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"Please keep in mind that these Standards of Conduct apply to all United States-based employees of the Company, whether or not an employee is directly involved with promotions. Any employee of the Company who violates the Standards of Conduct will be subject to discipline up to and including termination."
——From Sony BMG Internal Memo

SONY BMG APPOINTS COMPLIANCE OFFICER AS PART OF SPITZER INVESTIGATION AFTERMATH

Legal Department VP Gil Aronow Appointed to Enforce Promotion Compliance
In compliance with the deal finalized following last summer’s Elliot Spitzer payola investigation, Sony BMG has appointed Gil Aronow, a VP in the SBMG legal department, to the newly created post of Compliance Officer. The company issued the following internal memo this afternoon:

“As most of you are aware, SONY BMG has entered into an agreement with the New York State Attorney General's Office regarding the Company's promotions practices. In fulfillment of our obligations under that agreement, we have named Gil Aronow, a vice president in the SONY BMG Law Department, to the newly created post of Compliance Officer.

“In this role, Gil will be responsible for ensuring that the Company operates in accordance with the terms of the agreement, and maintains the highest possible standards and practices. Gil will report to senior management, to the SONY BMG Board of Directors and to the Attorney General's Office concerning the Company's compliance. Gil's extensive background in the law and the business of music and television, as well as his proven good judgment, make him the ideal choice for this position.

Also as part of the agreement, SONY BMG is issuing the Standards of Conduct for Promotion, which are designed to make the Company’s policies crystal clear. The document, which is posted in the Policies area on Buzz, should provide you with all the information you need regarding what is permissible relating to employees' direct dealings with radio stations, independent promoters and television.

Each and every employee should read the Standards of Conduct for Promotion and familiarize themselves with its contents. Please keep in mind that these Standards of Conduct apply to all United States-based employees of the Company, whether or not an employee is directly involved with promotions. Any employee of the Company who violates the Standards of Conduct will be subject to discipline up to and including termination.

Please note especially the following restrictions:

* In the course of their employment, employees may not misrepresent their identities in order to influence the selection of music on radio or television programming, and that includes, of course, calling a radio station posing as a member of the general public to request airplay for SONY BMG tracks.

* Only authorized individuals from the promotions departments of each label may provide radio stations or radio programs with copies of the company's CDs, DVDs or other product.

* Only authorized individuals from the promotions departments of each label may provide concert tickets to a radio station or radio program.

Employees may not send copies of CDs or DVDs or provide concert tickets directly to any radio station or radio program employee without first receiving permission from the relevant promotions department. Both of these points, as well as instructions dealing with a wide array of activities are covered in greater detail in the attached document.

We will be conducting training for employees involved in promotion activities to discuss the Standards of Conduct for Promotion, as well as to answer any questions that might arise.

If at any time you believe that the Standards of Conduct have been violated, you must report the violation to the Compliance Officer directly or through the confidential Compliance Hotline at 1-888-448-4627.

In addition, SONY BMG has revised the SONY BMG Code of Business Conduct to reference the Standards of Conduct for Promotion. The revised SONY BMG Code of Business Conduct is now posted on the Buzz.

 

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