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
As an industry leader, we regard business ethics and compliance as important values. Compliance—like safety and quality—is the basis for corporate reliability and sustainable growth. It requires a strong sense of ethics and integrity in individual and organizational behavior, not to mention compliance with laws and regulations. In addition to strengthening systems for raising awareness about compliance and changing behavior in order to prevent compliance violations, we promote effective programs. These efforts will support the enhancement of our corporate value.
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.

Business Ethics
To more effectively instill and promote business ethics and compliance, we have formulated the “Tokyo Electron Group Code of Ethics” as a code of conduct for all executives and employees and established the Business Ethics Committee. We have 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. In addition, through regular meetings with each of the Group companies, we discuss and implement measures to promote compliance.
We have also set up an award system for employees who have engaged in particularly excellent activities relating to business ethics and compliance, to raise awareness within the Group and fostering a compliance-oriented culture.
Compliance Training
We conducts online education and face-to-face training on topics including business ethics and 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 are reinforcing efforts to foster compliance awareness and practice in the company, in order to systematically expand our comprehensive training program and multilingual support.
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.
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 2024, 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 securely raise concerns and seek redress outside the chain of command about behavior that is, or may be, in violation of laws, regulations or business ethics. An internal leniency system has also been introduced, whereby any disciplinary action may be reduced or exempted in the event that an employee involved in a compliance violation has made a report or sought advice on their own volition. This encourages employees to proactively provide information and leads to problems being discovered and resolved at earlier stages.
As part of this internal reporting system, 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 and is also accessible to our suppliers and retirees —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.
