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.

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.

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.

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.

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.

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.