Compliance

The Tokyo Electron Group acts in strict compliance with business ethics andapplicable laws to ensure that its corporate activities are fair and trustworthy.

• Stance on business ethics and compliance

pertinent laws, regulations, international standards and internal company
rules, and consistently apply these rules in all of their activities.

Trust from stakeholders is the cornerstone of business activities. In
order to maintain trust, it is necessary to continuously act in rigorous

1 Internal reporting system

conformity to business ethics and compliance. In line with theIn the event that an employee becomes aware of any activity which

Fundamental Policies Concerning Internal Controls within the Tokyo

may violate a law, regulation or principles of business ethics, the GroupElectron Group, all Group employees are required to maintain highoperates an internal reporting system that employees may use to report

standards of ethics and to act with a clear awareness of compliance.

their concerns. The entire Group has established an ethics hotline and• Code of Ethics, Chief Business Ethics
Director, and Ethics Committee

overseas base. In all cases, this system ensures that strict confidentiality
is maintained to protect the whistleblowers and ensure that they are notsubject to any disadvantage or repercussions.

In 1998, Tokyo Electron formulated the Code of Ethics of the Tokyo
Electron Group to establish uniform standards to govern all of its global

2 Compliance education

Business Ethics Director and established the Ethics Committee, which

Through the Group’s e-learning system, we provide a common training

is responsible for promoting business ethics awareness throughout

program covering the basics of compliance, internal control, confidential

the Group. The Ethics Committee comprises the Chief Business Ethics

information management and other topics, which all executives andDirector, the Ethics Committee Chairman, and presidents of major Groupemployees are required to complete, as well as a training program oncompanies in and outside Japan. The members meet semiannually, reportinsider trading and other subjects aimed at different levels of personnel.

on ethics-related issues faced by each company, and discuss measures toWe regularly and actively encourage employees to participate in training

further improve ethical behavior and compliance.

via these programs. We also make information on compliance issues

The Code and its Q&A section areavailable to employees on a dedicated site on our Intranet and take otherpublished in Japanese, English, Korean

steps to promote broad awareness of compliance throughout the Group.

MANAGEMENT REPORT

business activities. In the same year, the company appointed a Chief

HIGHLIGHT

a compliance hotline, and this reporting system is also in place at eachand Chinese, and the company distributes

3 Confirming of information on Japanese laws

including those overseas. Moreover,

In order to reduce the risk of legal compliance violations, we regularly

the Code is appropriately reviewed andidentify and clarify the Japanese laws that affect company operations andrevised in response to changes in theregulations. Information regarding revisions to relevant laws is received inenvironmental and social demand. Thea timely manner via an external Web service and appropriate responses

most recent revision of the Code and Q&A
was in April 2011.

EHS REPORT

it to all Group executives and employees,

are taken, such as amending internal regulations, changing operational
Code of Ethics booklet

http://www.tel.com/environment/corp_governance/compliance/ethical.htm

4 Follow-up on compliance survey
Following a finding by a December 2010 compliance survey targeting• Compliance & Internal Control Executive Officer
Tokyo Electron has appointed a Compliance & Internal Control Executive
Officer from among the executive officers to raise awareness ofcompliance across the Group, and further improve its implementation.

• Framework for thorough implementationof compliancethe executives and employees of all Group companies that there is aneed for education on the issue of workplace harassment, in fiscal 2012
we focused on measures to prevent these types of incidents occurring.
Measures taken include informing all employees of the availability ofa contact point for consultation, as well as providing training to theconsultant staff. In March 2012, we also provided managerial personnel
at Group companies with web-based training on workplace harassment,with approximately 2,300 employees taking part.

Tokyo Electron has drawn up the Compliance Regulations setting out
basic compliance-related requirements in line with the Code. The
Compliance Regulations are intended to ensure that all individuals whotake part in the business activities of the Group clearly understand the13

SOCIAL REPORTThe Code of Ethics of the Tokyo Electron Group:

procedures, and notifying all personnel affected by the revisions.