this document applies to suppliers (collectively, "suppliers") of sony pictures entertainment inc. ("spe") and its majority-owned subsidiaries. use of the terms "spe," "we," and "the company" in this document refer to sony pictures entertainment inc. or one or more of its subsidiaries, whichever is relevant to the particular supplier relationship. spe expects that all its suppliers comply with…, conflicts of interest, if a supplier's employee is a family relation (spouse, parent, sibling, grandparent, child, grandchild, in-law, or same or opposite sex domestic partner) to an employee of spe, or if a supplier has any other relationship with an employee of spe that might represent a conflict of interest, the supplier should promptly disclose this fact to spe or ensure that the spe employee does so. spe employees…, bribery, spe prohibits corrupt practices in any form, including bribery, kickbacks, and other unlawful payments, in both the public (government) and the private (commercial) sectors. in connection with any transaction as a supplier to spe, or that otherwise involves spe, the supplier must not give or offer to give anything of value (payment, gifts, entertainment, or business amenity), directly or…, gifts, meals, and entertainment, spe employees are prohibited from accepting anything more than reasonable and modest gifts, meals and entertainment from suppliers, and are required by our global gift guidelines to record and report in writing any gift, entertainment or favors given to or received by spe or any of its subsidiaries, whose value (or cumulative value in any one year) exceeds $250. ordinary business meals and small…, protecting confidential information, suppliers should protect spe's confidential information. suppliers who have been given access to confidential information as part of the business relationship should not share this information with anyone unless authorized to do so by spe. suppliers should not trade in securities, or encourage others to do so, based on confidential information received in the course of providing services to or…, trade controls, both spe and its suppliers must comply with applicable trade control laws and regulations. these laws and regulations prohibit or restrict sales or other transactions involving certain products, services, software and technologies to certain countries, individuals or entities to secure international peace and security. suppliers must know and comply with those laws and regulations., business and financial records, both the supplier and spe must keep accurate records of all matters related to the supplier's business with spe. this includes the proper recording of all expenses and payments. if spe is being charged for a supplier's employee's time, time records must be complete and accurate. suppliers should not delay sending an invoice or otherwise enable the shifting of an expense to a different accounting…, reporting potential misconduct, suppliers who believe that an employee of spe, or anyone acting on behalf of spe, has engaged in illegal or otherwise improper conduct, should report the matter to the company. the supplier can contact the employee's manager. a supplier's relationship with spe will not be affected by an honest report of potential misconduct., privacy, spe respects the privacy of individuals, such as customers, employees of suppliers, and spe personnel. suppliers should develop and implement policies and internal rules regarding personal information and observe and comply with all applicable laws and regulations as well as applicable internal rules and policies whenever collecting, maintaining, using, disclosing or disposing of personal…, human rights, spe believes that all human beings should be treated with dignity and respect. suppliers should be committed to upholding internationally recognized human rights of all people, including using all reasonable efforts to avoid causing or contributing to adverse human rights impacts that may arise from operations, products, services and/or business relationships and acting diligently to help…, non-discrimination, spe values diversity and inclusion in the workplace. suppliers should be committed to a workforce free of unlawful harassment and discrimination. suppliers shall not engage in discrimination based on any basis protected by the laws of the jurisdiction in which they operate in hiring and employment practices., healthy and safe work environment, spe is committed to maintaining a healthy, safe and productive work environment. the company expects its suppliers to comply with all applicable health and safety laws and regulations to help ensure workplace safety. suppliers must also recognize that ongoing worker input and education is essential to identifying and solving health and safety issues in the workplace, and have suitable programs in…, environmental, spe expects its suppliers to recognize that environmental responsibility is integral to producing world class products and sustaining quality of life for future generations. suppliers are expected to have suitable programs in place which address topics including environmental permits and reporting, pollution prevention and resource reduction, hazardous substances, solid waste, air emissions,…, responsible sourcing of minerals, spe's suppliers shall adopt a policy and exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, and gold in the products they manufacture to reasonably assure that they are sourced in a way consistent with the organisation for economic co-operation and development (oecd) guidance for responsible supply chains of minerals from conflict-affected and high-risk…
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