Compliance/Code of Ethics

Tokyo Electron acts in strict compliance with business ethics and applicable laws to ensure that its corporate activities are fair and trustworthy.

Approach to Compliance

To practice our Corporate Philosophy, it is vital that each employee performs their daily duties with strong interest in and a deep understanding of compliance. We established “Tokyo Electron Group Code of Ethics” as a code of conduct to ensure that our employees are aware of the risks around them and conduct themselves appropriately. We have built a global system that can directly raise questions and concerns about compliance and business ethics to quickly address potential problems.

Compliance System

In order to effectively promote a global compliance program, we have appointed a Chief Compliance Officer (CCO) and established a dedicated Compliance Department at our headquarters. Additionally, we have also appointed Regional Compliance Heads at key overseas sites, and have established a framework for direct reporting to the CCO and Compliance Department. The primary role of the Compliance Department is to formulate and review our practical compliance programs, establish and implement business ethics, plan and implement education and training, and establish and operate internal reporting systems. It also cooperates with the Risk Management Department, regularly confirms the observance of laws and regulations in each country as well as internal company rules at each Group company, and assesses compliance risks. Furthermore, the Internal Audit Department conducts operational audits based on annual plans, which leads to the improvement of findings as appropriate.

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Business Ethics

We have published “Tokyo Electron Group Code of Ethics” as a code of conduct for all executives and employees and established the Business Ethics Committee, and are working to promote business ethics and compliance more effectively and ensure that these permeate the entire Group. We have also set up the Disciplinary Committee as a subordinate organization of the Business Ethics Committee to ensure the implementation of reasonable and appropriate disciplinary action and proper procedures.
To ensure awareness of the Code of Ethics, we have translated it into six languages, including Japanese, and have distributed it in the form of a booklet to all executives and employees. In fiscal year 2021, the Code of Ethics was revised. In addition to reflecting standards required as a global company, we added a number of new provisions on such important issues as personal data protection, information security, and money laundering. In addition, in pursuit of clarity and usability, we have made changes to the booklet design and adopted a bullet point format. We are also striving to raise awareness of compliance and business ethics by obtaining confirmation every year from all executives and employees that they understand and comply with the revised content.


The Tokyo Electron Group Code of Ethics (Itemized)

  • CEO message
  • Contents
  • About the Tokyo Electron Group Code of Ethics
  • Scope of the Code of Ethics
  • Our Responsibility – “Read, Understand and Apply”
  • Supervisor’s Responsibilities
  • Raising Concerns/Speaking Up
  • Role of TEL Group’s Ethics & Compliance Function
  • Company’s Response
  • Confidentiality and Zero Tolerance of Retaliation
  • Safety and Quality
  • Suppliers
  • Export & Import
  • Fair and Open Competition
  • Bribery and Corruption
  • Conflicts of Interest
  • Political Activities and Contributions
  • Money Laundering
  • Accounting/Tax/Financial Reporting
  • Insider Trading
  • Intellectual Property
  • Information Security
  • Personal Data
  • Company Assets
  • Human Rights & Fair Employment Practices
  • Workplace Free of Harassment
  • Environmental Preservation
  • Corporate Social Contribution

Compliance Training

TEL conducts online education and face-to-face training on topics including business ethics and the basics of compliance, anti-corruption, export compliance, insider trading prevention, the Act for Subcontracting, and the prevention of harassment. Depending on the topic, this education is implemented for specific levels or across the board. We will systematically expand our comprehensive training program and multilingual support, and reinforce efforts to foster compliance awareness and practice in the company.

Initiatives for Anti-Bribery and Corruption and for Competition Laws

We established the company-wide Basic Policy on the Prevention of Bribery and Corruption, and through regular education, we are working to promote understanding and awareness. Based on this basic policy, we have prepared the Guidelines for Gifts, Hospitality and Entertainment, which stipulate specific, practical procedures and standards on monetary amounts, and we have established a thorough process requiring prior approval for cases outside these standards. Using questionnaires that we have prepared, we also regularly check the status of our suppliers' efforts to prevent corruption and provide them with feedback on the results and areas for improvement as required.

We have also established the company-wide Basic Policy on Competition Law Compliance, and have prepared, disseminated and enforced guidelines that summarize different types of violations in an easy-to-understand format, based on applicable laws and regulations in the countries and regions in which we operate.

Personal Information Protection

Tokyo Electron has appointed a “Manager of TEL Group Personal Information Protection & Management” to supervise the entire TEL Group regarding the protection and management of personal information via the Personal Information Protection Promotion Committee. We are striving to strengthen compliance with personal information by establishing a process to respond promptly if an incident related to personal information occurs. In accordance with the Rule of Employment, it is taken preventive and corrective measures including disciplinary action against an employee who violates the laws and internal company rules regarding personal information protection.
In fiscal year 2023, we received no complaints at the inquiry desk (for external) designated by the Compliance Department for the handling of personal information.

Internal Reporting System

Preventing problems from occurring and resolving them before they become significant requires a system that allows employees to raise questions and concerns about business ethics and compliance without reservation or hesitation and to discuss them fully. For this reason, we have established an internal reporting system that ensures complete confidentiality, anonymity and the prohibition of retribution so that employees can safely and reassuringly provide information and seek redress outside the chain of command about behavior that is, or may be, in violation of laws, regulations or business ethics.

Specifically, we have established and are operating the Tokyo Electron Group Ethics & Compliance Hotline—a global common internal point of contact that uses a third-party system that is also accessible to our suppliers—as well as an external point of contact that allows direct consultation with an outside law firm. The internal point of contact can be accessed via phone or a dedicated website 24 hours a day, 365 days a year, and accommodates all languages used by employees.

Reports and consultations received via these points of contact are handled with sincerity, and investigations are undertaken in accordance with internal regulations. If a compliance violation is found, disciplinary action is taken in accordance with the Rules of Employment, and preventive measures and corrective measures, such as improvements to the workplace environment, are implemented as necessary.