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 (collectivelyTEL 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 ofemployment 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 ofEthics 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 thestakeholders?

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 anyquestions 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 ofethics 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.
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Raising Concerns/Speaking Up
Raising and discussing ethics and compliance concerns is a key for oursuccess 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 theTEL 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 effectiveinvestigation. 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 isgrounds 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.

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