict minerals and requires companies whose stock is listed on a US stock exchange, as Sony’s is, to conduct an inquiry into the origin of the four minerals in their supply chains. We have made annual disclosure mandatory since 2014. On May 27, 2026, Sony submitted its 2025 report on supply chain activities to the U.S. Securities and Exchange Commission (SEC).
Of the 330 smelters that comply with RMAP and other standards identified in a survey conducted in 2025, 132 source from the DRC. While it was not possible to confirm the country of origin for all of the four minerals in products, for those which could be identified in supplier reports, none sourced from the DRC could be considered to be contributing to conflict.*

• *Refer to Sony’s report to the SEC, which includes the smelters list confirmed through Sony's traceability program.

• Sony's report filed with the SEC (Form SD & Conflict Minerals Report) [PDF: 599KB]

Managing the Cobalt Supply Chain

Cobalt is an important mineral used in lithium-ion batteries for a wide range of products including electric vehicles and smart phones. There have been concerns about child labor and working conditions at sites where it is extracted in the DRC, a country known to have the largest reserves of cobalt in the world.
In 2016, a supplier reported that some lithium-ion battery parts procured by Sony contained cobalt produced in the DRC. In response, Sony established the Sony Group Policy for Responsible Supply Chain of Minerals in October 2017. This policy is a revision of the Sony Group Conflict Minerals Policy, which targeted the four minerals. In addition to the four minerals, Sony has recognized cobalt as another high-risk mineral and launched efforts to build a responsible cobalt supply chain.
Since then, Sony has continued to manage its cobalt supply chain using industry standard tools, such as the Extended Mineral Reporting Template (EMRT) developed by RMI, and by carrying out further third-party RMAP audits of cobalt refineries.
In fiscal year 2025, Sony conducted EMRT based surveys of eight lithium-ion battery suppliers, identifying 50 cobalt refiners in their supply chains. All companies were confirmed to be in compliance with RMAP or Cooper Mark’s joint due diligence standards. (As of January 2026)

Multi-Stakeholder Collaboration

Sony recognizes that multi-stakeholder collaboration is the key to identifying and mitigating the adverse human rights impact that can be associated with mineral extraction in high-risk areas. Specifically, Sony continuously collaborates with various multi-stakeholder efforts such as RMI in order to participate in the development of the due diligence process and mitigate human rights risks in the supply chain.

Industry Initiatives and the Industry Alliance

For High-Risk Minerals, Sony actively participates in and supports industry groups and alliances that identify the negative effects of mineral mining in high-risk areas, and works to mitigate or prevent these effects.

RMI

In 2011, RBA launched the industry-leading Conflict Free Sourcing Program (CFSP, currently RMAP), then, with the aim of promoting collaboration with other industries and multiple stakeholders outside electronics, established RMI (formerly CFSI) in 2013. Sony utilizes the frameworks developed by these industry groups and alliances as part of its efforts to ensure responsible sourcing of raw materials. RMI holds workshops for discussions with NGOs, socially responsible investors, local government representatives and other stakeholders, in which Sony participates.

• Responsible Minerals Initiative

Japan Electronics and Information Technology Industries Association (JEITA)

The Japan Electronics and Information Technology Industries Association (JEITA) cooperates with RBA/RMI to handle conflict mineral issues. Sony participates in JEITA’s Responsible Minerals Trade Working Group.

• JEITA Responsible Minerals Trade

Donations

Sony donates to the following RMI and NGO-related funds.

• The Assessment Fund for RMAP Participating Smelters and Refiners:
  A fund that helps cover the costs for cobalt refineries to undergo third-party RMAP audits (donated fiscal year 2016-2019, 2021, 2023-2025)
• RMI-Pact Partnership for Supporting Alternative Livelihoods through a Vocational Training Program:
  A program in cooperation with Pact, an NGO that provides vocational support to young people in cobalt mining areas of the DRC (donated fiscal year 2020)
• Better Mining:
  A project in cooperation with the RCS Global Group that aims to improve the health, safety, human rights and other risk areas for mines in parts of the DRC where artisanal and small-scale mining takes place (donated fiscal year 2020, 2022, 2023)

• RBA Foundation & RMI Funds
• SLR Better Mining Impact Report

Educational and Awareness-raising Activities in the Electronics Business

Training for Personnel Responsible for Promoting Responsible Supply Chains

Sony provides training for managers responsible for promoting responsible supply chains at electronics business companies to support deeper understanding of the content of the Supply Chain Code of Conduct and methods of addressing human rights issues in supply chains.

Training and Raising Awareness in Internal Procurement Personnel

Sony implements training regarding socially responsible procurement and the Sony Supply Chain Code of Conduct for procurement department employees.

• *Countries/regions not named are handled in Japan.

Educational and Awareness-raising Activities for Raw Materials and Parts Suppliers

Sony conducts educational and awareness-raising activities to help people better understand responsible supply chains and other Sony sustainability initiatives.

Grievance System, Remediation and Corrective Action

Establishing Contact Points for Suppliers and Stakeholders

Sony has made two contact points available for supply chain issues. Both accept reports via dedicated inquiry forms on their websites. Anonymous reports are also accepted, and we clearly state that reporters will suffer no repercussions for making a report. Sony once again introduced these to all suppliers with whom we do above a certain amount of business with via a video distributed in fiscal year 2023, requesting that all employees and upstream suppliers also be informed. Sony notified suppliers regarding the Grievance System for Sony Group Electronics Supply Chain once again when it announced revisions to the Supply Chain Code of Conduct and requested a declaration of compliance in fiscal year 2024. Sony also informs new raw materials and parts suppliers of the grievance system alongside its request that suppliers comply with the Sony Supply Chain Code of Conduct when they start doing business with Sony. In addition, supplier employees who take part in interviews during additional on-site assessments of raw materials and parts suppliers are also informed of the grievance system.

Supplier Hotline

Sony has established a Supplier Hotline which suppliers may use to report conduct by a Sony Group company executive or employee that violates laws, regulations, the Sony Group Code of Conduct, or the Sony Supply Chain Code of Conduct, as well as conduct that violates the company’s agreements with suppliers as a framework to facilitate sharing of concrete information.

• Sony Group Portal Website | Supplier Hotline (in Japanese)

Grievance System for Sony Group Electronics Supply Chain for Reporting from a Broad Range of Stakeholders

Sony established the Grievance System for the Sony Group Electronics Supply Chain for relevant stakeholders in the electronics supply chain, including manufacturers and suppliers of parts, raw materials, manufacturing equipment, etc., their employees, and other related parties in March 2024. A dedicated online inquiry form is provided to report any actions across the electronics supply chain that violate or may violate the Sony Supply Chain Code of Conduct or the Sony Group Policy for Responsible Supply Chain of Minerals. Japanese and English are supported, and strict confidentiality is enforced.

Results (FY2025)

• *Includes reports regarding the same incident.

When a report related to the Sony Supply Chain Code of Conduct is received, Sony carries out an investigation to establish related facts, including by visiting and interviewing suppliers. If Sony determines that corrective actions are necessary as a result of the investigation, it will take reasonable corrective action as appropriate. In fiscal year 2025, steps were taken by Sony regarding reports related to workplace environments by requesting that the supplier concerned take corrective action, carrying out site visits, and confirming that improvements have been made.

• Establishment of the "Grievance System for Sony Group Electronics Supply Chain"

Responding to External Reports

In cases where any possibility of violations of the Sony Supply Chain Code of Conduct is reported via external sources, such as NGOs or media reports, we work expeditiously and objectively to confirm facts regarding the report, including an RBA audit by a third-party auditor.
If this determination confirms the reported violations at our manufacturing sites, Sony ensures that corrective action is immediately taken. At supplier plants, Sony requests the prompt creation of an improvement plan and the implementation of action based on that plan. We request progress reports for implementation of these plans and check further by conducting follow-up audits as needed. In cases where any possibility of violations is reported at a secondary supplier, Sony works with the primary supplier to ensure that remedial action is carried out. Sony’s policy is to review its business relationship with a supplier if a serious violation of the Sony Supply Chain Code of Conduct is confirmed and the supplier fails to cooperate fully in making improvements.