Compliance/Code of Ethics

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

Approach to Compliance

Stakeholder trust is essential to business activities. In order to maintain this trust, it is essential to continuously ensure compliance and enhance corporate ethics. The Fundamental Policies concerning Internal Controls within the TEL Group and TEL‘s Code of Ethics (Code of Ethics) stipulate that all TEL Group executives and employees must comply with laws and regulations and act with high ethical standards and a strong awareness of compliance.

Compliance System

TEL has built a structure to implement its compliance program globally. Under the head of the Legal, Compliance Division, compliance representatives have been newly appointed at major overseas bases to create a system for direct reporting through the chain of command to the Legal, Compliance Division. The company has restructured its compliance system. Specifically, compliance-related issues are immediately reported by the head of the Legal, Compliance Division to the CEO, Board of Directors, and the Audit & Supervisory Board so that they can be addressed quickly and effectively.

Corporate Ethics

TEL has established the Code of Ethics as a standard of conduct by which employees and executives should abide. To ensure awareness of this code, we distribute it in the form of booklets in Japanese and four other languages to all employees. TEL revises its Code of Ethics as needed, in response to changes to external and internal conditions. In addition, an Ethics Committee has been established to support and supervise the activities of Group companies in Japan and overseas aimed at more effectively promoting and raising awareness of compliance and corporate ethics.
Furthermore, directors, officers and senior executives sign an oath to uphold the Code of Ethics and comply with corruption-related laws every year.

Compliance Regulations

Based on its Code of Ethics, each Group company in Japan and abroad has established its own compliance regulations to ensure that every individual taking part in the business activities of the Group clearly understands the pertinent laws, regulations and internal company rules, and consistently applies these in all of their activities.

Compliance Education

TEL conducts online education and face-to-face training on topics including corporate ethics and the basics of compliance, 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 also implement ongoing testing to check the degree of understanding among employees. From fiscal year 2020, we will deploy a more comprehensive, systematic education program, advancing multilingual support in an effort to foster compliance awareness and reinforce behavior-oriented awareness-building activities among all Group employees.

Internal Reporting System

As a means for employees to provide information outside the chain of command about behavior that may be in violation of laws or corporate ethics, we have established a hotline (organized around the tenets of confidentiality, anonymity, and prohibition of retribution) to receive internal reports. In addition, we established an external contact point for employees and another contact point specifically for suppliers and third parties. Each overseas location has its own internal reporting hotline, and we are building a unified internal reporting system for all overseas bases.

As a result of these initiatives, in fiscal year 2019 there were no reports or cases of noncompliance with laws, regulations, or the Code of Ethics that could have had a material impact on the TEL Group’s business or local communities.

Confirming of Information on Japanese Laws

In order to reduce the risk of legal compliance violations, we regularly identify and clarify the Japanese laws that affect company operations and regulations. Information regarding revisions to relevant laws is received in a timely manner via an external Web service and appropriate responses are taken, such as amending internal regulations, changing operational procedures, and notifying all personnel affected by the revisions.