Compliance

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.

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Compliance System

In order to effectively promote compliance programs that are expected of a global company, we have appointed a Chief Compliance Officer (CCO) and established a dedicated Compliance Department at our headquarters. 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, through which we strengthen our overall global compliance system.

Compliance Initiatives

Business Ethics and Compliance

To more effectively instill and promote business ethics and compliance, we have formulated the Tokyo Electron Group Code of Ethics as a Group-wide code of conduct, and established the Business Ethics Committee.
In February 2026, we conducted training on the Code of Ethics for directors and employees of the Group, and received their pledge of compliance. As part of the training, which included a message from the CEO, directors and employees were encouraged to maintain a strong sense of ethics and reaffirm their role in supporting company growth. The message also explained that compliance with the Code of Ethics is essential for fulfilling our social responsibilities and realizing sustainable development.

Initiatives for Anti-bribery and Corruption and for Competition Laws

As detailed in the section on Bribery and Corruption in the Code of Ethics, we do not bribe* anyone, anywhere, for any reason under any circumstances. Under Fair and Open Competition as well, we strive to operate in a fair, open and competitive marketplace and do not engage in illegal anti-competitive activities.
We have established the Basic Policy on the Prevention of Bribery and Corruption and the Basic Policy on Competition Law Compliance and we strive to put them into practice.
In fiscal year 2026, we were not found to have been involved in any cases of corruption and bribery, nor were we subject to any monetary penalties such as fines or surcharges.

Bribes include cash, entertainment, gifts, tours in connection with visits to Company facilities, travel invitations, healthcare services, employment, sexual services, and payment made in disguise of donations or sponsorships.
Initiatives for Anti-bribery and Corruption and for Competition Laws on our website

Internal Reporting System

We have established an internal reporting system that allows employees to safely and securely raise concerns and seek redress outside the chain of command, and to report and consult any behavior that is, or may be, in violation of laws, regulations, or business ethics. This system ensures complete confidentiality, anonymity and the prohibition of retribution and unfavorable treatment. 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 problem-solving at earlier stages.

Basic Global Response to Internal Reports

As part of this internal reporting system, we have been operating the Tokyo Electron Group Ethics & Compliance Hotline – global 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 actions in accordance with the Rules of Employment, corrective measures such as improvements to the workplace environment and preventive measures are implemented as necessary.
In fiscal year 2026, a total of 193 reports and consultations were received via the internal reporting system, of which 19 were recognized as compliance violations (with no cases resulting in indictment or prosecution). Main reports were related to the work environment, including harassment. We therefore continue to conduct regular training programs for our employees with the goal of preventing harassment, and we provide thorough follow-up with those concerned or involved.
On the other hand, also in light of the incident that occurred in Taiwan in fiscal year 2026, we are working to strengthen our company-wide systems and improve employee literacy in information security. As part of these efforts, we are conducting information security training and practical workshops for all employees.