We Commit to
Being Customer Driven

We will provide delight, trust, and happiness through
our customer-oriented business approach.

Code of Conduct MENU

What’s best for the customer is best for our success

We aim high to provide a great customer experience. We will be accountable, as well as hold others accountable when honoring our commitments and getting things done on time. We believe that OK is not good enough, and we focus on the details that matter to deliver excellence.

  • ■ We will do our best to meet customer needs and build and maintain our customers’ trust.
  • ■ We will strive to deliver safe, high-quality products and services at competitive and fair prices.
  • ■ We will represent our products and services fairly, accurately, truthfully and authentically.
  • ■ When conducting advertising and publicity activities, we will strive for accuracy and ease of understanding.
  • ■ We do not make false or illegal claims about competitors or their products and services.
  • ■ If our customer has a problem, we will work sincerely and promptly to accurately determine the facts, investigate to address the cause, and devise measures to prevent a recurrence.

We are fierce, but fair competitors

The SoftBank Group is committed to complying with competition laws everywhere we do business.

  • ■ We will compete fairly on the quality and cost of our products and services, and we will maintain proper relationships with business partners.
  • ■ We understand that “competition” or “antitrust” laws prohibit agreements or actions that might unreasonably restrain competition, create a monopoly or abuse a strong market position.
  • ■ We communicate properly with competitors and avoid discussion of sensitive information.
  • ■ We do not agree with competitors to set prices, “rig bids,” limit production or divide customers, suppliers or markets.
  • ■ We do not engage in the unlawful exchange of confidential or proprietary information with competitors to gain an unfair advantage over another competitor, supplier or customer.
  • ■ We follow our policies and procedures before we join groups like trade associations or customer advisory councils.

We promptly report all violations to Legal or Ethics and Compliance.

Sensitive information includes:
  • ・ Costs and margins.
  • ・ Pricing.
  • ・ Business plans and strategies.
  • ・ Employee compensation and other employment conditions.

Competition laws are complicated, and we should always ask questions and report concerns to Legal or Ethics and Compliance if we are unsure.

Be sure you don’t:
  • ・ Discuss pricing or the terms of our agreements with a competitor, even informally.
  • ・ Agree with a competitor to target certain customers, products, services or geographic territories.
  • ・ Agree with others to refuse to do business with a customer, supplier, licensor or licensee.
  • ・ Share confidential information from one portfolio company to another competing company.
Do consult with Legal or other appropriate departments before:
  • ・ Communicating with our competitors or participating in trade association activity.
  • ・ Teaming with our competitors.
  • ・ Entering into joint bidding or supply arrangements or forming a joint venture.
  • ・ Agreeing to contracts containing exclusivity provisions.

We respect and promote personal privacy

The SoftBank Group respects privacy by keeping personal data private and secure. All personal data collected and held by the SoftBank Group will be processed carefully, fairly and lawfully.

  • ■ We protect the personal data of customers, business partners, shareholders and fellow employees.
  • ■ We are committed to build privacy and security in the design of our products and services and to apply appropriate safeguards to protect personal data against unauthorized use or disclosure.
  • ■ We are committed to collecting and using personal data that is relevant and necessary for legitimate purposes.
  • ■ We maintain personal data in an accurate, complete and current state, consistent with the purpose for which it was collected.
  • ■ We do not maintain or process personal data longer than is necessary.
  • ■ We provide access to sensitive information only to those who have a specific business purpose and have been granted prior authorization.
  • ■ We properly shred, securely destroy or archive unnecessary personal data.
  • ■ We do not disclose personal data to any unauthorized third parties.
  • ■ We protect personal data physically and electronically and do not place personal data on unencrypted or unsecure computers, or removable media.

If we suspect a privacy or security breach or vulnerability, we promptly report our concerns to the SoftBank Group’s IT personnel.

Privacy laws cover sensitive personal data, like ethnicity, medical data, credit card numbers and pension account numbers, right?

Privacy laws and SoftBank policies apply to much more than this. Protected data includes e-mail, contact details, opinions about persons, their preferences, voice, image and location. Privacy laws define personal data extremely broadly as any information that could identify an individual. In case of doubt, treat it as personal data.

How to use the SoftBank Group
Code of Conduct

Our Code is built on the SoftBank Group’s “Commitments” and can be applied using “Action Statements”. These Action Statements provide direction in conducting business ethically. Below these statements are “Key Ideas” that provide specific guidance of how these action statements apply to our work at the SoftBank Group every day.

You will also find “Help” using additional materials such as Red Flags, Caution, Examples, Q&A, Definitions, and the Ethical Decision-making Model and by contacting the Ethics and Compliance Group.

Commitments

Example
We Commit to
Integrity and Respect

Action Statements

Example
We manage conflicts of interest

Key Ideas

Example
  • ■ We understand and look out for conflicts of interest.
  • ■ We disclose our personal interests that might conflict with our company’s interests by following our policies.
  • ■ We do not take advantage of the SoftBank Group information by acquiring interest in property or other assets that may conflict with the SoftBank Group’s interests.
  • ■ We are aware of our fiduciary obligations to customers and follow them, even when the obligation may conflict with the interests of the SoftBank Group. In those situations, we follow our policies to manage our conflict.

Help

”Red Flags” You should reconsider action or seek additional guidance.
“Caution” Be especially aware in these situations.
“Examples” of items discussed in the section.
”Q&A” of items discussed in the section.
”Definitions” of items discussed in the section.
“Ethical Decisionmaking Model” to help you in making the best ethical decision.