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Code of Conduct

Code of Conduct

SPE employees must comply with SPE Code of Business Conduct Policy which includes how suppliers are selected or recommended and acceptable gift giving to suppliers.

SPE Code of Business Conduct Policy states in part:

"When selecting or recommending suppliers of goods and services you must do so on the basis of competitive price, quality, delivery and other objective standards. Purchasing decisions including the selection of suppliers must be based upon the business benefit to Sony Pictures and its customers, and no trace of favoritism should be part of the buying process. This requirement applies not only to employees in charge of procurement, but also to any other employees who influence the buying process. Sony Pictures expects its suppliers and contractors to uphold its policies concerning compliance with applicable laws, respect for human rights, environmental conservation and safety."

The policy also states that Sony Pictures employees "...may not give a gift to any current or prospective customer, supplier or other business partner for the purpose of retaining business or for the purpose of obtaining any other favorable business action....You may not accept any payment, gift or entertainment that is intended to influence, or that appears to influence business decisions of Sony Pictures.

Gifts may be given or accepted only when they meet all of the following criteria:

  • Are consistent with customary business practices;
  • Are not excessive in value and cannot be interpreted as a bribe or payoff;
  • Are not in the form of cash or its equivalent (e.g. stock, bonds or other negotiable instruments);
  • Are not in violation of any laws, Sony Pictures policies, or known company policies of the third party donor or recipient; and
  • Are such that public disclosure of the gift would not reflect negatively upon or embarrass Sony Pictures or the employee, or make it appear that the recipient’s judgment would be compromised."