Tokyo Electron Group AI Basic Policy

Introduction Tokyo Electron Group pursues technological innovation in semiconductors every day to put into practice our Corporate Philosophy, “We strive to contribute to the development of a dream-inspiring society through our leading-edge technologies and reliable service and support.” To resolve the increasingly diverse social challenges that lie ahead and to create a sustainable society, it is important that we expand the AI capabilities embedded in our products and services and make effective use of AI within our own organization. At the same time, the use of AI has the potential to unintentionally infringe upon human rights, privacy, and security, among other matters, and thereby have a significant impact on society. To reduce the risks that may arise as we advance our use of AI and to practice the responsible use of AI, Tokyo Electron Group hereby establishes the “Tokyo Electron Group AI Basic Policy” (hereinafter, the “Policy”) as a guide for everyone involved in our business, including not only our management and employees but also the suppliers, subcontractors, and other business partners engaged in our business.

1. Delivering High Quality and Creating Value

Tokyo Electron Group will actively promote the use of AI to accelerate the development, manufacture, and other processes involved in creating high-quality products that contribute to solving social challenges.

2. Ensuring Safety

Tokyo Electron Group strives to ensure safety in its use of AI so that no serious problems arise, such as accidents affecting life, physical or mental health, property, or the environment. We conduct prior risk assessments and strive to ensure safety. In the event of an incident, we will promptly escalate the matter to the relevant parties, respond swiftly, and implement corrective measures going forward.

3. Protecting Privacy

When handling data that includes personal information in connection with its use of AI, Tokyo Electron Group carries out appropriate management and operation in accordance with the Tokyo Electron Group Privacy Policy and the Tokyo Electron Group Privacy Notice. In addition, we incorporate the principle of privacy by design at each stage of the collection, use, storage, and disposal of such data, and appropriately protect the rights of data subjects.

4. Ensuring Security

In using AI, Tokyo Electron Group recognizes AI-related security risks and implements appropriate measures, while striving to prevent unauthorized access and information leakage through technical and operational cybersecurity measures. In addition, based on the Global Security Policy, Tokyo Electron Group conducts education, awareness-raising, and training that take into account the characteristics of AI use, and strives to appropriately manage and protect information assets.

5. Respecting Human Rights and Fairness

Based on the “Tokyo Electron Group Human Rights Policy,” Tokyo Electron Group respects internationally recognized human rights and contributes to the development of society by using AI in a manner that does not give rise to unjust discrimination. In particular, we strive to identify and eliminate the risk of bias that may undermine fairness, and we likewise carry out our use of AI in a manner that respects human rights.

6. Prohibited AI

As a basic principle, Tokyo Electron Group will not develop, introduce, sell, or operate AI that falls under any of the following:

• AI intended to encourage or induce manipulative behavior, or to exploit vulnerabilities in an unauthorized manner.


• AI used for purposes that materially infringe upon an individual’s fundamental rights, such as conducting large-scale biometric surveillance without authorization (for example, continuous facial recognition surveillance in public spaces).


• AI that performs social scoring and uses the results thereof in the provision of services or otherwise.


• AI that is expressly prohibited under applicable laws and regulations in each country (including the EU AI Act).


• In addition to the foregoing, AI that raises concerns from an economic security perspective.

Any AI related project suspected of falling under the above (including cases where applicability is unclear or borderline) will be reported to the AI Steering Committee prior to development, and we will discontinue development or consider alternative approaches. We require our suppliers to comply with the same standards.



7. Disclosure of AI Capabilities and Limitations


Tokyo Electron Group discloses, for each AI, the intended scope of use, operating environment, and performance metrics (including acceptable tolerances and anticipated types of errors), so that users can properly understand the capabilities and limitations of the AI before utilizing it.



8. Human Intervention (Human-in-the-Loop)


For “important decisions” made through the use of AI that have a material impact on human life, safety, employment, creditworthiness, or legal rights and obligations, Tokyo Electron Group, as a general principle, ensures that a human makes the final decision only after establishing, in advance, that the decision is sufficiently justified and conducting a detailed risk assessment, among other measures.



9. Emphasizing Transparency and Accountability


In its use of AI, Tokyo Electron Group enhances transparency by providing appropriate information, such as the reasons underlying a given determination, and appropriately discloses AI-generated determinations and results within a reasonable scope upon request by users or affected persons. In addition, we clarify where responsibility lies in decision-making that uses AI, and, in the event a problem arises, we promptly investigate the cause and implement corrective measures.



10. Stakeholder Engagement


To promote the ethical use of AI, Tokyo Electron Group actively engages in dialogue and collaboration with a diverse range of stakeholders, including customers, business partners, academic institutions, industry associations, civil society, and regulatory authorities. We incorporate outside insights and strive for the ongoing sharing of best practices in AI ethics as well as continuous improvement.



11. Governance Structure


To ensure the effectiveness of this Policy and to clarify the structure of responsibility for the outcomes of our use of AI, Tokyo Electron Group establishes the following governance structure.

(1) Establishment of the AI Steering Committee: We establish an “AI Steering Committee” that approves company-wide policies relating to AI utilization, deliberates on and makes decisions regarding important matters, and reports on important matters to management.

(2) Appointment of the AI Governance Team: To ensure the appropriate utilization of AI, each member of the AI Steering Committee selects a representative from his or her own department and appoints that person as a member of the “AI Governance Team.”

(3) Continuous Improvement of the AI Governance Structure: The AI Governance Team shall promote the continuous improvement of Tokyo Electron Group’s AI governance structure to ensure the effectiveness of this Policy and to appropriately respond to advances in AI technology, regulatory developments, and changes in societal expectations. As part of this effort, the AI Governance Team shall review this Policy at least annually, taking into account the operational status of this Policy, stakeholder feedback, and relevant developments in Japan and overseas. If the AI Governance Team determines, as a result of the review, that revision of this Policy is necessary, it shall formulate a proposed revision and, upon obtaining the approval of the AI Steering Committee, publish the revised Policy.



September 17, 2026 Established

This Policy has been established with the approval of the responsible executive officer and and are applied to not only management and employees but everyone involved in our business.