Ma n a g e m e n t R e port

Compliance
TEL is determined to carry out sound business activities in accordance with
its corporate ethics and compliance with the law.

TEL’s Approach to Corporate Ethics
and Legal Compliance

Information Disclosures Concerning
Compliance and Emergency Management

Trust is and will always be the lifeline for TEL. The fundamental requirements for maintaining trust are rigorous
conformity to our ethical standards and compliance withthe law, by our employees as individuals, and by each of
our organizations. Our ethics are stated as ethical restrictions on behavior, and legal compliance means to remain
within legal restrictions. Both are necessary in order tomaintain progress of the company in the right direction,
like two wheels of a cart.

We have begun providing information about complianceand risk management over the company intranet. Those
messages contain information on a wide variety of topics,
including division of tasks, compliance programs, BCP*1,C-TPAT*2, management of personal information, personalsafety confirmation system, and ethical standards.

Setting Ethical Standards
We believe that common standards must be applied
throughout our divisions in order to create the globally
excellent company that we envision for ourselves. We
established specific ethical standards in 1998 to clarify ourapproach; at the same time, we established the Ethics
Committee to oversee the implementation of those standards. We have created a booklet titled “Improving our ethics consciousness” (revised in 2002, 2003 and 2004) anddistributed it to our employees in recent years.
Ethical standards at TEL*1 BCP: Business Continuity Plan
*2 C-TPAT: Customs Trade Partnershipagainst Terrorism, an anti-terrorism
program under the auspices of theUS Homeland Security Department,
Bureau of Customs and Border Protection

Compliance and risk management
websiteHotline Established
If a employees member has witnessed speech or behavior which violates ethical or legal compliance standards,
the member can use a special mailbox as a hotline toreport it. The only people allowed to access the contentsof the mailbox for ethical concerns are the ethics chairman
and members of the Ethics Committee. The confidentialityof all information in those messages is guaranteed. Thechairman and committee are committed to protecting thereporter’s privacy while investigating the complaint fairlyand honestly.

1Competitors

2

Reciprocal Transactions

3Conflict of Interest

4

Giving and Receiving Gifts

5

Political Contributions Prohibited

Protection of Personal Information

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Antisocial Movements and Organizations

7Environment

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Safety9Respect for Human Rights

Identity theft is becoming a major social problem. This has
spurred calls to companies to take all appropriate carewith the personal information they hold. TEL is very conscious of the law specifying protection of personal information, which went into effect in April 2005, and has
released a basic directive and regulations for protection ofpersonal information. We are moving as quickly as possible to establish detailed rules and finalize a security management system for guarding that information.

10 Harassment
11 Improper Use of Company Assets
12 Investment in Stocks
13 Handling Trade Secrets
14 Execution

Compliance Training
TEL has instituted a web-based compliance training system in which every employee is required to participate sothat each will be able to correctly understand what compliance is and to do their tasks with the right attitude. This
training presents the topics of compliance in the contextof corporate activities, compliance issues in day-to-day
activities, directives for risk management, and our compliance regulations. Courses were completed by about 6,300
employees in FY 2005.

TOKYO ELECTRON Environmental and Social Report 2005

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