Tokyo Electron Group

Code of Ethics

Tokyo Electron Group

Code of Ethics

Introduction
Tokyo Electron s Corporate Philosophy is defined as
We strive to contribute to the development of a
dream-inspiring society through our leading-edge
technologies and reliable service and support.
The importance of semiconductors and flat panel displaysthat sustain the fast-growing data society via the Internetof Things, high-speed communication network and artificial
intelligence has further increased.
At the same time, society s expectation of Tokyo ElectronGroup has become extremely high.
We acknowledge our social responsibilities and continue to
strive to be a company that society highly values andemployees can be proud of. To make this happen, it iscritical that each and every employee, which is the source ofthe company s growth, adheres to high standards of ethics.
Tokyo Electron s Code of Ethics clearly states what weshould be conscious of and how we should act when
encountering problems.
When revising the Code of Ethics this time, in addition to
updating the contents, we have also made it user-friendly
for Tokyo Electron Group employees around the world. We havehigh expectations that your understanding of the Code will
enable you to act boldly and strategically with further speed.

Toshiki Kawai
Representative Director,
President & CEOTokyo Electron Limited

Contents
Introduction
Our Journey with Ethics and Compliance

1 Business Practices
1-1

Safety and Quality

12

1-2

Suppliers

13

1-3

Export & Import

14

1-4

Fair and Open Competition

16

1-5

Bribery and Corruption

18

1-6

Conflicts of Interest

20

1-7

Political Activities and Contributions

22

1-8

Money Laundering

23

2 Our Assets & Property
2-1

Accounting/Tax/Financial Reporting

28

2-2

Insider Trading

29

2-3

Intellectual Property

31

2-4

Information Security

33

2-5

Personal Data

36

2-6

Company Assets

38

3 Our Workplace
3-1

Human Rights & Fair Employment Practices

42

3-2

Workplace Free of Harassment

44

4 Responsibilities to the Public
4-1

Environmental Preservation

48

4-2

Corporate Social Contribution

49

My Code of Ethics

The Code of Ethics

The Code of Ethics stipulates the behavior expected of all
employees of Tokyo Electron Group, to advance our basic
philosophy and vision and comply with the laws andregulations of the countries or regions where we do business.
By acting according to the Code of Ethics, we cancontinue to be a company that lives up to society s
expectations as a truly global leader and a company
that we can all be proud to be a part of.

Our Journey with Ethics and Compliance
About the Tokyo Electron Group Code of Ethics
Tokyo Electron Group Code of Ethics ( Code of Ethics or Code ) isa code for Tokyo Electron Limited and its subsidiaries (collectively
TEL Group, the Company, or we ). The Code of Ethics is a guidewhich sets out common and minimum standards, and establishes theappropriate actions to be taken for our daily work to comply withthe laws, rules and regulations in the countries in which TEL Group
operates ( laws and regulations ), as well as internal Company
policies and rules. The Code of Ethics supersedes any policies or rulesthat are not consistent with it; however, if there is a conflict between
the contents of the Code of Ethics and local laws or regulations, thestricter shall apply.
TEL Board of Directors has the sole authority to issue, amend andrevoke the Code of Ethics at any time.

Scope of the Code of Ethics
The Code of Ethics applies to all officers (including directors andcompany auditors), Corporate Officers and Executive Officers of TEL
Group, persons who have entered into employment with and isrendering services to any entity in TEL Group (irrespective of
employment status, such as regular employees, contract employees,
advisers, fixed-term employees, employees rehired after mandatory
retirement, part-time employees, and workers hired on a daily orseasonal basis), and other persons who perform work for theCompany such as secondees and temporary workers from anotherentity or agency (collectively the "Officers and Employees"), and we
encourage and expect our suppliers and third parties to follow theCode of Ethics or comply with their internal rules that are equivalent
to the Code of Ethics.

Our Responsibility – Read, Understand and Apply
To embody TEL s Corporate Philosophy and Vision, it is critical that
all Officers and Employees read, understand and apply the Code of
Ethics in their day-to-day business. All Officers and Employees, arealso expected to annually acknowledge that we have read,understood, and continuously comply with the Code of Ethics.
6In other words, as a member of TEL Group striving for sustainablegrowth together,

We are:▶ Committed to doing the right things,▶ Aware of risks around us, and▶ Knowledgeable on doing things right.
However, things are not always black and white. In case of doubt abouta course of action or conduct, ask yourself the following questions.
■

Would my action be in compliance with laws and regulations,
Code of Ethics, and/or other internal policies?

■

Wouldn t my action damage my and/or the Company s reputation?

■

Would I explain with confidence my action to all the
stakeholders?

If the answer to any of the above is not yes (for the second question,no ), you should not continue with that action. Please consult withyour direct supervisor or other channels available to you with on any
questions that you may have in doing your day-to-day business.

Supervisor s Responsibilities
All supervisors of TEL Group are expected to raise complianceawareness among their team members and promote a culture of
ethics and compliance. More specifically, supervisors are expected to:■Ensure that their team members understand their
responsibilities under the Code of Ethics and otherpolicies through day-to-day discussion of ethical conduct.

■

Never encourage or direct team members to achievebusiness results at the expense of ethical conduct orcompliance, and stop violations.

■

Create an environment where they feel comfortableraising concerns without fear of retaliation.
7

Raising Concerns/Speaking Up
Raising and discussing ethics and compliance concerns is a key for our
success because we can address problems at the outset, before they
become bigger issues. If something goes wrong and/or is not working as
designed, please raise your concerns immediately. This is our responsibility.
There are multiple channels for raising your concerns:

Your supervisor
Department head
■ Legal/Compliance Department■ HR Department■ Chief Compliance Officer■■

If you wish to report an ethics and compliance concern anonymously(and anonymity is permissible under your local law), please use the
TEL Group Ethics & Compliance Hotline, a third-party reporting
channel, which is available 24 hours a day, seven days a week, and in
all languages spoken within TEL Group:

TEL Group Ethics & Compliance Hotline at:

URL：tel.ethicspoint.com
Role of TEL Group s Ethics & Compliance Function
TEL Group s Ethics & Compliance function has been established toprevent, detect and correct unethical or non-compliant behavior andto ensure that our business is always on the right legal and ethicalcourse. TEL Group s Chief Compliance Officer, along withmanagement team, is responsible for ensuring TEL Group scommitment to complying with all applicable laws and regulations,as well as the objectives laid out in this Code of Ethics.

8

Company s Response
The Company treats ethics and compliance concerns reported ingood faith very seriously. The Company assigns an investigation
team, conducts an investigation and, if the concern is substantiated,takes corrective actions including disciplinary action if necessary.
The individual who raised the concern will receive feedback on the outcome.
The Company also expects all Officers and Employees of theCompany to cooperate with investigations.

Confidentiality and Zero Tolerance of Retaliation
Confidentiality is required and should be respected for an effective
investigation. Where possible, keeping investigations confidential isin the best interest of the Company and investigation participants
such as the reporter, the subject of the investigation and witnesses.
Information will only be disclosed as required by legitimate needs ofthe investigation. The Company requests all the participants tomaintain confidentiality, and this requirement also extends equally
to investigators and management. Breach of confidentiality is
grounds for disciplinary action.
The Company will not tolerate retaliation against those who report
ethics and compliance concerns in good faith. No one is permitted toengage in retaliation, or any form of retaliatory behaviors, against
another for reporting ethics and compliance concerns in good faithor cooperating with an investigation. If you feel you are being
retaliated against, please immediately contact any of the channels
available to you. Retaliation is grounds for disciplinary action.

9

1 Business Practices

Mutual trust is at
the foundation of our work
We strive to continue the business growth of TEL Group,and this cannot be achieved without mutual trust.
Each officer and employee must earn the trust of others,
being committed to high ethical standards and fairness inall activities.

1｜Business Practices

1-1 Safety and Quality
We pursue safety in our businessactivities – development,
manufacturing, transportation,
installation and maintenance of our
products – and provide the highest
quality products and services thatmeet customer expectations.
■

We achieve the above goals by meeting or exceeding
all legal and regulatory requirements and throughthe rigorous application of our safety and quality
management system and processes.

■

We implement effective and preventive processes,
and if appropriate, corrective actions to assure thatour business activities are conducted safely, andthat the highest quality products and services aredelivered by the Company.

For the TEL Group Safety Policy, please refer to the following
website at:https://www.tel.com/csr/safety/safety-management/
For the TEL Group Quality Policy, please refer to the following
website at:https://www.tel.com/csr/quality/quality-management/12

1｜Business Practices

1-2 Suppliers
We select suppliers based on
objective criteria and review their
qualifications by ensuring thatthey comply with laws andregulations as well as our businessethics.
■We select our suppliers based on objective criteria,such as quality, technology, price, delivery times,
compliance and other reasonable standards.

■

As a part of the global supply chain where we do ourbusiness, we consider the environmental, social andethical impacts of the Company s supply chain thatare critical in the industry.

■

We require our suppliers to comply with laws andregulations, including in relation to anti-bribery andcorruption, fair competition, forced labor, bonded
labor, child labor or modern slavery, and to respect
our business ethics. At the same time, we continue
to work respectfully with our suppliers and continue
to build strong partnerships with them.

■

We do not accept raw materials or materials that
contain conflict minerals which have been obtained
illegally by use of child labor or modern slavery, or
through other abuses of human rights.
For the TEL Group Procurement Policy and Procurement
Policy – Supplement, please refer to the following website at:https://www.tel.com/csr/procurement/procurementmanagement/13

1｜Business Practices

1-3 Export & Import
We are committed to upholding
all applicable laws and regulations,and our Company s internal rules
regarding the export and importof goods and technology.

■

In any countries or regions where we do business,
we comply with export/import (including re-export)
laws and regulations, licensing requirements,
embargoes and other restrictions that have been
approved by recognized national and international
authorities.

■

When importing/exporting our products or
technology, we follow the import/export
requirements of the applicable government
agencies of countries or regions and provide
accurate, truthful and complete information about
our products, technology and other items tocustoms and other relevant authorities.

●

14

Many countries where we do business have laws in place
which regulate the import/export of goods andtechnology. The United States has controls which
restrict the export of certain products (e.g. services,
technical data and software) to other countries, as wellas the re-exporting of those items from a country otherthan U.S.to another non-U.S. destination.

1｜Business Practices●●

As for exporting, the classification and content of
products or technology, final destination, and end
user need to be confirmed in accordance with laws
and regulations in many jurisdictions.
Trade restrictions (e.g. sanctions, embargoes, anddenied-parties lists) seek to prevent or limit trade withspecific entities and, in some cases, entire countries.
TEL Group is committed to screening the parties withwhom we do business.

15

1｜Business Practices

1-4 Fair and Open
Competition

We strive to operate in a fair,
open and competitivemarketplace.
■

We are committed to complying with all competition
laws in the markets where we do business and do not
engage in illegal anti-competitive activities.

●

●

●

Competition laws and regulations in the markets
where we do business, such as the U.S. and EU, haveextraterritorial application.
Investigations by competition authorities may resultin significant fines and costs, and incur damage to our
reputation. Criminal sanctions may also apply, andthe Company may be liable for civil damages.
The following are examples of conducts that arealways illegal:▶

Competitors agreeing or taking concerted actions
regarding:・prices or any price components, terms and conditions,・product or territory allocation or sharing,・boycotts, or・limits on production, sales, inventory or researchand development.

16

1｜Business Practices▶

Employing unfair or deceptive trade practices or
methods that generally fall within the scope of
unfair competition laws, such as:・misleading advertising,・disparaging a competitor s product,・harassing a competitor, or・stealing trade secrets or other confidential

business information.

●

The following are examples of conducts that may beconsidered illegal and may result in high fines in many
countries:▶

Dominant companies taking actions that appear tobe efforts to control a market, such as:・tying or requiring bundling of separate products,
・unfairly terminating dealers, distributors or suppliers,
・discriminating on price,・selling below cost (predatory pricing), or・imposing overly restrictive exclusive dealingarrangements.

17

1｜Business Practices

1-5 Bribery and Corruption
We do not bribe anyone,
anywhere, for any reason
under any circumstances.
■

We are committed to complying with all applicableanti-corruption laws, rules and regulations, andnever offer or give a bribe or allow others to bribe on
our behalf.

■

We do not make Facilitating Payments＊ even if allowed
under local law or if doing so is common in society.

■We follow the Company s internal rules when giving
or receiving gifts, meals, travel and otherentertainment.

■

We only do business with third parties who we know
do business with integrity, after conducting
appropriate due diligence. When third parties
engaged by TEL Group participate in misconduct orviolate the law, they put TEL Group at risk for legal
violations and reputational harm.

●

18

Bribery occurs when anyone authorizes, offers, solicits,
gives, receives or accepts anything of value, or any
financial or other advantage, in exchange for favorable
treatment by a company, government authority,
official or employee or relating to their duties. In China,
for instance, we should understand that the local lawsalso regulates commercial bribery. It would be illegal
even if the recipients are their close relatives.

1｜Business Practices

●

●

●

●

A "bribe" typically takes the form of cash, but also
includes entertainment (e.g. meals and beverages,
attendance of sporting events and performances),
gifts, tours in connection with visits to Company
facilities, travel invitations (e.g. training trips lacking a
legitimate purpose), healthcare services, employment
including employment of relatives of Public Officials
and sexual services, etc. Payment made in disguise of
donations or sponsorships could also constitutebribes.
Most countries enforce laws prohibiting bribery andcorruption. Many of these laws apply even when thewrongful conduct is committed outside the country s
own borders and/or by citizens of other countries,
such as the UK Bribery Act 2010 and the US Foreign
Corrupt Practices Act 1977.
Violations of these laws can result in criminal andcivil liability, including prison sentences and fines forindividuals.
The Company will conduct periodic anti-corruption
training for all directors and officers, and, whereappropriate, employees, agents and business partners.

＊Facilitating Payment – a small payment paid to public officials to facilitate

non-discretionary actions or services such as obtaining an ordinary license,
business permit or visas.

19

1｜Business Practices

1-6 Conflicts of Interest
We make fair and objective
decisions in the best interest of
the Company, and avoid any
action that puts our personal
interests ahead of those of theCompany s.
■

We have a responsibility to avoid activities whichconflict or appear to conflict with our professional
responsibilities. Even the appearance or perception ofa conflict of interest can place the Company at risk.

■

We should never allow personal gain or benefit toprevent us from doing what is in the best interest of
the Company. Examples are:▶

Receiving personal privileges from a supplier;▶ Concurrent employment as a board member or as an
employee of another company or organization;▶ Business with a company that a close relative or friend
manages/owns;▶ Bringing an unjustifiable financial interest in any
company or a current or prospective customer, supplieror competitor of the Company or receiving improper
personal benefits or gifts;▶ Supervising the job performance or compensation of a
relative or romantic partner as a part of the day-to-day
job duties;▶ Engaging in an activity which competes directly or
indirectly with the Company; and▶ Engaging in any transaction that involves a former
Company employee or officer or any close relative ofsuch ex-employee in providing goods and services.
20

1｜Business Practices●●

A conflict of interest occurs when a personal
relationship or activity exists that may influence ourjudgment or ability to perform our job objectively or
to uphold our duties to the Company.
It is our responsibility to disclose any actual or
potential conflicts of interest to the Company
voluntarily and proactively. In most cases, disclosed
conflicts can be cleared by an open and transparent
discussion.

21

1｜Business Practices

1-7 Political Activities

and Contributions
We do not, directly or
indirectly, support or makecontributions to politicalparties or candidates using
Company finances or assets.

■

We are committed to complying with all applicablecampaign finance laws, rules and regulations.

■

While TEL Group does not support or contribute topolitical parties or politicians including candidates,
employees may offer support and contributions＊ topolitical groups in a personal capacity and on theirown time.

■

We ensure that:▶

▶

Any contributions towards, and support for, politicalparties are clearly personal and give no impression of
being connected to TEL Group; andNo personal political support or contributions affectperformance or objectivity on the job.

＊Support and contributions include financial contribution, benefits in kind, gifts,

sponsorships and use of any Company resources.

22

1｜Business Practices

1-8 Money Laundering
TEL Group does not receive theproceeds of criminal activities,
as this can amount to thecriminal offence of money
laundering. Nor do we engage
in any relationships with
antisocial organizations.
■

We are committed to complying with all applicableanti-money laundering laws, rules and regulations.

■

We look out for warning signs of money laundering,such as:▶

Supplier requests to:・Pay funds to a bank account in the name of a third partyor outside their country of operation;

・Make payments outside the normal form of business;
・Split payments to several bank accounts; or・Overpay.
▶

Customer payments to TEL Group:
・From multiple bank accounts or ones overseas when

not a foreign customer;

・Made in cash when normally made by checks orelectronically,

・Received from third parties; or・Made in advance when not part of normal terms ofbusiness.

23

1｜Business Practices▶

Use of a paper company and P.O. Box as the third party
address▶

Transactions that do not make obvious commercial
sense

■

We do not do any business with antisocialorganizations and firmly refuse improper demands
from such organizations.

■

The Company conducts appropriate due diligenceon certain customers and vendors to identify
potential money laundering risks.

●

If you suspect money laundering or transaction with
antisocial organizations, please consult with your
Legal/Compliance Department immediately.
Money laundering – the illegal process ofconcealing the origins of money obtained illegallyby passing it through a complex sequence ofbanking transfers or commercial transactions.
Antisocial organizations – refers in Japan to gangs andother parties who hinder social order and safety of
citizens and/or business activities by gaining economic
benefit with unfair demands through violence, threat,
and fraud. Such organizations may disguise theirintentions to take advantage of innocent citizens
by masquerading as ordinary businesses ororganizations seeking donations or participation inbusiness, sending unsolicited publications anddemanding payment or subscription in return, etc.

24

1｜Business Practices

25

2

Our Assets &PropertyResponsible disclosure andguarding of information
We disclose financial and accounting details whenappropriate, and have the responsibility to guard
important information assets and intellectual property.

2｜Our Assets & Property

2-1 Accounting/Tax/

Financial Reporting
We prepare financial documents
in a timely, accurate and appropriatemanner, disclosing all accounting andfinancial reports in accordance with
relevant laws and regulations,and generally accepted
accounting principles.

■

We document and reflect the Company s businessactivities and economic information including
financial statements, expense reports, contracts,
internal & external reports and tax filing in a timely,
accurate and complete manner based on facts andevidence and accordance with related laws andregulations, accounting principles and internal rules.

■

We keep business records in accordance with applicablelaws and regulations, and the Company s own internal
rules regarding the preparation of such documents.

●

We assure that documents and records related tointernal and external investigations or audits, as well as
pending or potential litigation, be retained properly
upon request from our Legal Department
and/or any other relevant departments.
For the TEL Group Tax Policy, please refer to thefollowing website at:https://www.tel.com/csr/related-policy/28

2｜Our Assets & Property

2-2 Insider Trading
We do not use material
non-public or non-disclosed
inside information about TELGroup or any other company,
including suppliers and customers,
to buy, sell, or otherwise transact
in securities of TEL Group or any
other publicly traded company.
■

We do not make profits by trading securities usingmaterial non-public or non-disclosed inside
information.

■

We do not recommend or suggest to others to buy,sell, or otherwise transact in securities using material
non-public or non-disclosed inside information.

■

We do not communicate regarding material non-public
or non-disclosed inside information to others who
might trade on the basis of such information, tip theinformation to others, or otherwise misuse theinformation, whether verbally or by any other means.

●

Examples of inside information include the following:▶

Business results or forecasts for a company▶

Changes in management or board of directors orother governing body of a company▶

Major new product, product claim or productincident/issue29

2｜Our Assets & Property

●

●

▶

Loss, delay or gain of significant contract, sale or order▶

Acquisition, merger or divestment▶

Major developments in litigation cases or in
dealings with regulators or governments▶

Revisions in dividend policy▶

Issuance of stock and stock acquisition rights, stockbuy-back, and stock split▶

Changes in or dispute with a company independent auditor▶

Default in debt or bankruptcy filing

Trading or encouraging others to trade on material
non-public or non-disclosed inside information, or
giving it to unauthorized parties, is a criminal offense
in many jurisdictions. A breach of the applicable laws
can lead to fines and/or imprisonment against theindividual who passed the information even if he/she
does not personally gain.
Trading securities through third parties such as family
members, friends, and/or agents, is also not allowed.
Insider Trading – the buying or selling of a security(e.g. shares, equities and related derivatives) of alisted company by investors (individuals or legal
entities) with access to non-disclosed material
information (inside information) about thecompany. This is prohibited by laws, and theCompany is committed to complying with allapplicable insider trading laws, rules and regulations.

30

2｜Our Assets & Property

2-3 Intellectual Property
We respect intellectual
property and protect,manage, and utilize it
appropriately.
■

We are committed to complying with all applicable
intellectual property laws, rules and regulations, andwe secure and protect the use of these valuable assets.

■

We take precautions to protect our intellectual
property and confidential business information.

■

We do not use TEL Group intellectual property andconfidential business information outside of theoffice without permission.

■

We respect and do not misuse intellectual property
and confidential business information of others. We
do not use other s intellectual property andconfidential business information withoutauthorization or an appropriate license.

●

Below are some examples of intellectual property rights:
・Patent Right ・Utility Model Right ・Design Right
・Trademark ・Copyright・Trade secret●

We do not discuss or share TEL Group or third party
intellectual property and confidential businessinformation in public places, such as airports andrestaurants.

31

2｜Our Assets & Property

●

●

●

32

We do not bring to TEL Group any intellectual
property and confidential business information of aformer employer or other third party, or utilize for the
benefit of or disclose to TEL Group any intellectual
property and confidential business information of any
former employer or third party, without prior written
authorization from the former employer or third
party and unless necessary to further a businesspurpose.
We immediately notify the Company, in thedesignated manner, when in the scope of our work
we create an innovation, invention, idea, design using
the physical or technical assets of TEL Group.
We consult with the designated department before
using TEL Group intellectual property, such as
trademark or copyright, outside the Company.

2｜Our Assets & Property

2-4 Information Security
We protect TEL Group confidential
business information as well as
any confidential businessinformation that is entrusted to
the Company by our customers
and business partners, andprevent information leakage by
maintaining a reasonable andappropriate information
management framework andcomplying with rules concerning
the handling and protection ofconfidential business information
including personal information.
■

We appropriately protect and manage confidential
information such as technical and sales information,and only use TEL Group confidential businessinformation for legitimate business purposes or as
required by law.

■

We do not misuse or improperly obtain confidential
business information from third parties.

33

2｜Our Assets & Property

●

●

●

●

34

We define the classification of information and scopeof disclosure, control such information, and only
disclose confidential business information on an
as-needed basis and in accordance with company
policy. Examples of confidential information are:detailed sales information, business performancetargets, key performance indicators, productstrategies, new product and technology, pending
personnel announcements, manufacturing processes
and equipment designs, and contracts withcustomers.
We take care not to disclose confidential businessinformation in public places, including taking allnecessary steps to protect documents and IT devices
away from the workplace.
We do not disclose confidential information beyond its
authorized limits while employed at the Company.
Upon the end of employment, we must erase, destroy
or return electronic files and material objects that
contain confidential information, and shall sign written
acknowledgement of such action. It is absolutely
impermissible to keep the confidential information after
the end of employment.

2｜Our Assets & Property

●

●

●

Below are some examples of methods to prevent
information leakage and loss:▶

Do not open an attachment and/or URL when you
receive a suspicious email;▶

Do not let others know or use your password;▶

Pay close attention to the companies devices withconfidential information; especially when outside
the Company, in transit, etc.;▶

Ensure any removable TEL Group IT equipment,
including devices, are secured when left in the officeovernight and are locked away or out of sight whenleft unattended off premises; and▶

Do not install software without Company s approval.

The Company may monitor, record or use any
communication made by using the Company s
information system (e.g., email and internet) to theextent permitted by local laws and regulations.
Officers and Employees must immediately report theloss or theft of any TEL Group equipment, or any
personal device used to store TEL Group informationor any actual or potential incidents of information
leakage to the information security department.
For the TEL Group Information Security Management,
please refer to the following website at:https://www.tel.com/about/riskmanagement/35

2｜Our Assets & Property

2-5 Personal Data
We respect the privacy of all
individuals and confidentialityof Personal Data and handle
Personal Data with utmost
care and take measures topromote the appropriate
handling of Personal Data.
■

We comply with each country/region s law,regulations, and internal Company rules regarding
Personal Data protection. We collect, use and retain
Personal Data on a minimum basis to the extent ourbusiness needs and dispose it when no longer
necessary.

■

We always consider the privacy risks before wecollect, use, or retain or disclose Personal Data, suchas in a new system or part of a project.

■

We endeavor to keep Personal Data accurate andup-to-date.

■

We protect the Personal Data we hold by ensuring
we have effective safeguards in place so it does not
fall into the wrong hands.

■

We are transparent with individuals about how weuse, disclose or transfer their Personal Data. We also
make it easy for individuals to access and correct
their information.

36

2｜Our Assets & Property●●

Personal Data is information about any existing
individual including the following:▶

information that can identify a specific individualsuch as name, date of birth or other descriptors▶

information that can be collated with otherinformation and can identify a specific individual

Many of the laws and regulations related to Personal
Data are extraterritorially applied; therefore, whenhandling personal information, it may be necessary tounderstand and follow not only the laws and regulations
in your country, but also the other country/region.
For the personal information protection policy,
please refer to your market s specific policies.
If you receive any contacts from outside parties
regarding the usage of personal information of
TEL Group or data breach, immediately consult withyour local Legal/Compliance Department.

37

2｜Our Assets & Property

2-6 Company Assets
We do not improperly use
company assets for ourown personal benefit.
■

We rely on company assets to support our work
every day. We use computers, mobile devices,
information technology hardware and software,
vehicles, facilities, intellectual property, supplies
and other assets with our care and for legitimate andappropriate business reasons.

■

We do not use, waste or take the property of
TEL Group out of the Company s facilities without
the Company s permission regardless of whether it istangible or intangible.
●●●

We may not install software that the company purchasedon a home PC, or use a company PC for personal purposes.
Improper usage of company assets (as above) would
not only be a violation of the internal rules but could
also constitute a criminal offense.
Below are some examples of assets that areconsidered company assets.
Tangible

Intangible

Facilities

SoftwareEquipment(customer information, market share information etc.）

Raw materials
Office supplies

38

Confidential Information

Intellectual property rights
such as patent rights

2｜Our Assets & Property

39

3 Our Workplace

Teamwork through diversity
TEL Group promotes a workplace where employeesinteract respectfully and work with peace of mind.
In so doing, we nurture the unique abilities of TEL Group s
diverse members working together to become anorganization that makes full use of their talents.

3｜Our Workplace

3-1 Human Rights & Fair

Employment Practices
We are committed to fostering aworkplace that is respectful,inclusive and safe by promoting
human rights and diversity andcomplying with all laws andregulations pertaining to labor
practices, freedom of association,collective bargaining, andimmigration. We also do not
engage in discrimination or
support forced labor, debt labor,child labor or any other form ofmodern slavery.

■

We make all employment-related decisions basedon merit.

■

We respect each other, and do not discriminate on
the basis of race, color, age, gender, sexual
orientation, gender identity and expression,
ethnicity or national origin, disability, pregnancy,
religion, political affiliation, union membership,covered veteran status, protected genetic
information, marital status, childcare/nursing
responsibilities, or any other protected personal
characteristic under applicable law.

■

We respect and strive to understand different
customs and values of our colleagues.

42

3｜Our Workplace●●

TEL Group respects the human rights described in the
UN Guiding Principles on Business and Human Rights,
the International Bill of Human Rights, and the ILO
Declaration on Fundamental Principles and Rights at Work.
TEL Group considers that the following human rights
are particularly important:▶

freedom, equality & non-discrimination▶

freely chosen employment▶

product safety & workplace health and safety▶

freedom of association▶

appropriate working hours &breaks/holidays/vacations
For the Tokyo Electron Group Human Rights Policy,
please refer to the following website at:https://www.tel.com/sustainability/managementfoundation/human-rights/index.html

43

3｜Our Workplace

3-2 Workplace Free ofHarassment

We do not allow any form ofharassment and are committed tocreating and safeguarding anenvironment where every person feels
respected and valued, and where
everyone is treated equally and fairly.
■

We respect each person as an individual andendeavor to create a working environment thatallows people to fully display their abilities.

■

We do not engage in any behavior that is offensive,
intimidating, malicious or insulting. This includes any formof sexual or other harassment or bullying, whether
individual or collective and whether motivated by race,color, age, gender, sexual orientation, gender identity andexpression, ethnicity or national origin, disability, pregnancy,
religion, political affiliation, union membership, covered
veteran status, protected genetic information, marital
status, childcare/nursing responsibilities or any otherprotected personal characteristic under applicable law.

■

We do not engage in any behavior which could be construed
as sexual or other harassment or bullying, such as making
offensive or sexually explicit jokes or insults, displaying,emailing, texting, or otherwise distributing, offensive
material or material of a sexually explicitly nature,
unwelcome sexual advances or engaging in any otherconduct with sexual overtones, misusing personal
information, creating a hostile or intimidating environment,
isolating or not co-operating with a colleague, or spreading
malicious or insulting rumors.

44

3｜Our Workplace■

Violence and threats of violence are also
unacceptable.

■

All supervisors are responsible for promoting andmaintaining a harassment-free work environment.

●

●

●

●

TEL Group deals with any type of harassment
seriously; discipline may include termination of
employment.
There will be no tolerance for retaliation against
those who have reported concerns regardingharassment in good faith.
Harassment is unwelcome and offensive conduct that
may interfere with a person s ability to perform his or
her work. Harassment does not require intent tooffend. Inappropriate conduct meant as a joke, aprank or even a compliment can lead or contribute toharassment.
Sexual harassment can entail the harassment of awoman by a man or a man by a woman, as well assame-gender harassment.
The workplace means not only the regular placesof work, but other places where meetings andinteraction among personnel may occur, including
customer facilities, restaurants, and other social
settings.

45

4

Responsibilities to
the PublicA symbiosis of people, society,and nature
We strive for our business activities to be in harmony withthe global environment as well as the success of ourcommunities. We continue in the pursuit of cutting-edge
technology and working toward a sustainable society.

4｜Responsibilities to the Public

4-1 Environmental
Preservation

We are committed to upholding
laws and regulations related toenvironmental protection andconservation, and conductbusiness activities while maintaining
harmony with the global environment.
■

We strive to produce environmentally friendly
products with the TEL Group Environmental Policy.

●●

In order to reduce the burden on the environment,
we aspire to promote the creation of environmentallyfriendly products from the product development
stage stated as below:▶

Limiting materials used and waste generated;▶

Using recyclable products; and▶

Placing priority on the use of safer alternatives tohazardous substances.

It is important to understand that technologicaldevelopment may entail risks to the life and assets ofindividuals as well as to the global environment.
For the TEL Group Environmental Policy, please refer tothe following website at:https://www.tel.com/csr/environment/
environmental-management/48

4｜Responsibilities to the Public

4-2 Corporate Social
Contribution

We strive to build solid,
trustworthy relationships with
community members to help
develop local communities andresolve social issues at the global
level through various activities.
■

Our social contribution activities are based on
the principles of the corporate philosophy,
in accordance with the TEL Group Social Contribution
Guidelines, and are working in line with the United
Nations Sustainable Development Goals (SDGs).

■

We follow proper procedures when making
donations through TEL Group initiatives.

For information on TEL s Social Contribution, please referto the following website at:https://www.tel.com/csr/contribution/

49

My Code of Ethics
As a member of TEL Group striving for sustainablegrowth together, I am:

Committed to doing the right things,
Aware of risk around us, andKnowledgeable on doing things right.

Note:

Establishment: August 14, 1998
Revision: April 1, 2023
Publisher: Tokyo Electron Limited