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.
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 code of conduct for all executives and employees and established the Business Ethics Committee. We held the Business Ethics Committee in February 2025, where each Group company shared their progress toward the fiscal year 2025 according to their three-year plan. We discussed the current status and continuous improvement on effective business ethics and compliance programs.
Initiatives for Anti-bribery and Corruption and for Competition Laws
We have 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 as Group-wide policies and guidelines. With the expansion of the market in India, in March 2025, we conducted activities to foster awareness by publishing the Handbook for Employees going to India on business to enable executives and employees to respond appropriately to bribery risks.
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.
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 2025, a total of 181 reports and consultations were received via the internal reporting system, of which 27* were recognized as compliance violations. 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. We are also working on establishing awareness regarding compliance, including the prevention of harassment. The CCO provides continuous compliance training for managers, which serves as opportunities to reexamine 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
*Percentages may not add up to 100 because they have been rounded
