and applicable laws to ensure that its corporate activities areSince April 2009, Tokyo Electron has appointed Compliance &conformity to ethical standards and compliance with the law, byInternal Control Executive Officer from among its executive

individual employees and by each of our organizations.

officers to raise awareness of compliance across the Group andIn line with the basic policy for internal control systems in
the Tokyo Electron Group, all Group employees are required tomaintain high standards of ethics and to act with a clear
awareness of compliance.

Code of Ethics, Chief Business Ethics
Director and Ethics Committee

further improve its implementation.

Framework for Thorough Implementationof ComplianceTokyo Electron has drawn up the Compliance Regulations
setting out basic compliance-related requirements in line with its
Code of Ethics. The Compliance Regulations are intended toIn 1998, Tokyo Electron formulated the Code of Ethics of theensure that all individuals who take part in the business activities

Tokyo Electron Group (revised in April 2011) to establishof the Group clearly understand the pertinent laws, regulations,

uniform standards to govern all of its global business activities.

international standards, and internal company rules andIn the same year, Tokyo Electron appointed a Chief Business

continuously apply these rules in all of their activities.

Ethics Director and established the Ethics Committee, which is(1) Internal Reporting System

responsible for promoting awareness of business ethics

In the event that an employee becomes aware of any activity

throughout Tokyo Electron.

which may violate laws, regulations or principles of businessThis Code of Ethics prescribes a common code of behavior forethics, Tokyo Electron operates an internal reporting system

all employees of Tokyo Electron and the Group, and Tokyo Electron(Hotline) that employees may use to report their concerns.

distributes it to all Group employees, including those overseas.

Strict confidentiality is maintained to protect the whistle blower,and to ensure that they are not subjected to any disadvantages
or repercussions.

The Code of Ethics of the Tokyo Electron GroupI. Principles
1. Compliance with Applicable Laws
2. Acting in Accordance with Social Conscience
3. Maintaining Harmonious Relationships with Local
Communities

II. Honest and Fair Business Activities(A) Technology, Safety, and the Environment
4. Ensuring Safety and Pursuing Quality
5. Promoting Environmental Preservation Activities
6. Ethics in Manufacturing(B) Fair Trade
7. Implementing Fair and Open Competition
8. Fair Business with Suppliers
9. Handling of Confidential Information
10. Strict Export/Import Controls
11. Reasonable Exchanges of Gifts and Entertainment
within the Bounds of Common Sense(C) Relationship between the Company and Individuals
12. Prohibition of Conduct Causing Conflicts of Interests
13. Prohibition of Improper Use of Company Assets
14. Prohibition of Conduct of Harassment

III. Being a Good Corporate Citizen
15. Prohibition of Insider Trading
16. Prohibition of Political Activities and Contributions
17. Prohibition of Involvement in Antisocial Forces
18. Respect for Individuals(2) Employee Training
Tokyo Electron conducts web-based training programs foremployees, makes information on compliance issues available

MANAGEMENT REPORTThe fundamental requirements for maintaining trust are rigorous

EHS REPORT

Trust is the cornerstone of the TEL Group’s business foundation.

Compliance & Internal Control Executive
Officer

Stance on Business Ethics and Compliance

HIGHLIGHT

fair and reliable.

SOCIAL REPORT

Compliance

The TEL Group acts in strict compliance with business ethics

to employees via the Intranet, and takes other steps topromote broad awareness of compliance throughout Tokyo
Electron.
(3) Confirming Information on Japanese Laws
In order to reduce the risk of legal compliance violations, Tokyo
Electron regularly identifies and clarifies the Japanese laws that
affect company operations and regulations. Information
regarding revisions to relevant laws is received in a timely
manner via an external Web service and appropriate responses
are taken such as amending regulations, changing operational
procedures, and notifying all personnel affected by the revisions.
(4) Compliance Survey
In December 2010, the TEL Group conducted an anonymouscompliance survey via the Internet targeting approximately
12,000 employees and executives from its Group companies inJapan and overseas with the purpose to ascertain theunderstanding, penetration and inherent risks regarding
compliance within the TEL Group and to utilize this to develop
improvement measures and prioritize its actions. Going forward,
we will use the results of this survey to continually enhance ourcompliance practices and programs.

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