Compliance
The TEL Group acts in strict compliance with corporate ethics and applicable laws to ensurethat its corporate activities are fair and reliable.
Compliance & Internal Control
Executive Officer

Trust is the cornerstone of the TEL Group’ business

Since April 2009, Tokyo Electron has appointed Compliance &foundation. The fundamental requirements for maintaining

Internal Control Executive Officer from among its executive

trust are rigorous conformity to ethical standards andofficers to raise awareness of compliance across the Group

compliance with the law, by individual employees and by eachand further improve its implementation.

of our organizations.
the Tokyo Electron Group, all Group employees are required

Framework for ThoroughImplementation of Complianceto maintain high standards of ethics and to act with a clear

Tokyo Electron has drawn up compliance regulations setting

awareness of compliance.

out basic compliance-related requirements in line with its CodeIn line with the basic policy for internal control systems inCorporate GovernanceCompliance

Stance on Corporate Ethics and Legal
Complianceof Ethics. The compliance regulations are intended to ensure

Ethical Standards, Chief Business
Ethics Director and Ethics Committeethat all individuals who take part in the business activities ofIn 1998, the Company formulated the Tokyo Electron Code ofinternational standards, and internal company rules andEthics (revised in June 2007) to establish uniform standards

continuously apply these rules in all of their activities.

the Group clearly understand the pertinent laws, regulations,to govern all of its global business activities.
In the same year, Tokyo Electron appointed a Chief(1) Internal Reporting System
In the event that an employee becomes aware of any activity which

Committee, which is responsible for promoting awareness of

may violate laws, regulations or principles of business ethics,

business ethics throughout the Company.

the Company operates an internal reporting system (hotline) that

The Tokyo Electron Code of Ethics prescribes a commonemployees may use to report their concerns. Strict confidentiality

code of behavior for all employees of Tokyo Electron and theis maintained to protect the whistle blower, and to ensure that theyGroup and the Company distributes it to all Group employees,

are not subjected to any disadvantages or repercussions.

HIGHLIGHT

Business Ethics Director and established the Ethics

including those overseas.
Tokyo Electron conducts Web-based training programs for

The Code of Ethics of the Tokyo Electron Group

all its employees, makes information on compliance issue

Introduction

available to employees via the Company intranet, and takes

I. 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

15. Prohibition of Insider Trading
16. Prohibition of Political Activities and Contributions
17. Prohibition of Involvement in Antisocial Forces
18. Respect for Individuals
Implementation of the Code of Ethics** The “Implementation” section provides specific mattersand procedures(3) Management of Information on Japanese Laws
In order to reduce the risk of legal compliance violations, Tokyo
Electron regularly identifies and clarifies the Japanese lawsthat 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
taken such as amending regulations, changing operational
procedures, and notifying all personnel affected by the revisions.

(4) Protection of Personal Information
When the Act on the Protection of Personal Informationcame into full effect, the Tokyo Electron adopted a basic
policy and regulations concerning the protection of personal
information and prepared various manuals regarding thehandling of personal information. Tokyo Electron has also
been conducting Web-based training for employees and taking

SOCIAL REPORTIII. Being a Good Corporate Citizen

throughout the Company.

EHS REPORTII - 1 Technology, Safety, and the Environment
4. Ensuring Safety and Pursuing Quality
5. Promoting Environmental Preservation Activities
6. Ethics in Manufacturing
II - 2 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
II - 3 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

other steps to promote broad awareness of compliance

MANAGEMENT REPORT(2) Employee Training

other measures to ensure the proper implementation of thesepolicies and regulations in business operations. In addition,Tokyo Electron has been strengthening personal informationmanagement through such measures as installing computer
servers specially equipped to handle the storing of personal
information, introducing encryption functions, and using
auxiliary storage units with password-based access control.

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