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.

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 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.

Initiatives for Anti-bribery and Corruption and for Competition Laws

We have globally established the Basic Policy on the Prevention of Bribery and Corruption and the Guidelines for Gift, Hospitality and Entertainment in the area of anti-bribery and corruption, and the Basic Policy on Competition Law Compliance and Guidelines in the area of competition laws. To prevent violations, we regularly conduct activities to foster awareness, and we are committed to promoting understanding and instilling these Policies and Guidelines.

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 discuss 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 problems being discovered and resolved at earlier stages.

Breakdown of Report/Consultation Contents

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 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 2024, a total of 110 reports and consultations were received via the internal reporting system, of which 16* were recognized as compliance violations. The reports and consultations primarily related to the workplace environment, including harassment.
Based on the results, we continue to conduct regular education programs for our employees with the goal of preventing harassment, and we provide thorough follow-up with those concerned or involved. The CCO also provided compliance training for managers, which included the importance of establishing an open work environment.
There were no reports or cases of violations of laws/regulations in our operations that could have had a serious impact on our business or on local communities.

There were no cases filed or prosecuted by the authorities