CODE OF CONDUCT

Dear Colleagues,

Ethical business conduct and compliance with applicable laws and regulations are fundamental aspects of our corporate culture. We are committed to uphold the highest professional and ethical standards in everything we do; especially the way we conduct our business. We also seek to create a workplace that reflects our core values.

We recognize that our employees may sometimes be faced with difficult ethical decisions in the workplace; therefore, we have provided this Code of Conduct to serve as a guideline to take those decisions. Each employee's decisions help shape and protect our brand, our Company and our reputation. This Code of Conduct applies to everyone who is associated with us, be it an employee, freelancer, supplier or a vendor. Failure to abide by these guidelines will lead to disciplinary action, including dismissal, where appropriate.

If you have any questions or concerns about business conduct issues, including possible violations of the Code of Conduct, you should promptly seek the advice of your immediate supervisor, department head, HR or our Ombudsperson. The Ombudsperson's role is to understand, address and initiate investigation, for concern(s) relating to or violation(s) of the Code of Conduct while maintaining employee confidentiality. Currently, the Ombudsperson for SPN is Ashok Nambissan - General Legal Counsel. Employees can reach Ashok Nambissan directly at (Ashok.nambissan@setindia.com / 91-22-67081106). If you report, in good faith, what you suspect to be illegal or unethical activities, you should not be concerned about retaliation from others. Any employee involved in retaliation will be subject to serious disciplinary action by the Company.

Thank you for helping to preserve our most important asset - 'our reputation'.

N.P.Singh, MD & CEO,
Sony Pictures Networks India

 

I. Sony Pictures Networks India Private Limited - Code of Conduct

Sony Pictures Networks India Private Limited ("SPNSPN" or "Company") has developed a Code of Conduct for its employees, to adopt a consistent approach on key professional conduct issues at the workplace and provide clarity on SPN's core values and principles.

This Code of Conduct is an integral part of the employment/engagement contract between SPN and every stakeholder as mentioned below.

Any violation of the Code of Conduct is viewed seriously and may lead to disciplinary action including possible termination of employment/engagement.

II. Who must follow the Code of Conduct

The Code of Conduct is mandatory for all employees, either full time or part time, temporary or ad hoc staff e.g. probationers, trainees, apprentices and workers engaged through an agent or contractor and other stakeholders e.g. agents, vendors, contractors, consultants, joint ventures and subsidiary companies. All such individuals are required to undergo relevant training and refresher courses as and when mandated by the Company.

Employee Responsibility:

• Must read, understand and adhere to SPN's Code of Conduct.

• Confirm that they understand and acknowledge their commitment to the letter and the spirit of the Code of Conduct and Company policies; and that they are not aware of any violation to the best of their knowledge.

• Seek help from the department head, HR or the Ombudsperson when in doubt about the application of the Code of Conduct.

• When faced with an ethical dilemma, consult the Ombudsperson for better understanding on how to resolve such dilemma.

• Highlight instances of possible violation of the Code of Conduct to the department head, HR or the Ombudsperson.

• Co-operate in investigation(s) into reported violations of the Code of Conduct.

III. Equal Employment Opportunity

SPN is an equal opportunity employer i.e. Employment at SPN is based solely on merit and is not influenced by race, colour, religion, national origin, marital status, gender or age.

Employees are treated with dignity and in accordance with the Code of Conduct. SPN promotes an environment free of harassment whether physical, verbal, psychological or sexual.

SPN does not use any form of forced or involuntary work. SPN does not use "child" labor. The term "child" refers to a person who has not completed fourteen years of age. SPN adheres to all applicable laws and regulations regarding performances of children on its programmes.

SPN strives to be an employer of choice by providing a fair work environment which is free from any kind of discrimination and harassment.

Employee Responsibility:

• Use merit, qualifications and other job related criteria as the sole basis to select, recruit, hire and advance a qualified person without regard to the race, colour, religion, national origin, marital status, gender or age.

• Provide a work environment free from any form of harassment.

• Report any violation to the department head, HR or the Ombudsperson.

IV. Professional Work Environment

SPN is committed to provide a safe, orderly, inspiring, diverse and tolerant work environment.

Employee Responsibility:

• Grant others the same respect, co-operation and dignity as you wish for yourself.

• Encourage ethical behaviour.

• Dress professionally at work and outside office whereever you represent SPN.

• Maintain professional order around one's area of work and surroundings.

• Ensure that the work environment is free of any form of harassment or intimidation.

• Be courteous and respectful of individual sensitivities while communicating with others and do not use abusive or disrespectful forms of communication.

• If you feel that you or your colleague is a victim of harassment, report the matter to your manager/department head, HR or the Ombudsperson immediately.

• Do not smoke or consume any form of banned substances in or around office premises / no smoking zones.

• Consume alcohol in moderation at social gatherings, functions and other occasions in connection with the Company's work or at events sponsored by the Company.

• Ensure that you or colleague(s) do not drink and drive when leaving Company events. Behave responsibly in public areas.

• Carry the Company provided identity-cum-access card at all times during office hours and produce this for verification at the request of the Company staff.

V. Anti-Sexual Harassment

SPN does not tolerate any kind of sexual harassment including discrimination subtle or quid pro quo or otherwise, at the workplace or with other colleagues and stakeholders and violators will be subject to disciplinary action.

SPN has therefore formulated an Anti-Sexual Harassment Policy ("Policy") in accordance with the laws applicable in India, including but not limited to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("the Act"). This Policy lays down the procedure/s for making and responding to any complaints of Sexual Harassment at Workplace and is applicable to all the employees of the Company.

"Sexual Harassment" as per this Policy means and includes (but is not limited to) any one or more of the following unwelcome acts or behavior (whether directly or by implication) namely:

• Any physical contact and/or advances in a way that may make an employee feel uncomfortable, including but not limited to patting, pinching or intentional brushing against another's body; or

• Demand or request for sexual favors; or

• Leering, i.e., staring in a sexually suggestive manner, or

• Making sexually colored remarks, about looks, clothing, body part; or

• Telling sexual or lewd jokes, hanging sexual posters, making sexual gestures, etc., or

• Teasing, innuendos and taunts having sexual overtones,

• Showing pornography; or

• Sending, forwarding or soliciting sexually suggestive letters, notes, emails, text messages, images, instant messages including via Facebook, Twitter, WhatsApp or any other medium; or

• Any other unwelcome physical, verbal or non-verbal conduct of a sexual nature; or

• Any act of a sexual nature by an Offending Employee which interferes with an Aggrieved Employee's work or creates an intimidating, offensive or hostile work environment or humiliating treatment which might affect the physical/mental health and/or safety and/or reasonable apprehension about the career prospects of the Employee who is subjected to such acts.

• Any of the above acts coupled with the implied or explicit promise of preferential treatment, or threat of detrimental treatment, or threat about present/future employment status for sexual favors.

"Workplace" will include the office premises, any place visited by the employee arising out of or during the course of employment including and not limited to transportation provided by SPN for undertaking any journey, off sites and conferences.

Any act of reprisal towards the complainant, witnesses or others involved in the investigation is subject to disciplinary action.

Malicious or frivolous complaints of sexual harassment may result in disciplinary action being taken against the complainant.

An Internal Complaints Committee ("Committee") will handle sexual harassment complaints. The Committee shall address any sexual harassment complaints across the Company including any complaint(s) received from any branch/administrative offices.

If the Committee concludes that the offence of Sexual Harassment has taken place and disciplinary action is warranted, appropriate action will be taken against the offender, including possible termination of employment/engagement and prosecution, if any, under the Policy and as per applicable laws.

Please refer to the Anti-Sexual Harassment Policy for further details available on Insight.

Employee Responsibility:

• Respect other colleagues' personal dignity and contribute to a safe and professional work environment.

• Avoid causing discomfort or harassment of any nature to other colleagues, knowingly or unknowingly.

• Read, understand and follow the Policy guidelines on dealing with sexual harassment.

• Immediately report any instances of sexual harassment only to the Committee.

VI. Financial Reporting & Records

SPN follows prudent financial accounting norms as per government regulations and/or notifications issued by the Institute of Chartered Accountants of India and complies with applicable accountancy and financial disclosure norms. Deviations, if any, are clearly highlighted and adequately explained.

The knowledge or act of deliberate falsification of any financial reports or records may be the basis for immediate discharge and may subject an employee to civil and criminal actions as well. Dishonest reporting of information to government entities, third-party organizations and people outside SPN, including false, misleading or artificial entries in the Company's books and records that may serve as the basis for such reports, is strictly prohibited.

Employee Responsibility:

• Follow SPN's accounting procedures as well as all generally accepted accounting principles, standards, laws and regulations, accounting and financial reporting of transactions, estimates and forecasts.

• Maintain complete, accurate, timely records and accounts to reflect all business transactions.

• Desist from disclosing information regarding the financial health of the Company to any third person other than through an authorized person within the Company.

• Provide timely, candid forecasts and assessments to management.


Never destroy, alter, falsify or conceal records for the purpose of obstructing or influencing an ongoing, pending or reasonably anticipated lawsuit or government investigation.

• Ensure all costs and expenses incurred are accurately recorded in the books of accounts.

• Do not conceal information from auditors.

• Do not approve any fraudulent expense or prepare documents supporting it.

• Disclose vital information that might have a bearing on the Company's business to the supervisor/department head or to those employees who are authorized to be informed only.

• Preserve all the relevant Company's records including paper documents, email, and other electronic files, that can be sought by summons or otherwise in an ongoing or anticipated lawsuit or government investigation.

• Contact the legal department immediately on knowing of any financial irregularity relating to the Company's business, any actual or threatened lawsuit or investigation involving the Company.

VII. Regulatory Compliance and Adherence to Anti-Bribery Laws

SPN ensures that adherence to all laws is mandated at all its locations, and by all its employees, vendors, contractors, suppliers, associates and affiliates. Every employee, vendor, supplier, associate and affiliate in the course of the business, must comply with all applicable laws or regulations, in all the territories in which they operate. If the ethical and professional standards set out in the applicable laws and regulations differ from that of the SPN Code of Conduct, whichever prescribes a higher standard of compliance shall prevail.

Prevention of Corruption Act ("PCA") prohibits giving bribes in any form, whether in cash or kind, to government officials, public servants or officials of any public body. It prohibits a public servant from accepting gratification other than legal remuneration in respect of an official act. It is also an offence to influence a public servant by giving any kind of gratification.

Foreign Corrupt Practices Act ("FCPA") contains several prohibitions, including the making or offering a payment (bribe) in any manner (be it cash or in kind) to any government official and/or any representative of a government organization for the purpose of influencing any action that can result in the Company obtaining favorable treatment or lead to improper accounting of Company's funds.

The UK Bribery Act prevents offering, promising, or giving a bribe to a person (including private parties), receiving or accepting a bribe, offering, promising, or giving a bribe to a foreign government official with intent to influence the performance of his or her functions as a public official to retain business or obtain business advantage.

Employee Responsibility:

• Comply with the provisions of the above Acts as applicable.

Be aware that the Code of Conduct applies to all persons associated with SPN including vendors, suppliers and contractors, etc.

• Do not authorize third parties e.g. vendors, agents, etc., to give gifts or make any unauthorized payments on behalf of the Company.

• Respect and abide by the laws of the land.

• Do not offer or receive bribes in any form whether in cash or kind.

• In case the standards of any applicable law are at variance with the SPN Code of Conduct, keep management informed and follow whichever prescribes a higher standard of compliance.

• Do not make any payment to induce or influence any government official to direct undue business to SPN or to SPN's vendors, suppliers and contractors.

• Immediately report situations that may violate any laws or for that matter the Code of Conduct to the department head, HR or the Ombudsperson.

• Do not have apprehensions about any adverse consequences from such reporting.

• Co-operate in investigations of any violation of the Code of Conduct.

VIII. Copyright & Software Compliance and Handling Company Assets

Company policy is to respect copyright laws. All materials including computer software used by SPN must always be legally licensed for use by SPN and its employees. Copyright laws and Company policy prohibit individuals from making copies of software programs they use at work for their personal use, distribution or use and display of a copyrighted work without the prior permission of the copyright owner. The restrictions also apply to software and written material, and extend to making derivative works or compilations of any copyrighted material. Employees must not use their office computers and laptops to stream, download or store content that is obscene, illegal or that infringes copyright.

Company assets include but are not limited to:

• Physical (tangible) assets;

• Intangible assets / intellectual property rights arising out of research and development in the form of patents, trademarks, copyrights, trade secrets, ideas, logos and other proprietary information; and

• Electronic data, software, etc.

SPN reserves the right to monitor and inspect how its assets are used by its employees, including inspection of e-mail, voicemail, data and files kept on computers or other network terminals, as well as desks, file cabinets, lockers or offices.

Employee Responsibility:

• Read, understand and follow the Company's IT Policy.

• Take reasonable precaution to ensure that the Company's assets including computers/ electronics systems and other items are protected at all times.

Ensure that intellectual property rights of others are not being used without proper authorization and appropriate written agreements and be aware that any such violation may result in liability to the Company.

• Do not misuse Company's resources, information, intellectual property, time or facility including office equipment, email and computer applications.

• Follow the Company's policies with respect to the usage of Company property and use only the Company's official network and systems for all Company related work and communication.

• Do not use the Company's stationery in communication involving personal or non-SPN business.

• Report loss or theft of any Company equipment to the IT / Admin department immediately.

• Do not access proprietary, privileged or sensitive information in an unauthorized manner.

• Do not use Company's assets, computers and electronic systems for personal usage, including sending emails. However, nominal use of Company assets for social media or for sending personal emails is permitted on the condition that the Company may access these emails if it thinks appropriate in its sole judgment.

• Do not access websites of objectionable nature.

• Do not download intellectual property except from authorized legal sites.

• Do not install freeware or other unauthorized software on to Company owned computers without the prior approval of the IT department.

IX. Social Media Responsibility

SPN shall be the owner of any account created on any social media platform in its name. Any social media account created by an employee or any agency at the instruction of an employee for the business of the Company shall be in the name of the Company and/or its affiliates or in the name of any of its shows or channels and its ownership shall belong to the Company at all times.

Any social media accounts in the name of the Company, its shows or channels may be created only after obtaining prior written approval from the concerned department head and in compliance with the applicable policy on social media.

Employee Responsibility

• Read, understand and adhere to Company's guidelines on the usage of social media.

• Exercise discretion while describing the association with the Company or the work you do on your personal social media accounts.


X. Insider information and Money laundering

Insider information refers to the use, by any person or groups of persons, of any data, document or information, whether electronically disseminated or not, which is not within the public domain to gain an unfair advantage that may result in a monetary gain to any individual, group of individuals or non-Company entities involved.

Information that may be considered as Insider information includes, without limitation, the following:

• Acquisition & divestiture of businesses or business units;

• Financial information such as profits, earnings, dividends, etc.;

• Announcement of new projects, product introductions or developments;

• Asset revaluations, investment decisions/plans; ï‚· Restructuring plans, major agreements; and ï‚· Raising finances.

Employee Responsibility:

• Data generated internally within the Company at any point in time should not be discussed, shared with non-Company entities/persons without the prior written approval of the department head.

• Do not respond to any query from reporters or the press without management authorization. Such queries must immediately be referred to the designated person responsible for public relations or the designated department / business head.

Money laundering refers to the transaction, movement or deposit of non-accounted money that, if declared, may attract penal provisions of applicable laws.

Monetary transactions should be undertaken by way of cheques, demand drafts and other legal instruments of payments so that sources of origin can be traced at any time. Cash transactions for official purposes should be avoided unless absolutely essential or necessitated due to emergencies and, in any event, not without prior written approval of the department head.

Employee Responsibility:

• Comply with all applicable laws that prohibit money laundering and require the reporting of cash or other suspicious transactions.

• Follow the Company's guidelines regarding acceptable forms of payments.

XI. Customer, Vendor and Supplier Relationships

SPN maintains its relationships with customers, suppliers and vendors on lawful, efficient and fair practices and expects the same from them. The Company strives to ensure that all transactions with customers, suppliers and vendors should be based on parameters that are internally determined but are transparent and subject to both internal as well as external scrutiny.

Some indicative parameters on which the customers, suppliers and vendors should be evaluated are as follows:

• Price

• Quality

• Service capabilities

• Technical superiority

• Track record with the Company

The Company's interests in any business transaction must be placed ahead of any personal interests. Wherever applicable, the Chart Of Financial Authority ("COFA") and the Company policy on vendor selection must be followed. Exceptions, if any, require prior written approval of the department head.

Employee Responsibility:

• Do business only with customers, suppliers and vendors who comply with applicable laws and Company standards relating to labour, environment, health & safety, intellectual property rights and proper payments.

• Do not demand or accept payments, gifts or other benefits.

• Comply with the Company's set parameters while evaluating customers, suppliers and vendors.

XII. Governmental Relationships and Interactions

SPN, during the course of its business, may deal with government (local, state or central), semi-government and quasi-government agencies.

SPN complies with the norms prescribed by such government agencies for doing business with them and does not offer or give Company funds or property as donations to them or to their representatives, directly or through intermediaries, in order to obtain any favorable performance of official duties.

Cash transactions with government, regulatory bodies, public sector companies and other related bodies without official receipts for services rendered are strictly prohibited.

Only certain individuals designated by the Company are authorized to express the Company's views on legislations, regulations, government actions, notices, etc.

Employee Responsibility:

• Comply with the Code of Conduct on dealing with government officials and representatives.

• In case of any doubt, seek guidance / advice from the Ombudsperson.

• Do not promise or offer payments, gifts or other benefits to any government official or representative in lieu of an undue favor.

• Immediately report any deviation from the above norms.

XIII. Gifts and Entertainment

SPN employees should neither receive nor offer or make, directly or indirectly, any illegal payments, remuneration, gifts, donations or comparable benefits which are intended to or perceived to obtain business or influence decisions in SPN's favor or undue advantage in relation to conduct of SPN's business.

However, an SPN employee may give gifts to an individual or an organization carrying the Company's name or logo (e.g. Company branded mugs, t-shirts, etc.) and/or accept gifts from an individual or organization that are customarily given (e.g. gifts packs, dry fruits, sweets, etc.) during festive occasions like Diwali, Eid, Christmas, New Year, or are of commemorative nature for special events like an anniversary or the completion of a project milestone. The value of such gifts should not exceed Rs. 5,000/- each.

In case of government officials, no gifts should be given which could be seen as a violation of the guidelines under the SPE Group Anti-Bribery Policy (available on Insight), FCPA, PCA and the UK Bribery Act. The value of gifts given should not exceed Rs. 1,500/-. Please note that 'Government official' includes representatives of Public Sector Undertakings, Regulatory Bodies, Municipal Corporations, and government owned Banks/Financial Institutions, etc.

Exceptions to the above limits and/or any entertainment provided to any government official must be pre-approved in writing by the Chief Financial Officer and General Legal Counsel.

Benefactor Policy

• No gifts should be given in cash.

• A record of all gifts to government officials requiring pre-approvals must be maintained by the respective department heads.

• Any entertainment provided to any government official must be recorded and reported separately with details of persons entertained.

Beneficiary Policy

• No gifts in cash should be accepted.

• All gifts received by the employee from a contractor, vendor or any other party, associated with the Company, must be reported to the department head within seven days of the receipt. Employee should give the details of the type of gift, entertainment

or favor, its value, the third party's name from whom the gift was received, and the nature of the party's association with the Company.

• All gifts received of value exceeding Rupees five thousand (Rs.5,000/-) are required to be notified to the HR department and deposited with the Administration department. An Inventory of such gifts will be created and the Company will deal with these gifts as it deems appropriate.

Employee Responsibility:

• Operate in compliance with the above guidelines.

• If in doubt, discuss the matter with the department head or the Ombudsperson before giving or receiving any gifts or providing any entertainment.

• Ensure that public disclosure of gifts given and / or entertainment provided or vice versa, would not reflect negatively upon the Company's name or image or cause embarrassment to it.

• Return the gift that does not meet the above criteria.

• Ensure that the department head is notified of all gifts given to any government official which require pre-approval.

XIV. Conflict of Interest

A conflict of interest, actual or potential, may arise, directly or indirectly, when an employee of SPN:

• Engages in any business activity which is outside the purview of the employee's employment contract;

• Is in a position to derive a personal benefit or a benefit to any of the employee's immediate family by making or influencing decisions relating to any transaction; or ï‚· Cannot exercise independent judgment of the Company's best interest.

Employee should declare in writing to the HR department, at the time of joining and at all times during employment, if the employee or any family member or relative is a service provider, contractor, agent or vendor to the Company or has any kind of interest, pecuniary or otherwise, in any service provider or vendor of the Company.

While the Company encourages team work and promotes a cordial relationship amongst its employees at the workplace, we expect employees to disclose any relationship with other employees that may lead to a conflict of interest, especially when an employee is in a position to influence the conditions of employment of the other employee such as promotions, increments, bonuses and like. This includes family ties, marital and consensual physical relationships between employees, business ties, etc.

The Company does not encourage any kind of personal relationship of the above nature between a manager and his/her team members. Managers must ensure that they conduct their professional relationships in accordance with the Code of Conduct. Any relationship of this nature must be reported immediately.

Based on such disclosure, the Company reserves the right in its sole discretion to take appropriate action including but not limited to reassignment of roles within the Company or separation of the concerned employees , if necessary.

If an employee fails to make such a disclosure, as required, and the Company becomes aware of an instance of conflict of interest that ought to have been disclosed by such employee, it will take a serious view of the matter and consider appropriate disciplinary action against such employee, including termination of services.

Employee Responsibility:

• Do not engage in any business, relationship or activity, either directly or indirectly or through family member(s) or relative(s), which might create conflict with the interests of the Company.

• Do not set up any business or acquire a stake in any business in any capacity whether as shareholder, partner or proprietor during the continuation of your employment with the Company.

• Disclose any kind of personal, romantic or physical relationship with a colleague whether it gives rise to a conflict of interest or not promptly to your manager and HR department.

• Make prompt and full disclosure of any conflict of interest, to your manager(s) and HR in writing.

XV. Privacy

SPN has a commitment to ensure the privacy of personally identifiable information received from employees, vendors, customers, contestants and others. SPN's policy on data privacy which governs the use of information is as follows:

(i) Third Party Privacy

The information shared with SPN by vendors, suppliers, clients, contestants, etc., during the course of normal business transaction is confidential and must be seen and/or used only by employees with a legitimate need to access it. Information will be disclosed outside the organization only if required by the applicable laws and after proper authorization.

(ii) Employee Privacy

SPN maintains information of its employees during the normal course of business. SPN record-keeping practices are reviewed periodically to ensure that they are ethical and in accordance with local laws and regulations. Information and details of employees are kept confidential and access to it is strictly limited to those who need it for official purposes only. (iii) Discussing details of one's emoluments

Employees are expected not to discuss the details of their salary, perks or other benefits with their colleagues or any other organization/person without a valid and legitimate need.

Breach of this rule can result in disciplinary action against the employee.

Employee Responsibility:

• Read, understand and adhere to the Company policy on data privacy.

• Read and sign off the 'Employee Data Protection Notice' available on Insight.

XVI. Political Non-Alignment

SPN does not offer or give Company funds or property as donations, directly or indirectly, to any political party, candidate or campaign.

Employee Responsibility:

ï‚· Do not use your official position to associate SPN with any political party, either directly or indirectly.

XVII. Environmental Conservation

SPN continually seeks to minimize the environmental impact of its services and operations. To carry this agenda ahead, SPN endeavors to evaluate and, as appropriate, implement programs that meet or exceed legal requirements.

Employee Responsibility:

ï‚· Follow all the Company programs and initiatives relating to conservation of the environment.

XVIII. Public representation of the Company

SPN honours the information requirements of the public and its stakeholders. In all its public appearance with respect to disclosing Company and business information to public constituencies such as the media, the financial community, employees and the shareholders, SPN shall follow one-voice policy.

Only specifically authorized employees can represent SPN. It is the sole responsibility of these authorised representatives to disclose information of the Company.

Employee Responsibility:

ï‚· Do not initiate contact with reporters/journalists on behalf of or with respect to Company matters. If contacted by the media immediately refer the contact to the authorized representatives.

XIX. Image of Company and Reputation of Employees

All external and internal communication should reflect a positive image of the Company.

Employee Responsibility

• Do not say, communicate or do anything that may degrade or lower the image and reputation of the Company or its employees.

• While expressing views or opinions on social media, take care not to disparage or demean or defame the Company, any employee or stakeholder of the Company.


Sony Ethics & Compliance Hotline

Employees also have an additional option to raise concerns related to the Code of Conduct on Sony's International Ethics Hotline.

The contact details are as follows:

Online: www.sony.alertline.com

Phone: Step 1: Dial the Country Access Code: 000-117

Step 2 : When prompted, dial 855-315-0767 FREQUENTLY ASKED QUESTIONS FOR ETHICS HOTLINE Q. What happens when I call the Hotline?

A. A person ("Call Specialist") who has been extensively trained in handling these types of calls will assist you. They are especially concerned with your confidentiality and will do everything they can to assist you in your efforts to provide information.

Q. How will my confidentiality be maintained? How can I be sure that someone will not try to determine who I am?

A. Sony Pictures Entertainment ("SPE") purposely recruited a third party vendor who specializes in handling confidential calls. The Call Specialist is contractually protected in not providing SPE with any information that would reveal the identity of any callers.

When you call, the Call Specialist will ask you if you want to give your name. But that is a courtesy extended to those who wish to give their names. You will not be pressured in any way to give any information that you do not wish to reveal.

After giving your information, the Call Specialist will provide you with an unique identification number. You will use this number to identify yourself each time you call in. Q. What kinds of questions will the Specialist ask?

A. The Call Specialist uses a framework of the six "W's" of journalistic interviewing (Who? What? When? Where? Why? And How? focuses on obtaining all the information necessary to produce an actionable report for SPE.

Q. How do I place a call to the Sony Ethics Hotline from India?

A. A caller from India, using the AT&T Direct Service to access a toll-free number in the U.S., must first dial an access number ranging in length from three to thirteen digits. In case of India it is 000-117.

Upon dialing the access number, the caller will be connected to the U.S. and will be answered either by an AT&T operator or a tone and voice message instructing the caller to dial the number they are attempting to call. All voice messages are in English, and all operators answer in English, but non English speaking callers can be accommodated.

AT&T country-specific access codes, as well as other useful information regarding international toll free calling may be found at http://www.business.att.com/bt/access.jsp Instructions to Callers

Make sure you have an outside line (if using a public phone, make sure it can be used to make international calls).

STEP 1 : Enter the AT&T Direct Access Number for the country you're calling from.

STEP 2 : When you hear the English-language voice prompt or series of tone prompts, enter your toll-free Hotline number (DO NOT press "1" or "0" before dialing the telephone number).

STEP 3 : The call will be connected to the Sony Ethics Hotline.

If you do not speak English, or prefer to have an interpreter assist you in speaking with the Sony Ethics Hotline Specialist, immediately inform the Hotline Specialist which language you speak. The Call Specialist will then begin conferencing in an interpreter. As this happens, you will hear music, please remain on the line. You will then hear a recorded message in your language to confirm that an interpreter will come on line shortly. An interpreter will then join your conversation to assist you and the Call Specialist in completing the call. Q. What happens after the call is completed?

A. The Call Specialist will provide you with the unique identifying number noted above. Then, based on the priority assigned to the call, you will be requested to call the Hotline back in 24, 72, or 168 hours (1, 3, or 7 days). You will identify yourself by the unique identifying number assigned to you. The purpose of asking you to call back is to provide an opportunity for SPE Security/Legal to have additional and/or clarifying questions asked of you. You will also be given the opportunity to provide any additional or new information. This method of contact is designed to keep that buffer of anonymity between you and SPE at all times.

Upon completion of the call, the Call Specialist writes a report using gender-neutral pronouns to further protect the identity of those callers wishing to remain anonymous and forwards to three carefully selected SPE Security and Legal recipients. These SPE employees are especially trained to make inquiries into the information forwarded by the caller.

Employee Certificate of Compliance with Code of Conduct

I confirm that I have read the Code of Conduct (the "CoC") of Sony Pictures Networks India Private Limited and undertake to comply with all the provisions stated therein.

I agree and confirm that I have never participated in, and / or am not aware of, any violation of the CoC.

Should I ever obtain information giving me reasons to believe that any employee, person, or firm may have engaged in conduct that violates the CoC, I undertake to report that information promptly to the Ombudsperson administering the Code.

Employee Name -

Designation -

Signature -

Date -

Employee Disclosure Form - Conflict of Interest

Please select one of the options:

ï‚  I have no conflict of interest to declare.

ï‚  I have a conflict of interest to declare (please mention details below):

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

Note: This disclosure may be shared with your immediate manager, department head, HR and/or Ombudsperson.

Employee Name -

Designation -

Signature -

Date -

Advertisment