Approach to Compliance

To practice Tokyo Electron’s 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’s 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 compliance program that is expected of a global company, we have appointed a Chief Compliance Officer (CCO) and established a dedicated Compliance Department at our headquarters. 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, establish and operate internal reporting systems, and provide advice and support on compliance to each department. It also cooperates with our Risk Management Department, regularly confirms the observance of laws and regulations in each country as well as internal company rules at each of the Group companies, and assesses compliance risks.

Additionally, the persons responsible for compliance who are called Regional Compliance Controllers have been appointed at key overseas sites, establishing a system for direct reporting to the COO and Compliance Department.

We engage in improvement activities with the relevant departments as appropriate for the items identified in yearly operational audits conducted by the Internal Audit Department.

In fiscal year 2022, a third-party evaluation of our global compliance system was conducted by an external law firm, and we made efforts to further strengthen compliance by identifying items that require improvement.

Representative Director, President & CEO General Manager of Legal, Compliance Unit Chief Compliance Officer Compliance Department (Headquarters) Regional Compliance Controllers U.S. Europe/Israel Korea Taiwan China Singapore/Malaysia

Compliance Initiatives

Business Ethics

We have established the Business Ethics Committee to promote and raise awareness of compliance and business ethics more effectively together with establishing “Tokyo Electron’s Code of Ethics” as the standard of conduct for all executives and employees.
In addition, through regular meetings with each of the Group companies, we discuss and implement measures to promote compliance.

Our Code of Ethics, which is available in five languages* including Japanese, is distributed not only in downloadable PDF formats but also in the form of a booklet to all executives and employees to ensure awareness.

In fiscal year 2021, the Code of Ethics was revised and provisions such as personal data protection, information security and money laundering were added. We are also striving to raise awareness of compliance and business ethics by regularly obtaining pledges from all executives and employees that they understand and comply with the content.

We have also set up the Disciplinary Committee as a subordinate organization of the Business Ethics Committee for the purpose of ensuring the implementation of reasonable and appropriate disciplinary action and proper procedures.

* Five languages: Japanese, English, Korean, Traditional Chinese and Simplified Chinese

Initiatives for Anti-Bribery and Corruption and for Competition Laws

We have established the Group-wide Basic Policy on the Prevention of Bribery and Corruption and regularly conducts training to promote understanding and awareness. Based on this 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 where there is a deviation from these standards.

Using questionnaires that we have prepared, we regularly check the status of our suppliers' efforts to prevent corruption and provide them with feedback on the results and areas for improvement.

We have also established the Group-wide Basic Policy on Competition Law Compliance, and have prepared, disseminated and enforced guidelines for executives and employees 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.

Compliance Training

We conduct online and face-to-face training adapted to different levels, for all employees*. We will systematically expand our comprehensive training program and multilingual support, and reinforce efforts to foster compliance awareness and practice in the Company.

* Training and seminar topics include basics of business ethics and compliance, anticorruption, export compliance, insider trading prevention, the Act for Subcontracting, and the prevention of harassment.
 Some training is limited to certain employees such as department managers or new employees.

Internal Reporting System

Preventing problems from occurring and resolving them quickly when they occur 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. 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.

Global Response to Internal Reports

Response to Internal Reports

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.

* A leniency system has been introduced whereby any disciplinary action may be reduced or exempted in the event the employee involved in a compliance violation has made a report or sought advice on their own volition.

In fiscal year 2022, a total of 95 cases were received via the internal reporting system, of which 19 were recognized as compliance violations. The reports and requests for advice primarily related to harassment and the workplace environment. Based on this result, we have conducted regular education programs for our employees with the goal of preventing harassment and have provided thorough follow-up with those concerned or involved.

There were no reports or cases of non-compliance that could have had a serious impact on our business or on local communities.