The Tokyo Electron GroupCSR Policy
Code of Ethics
I. Principles
1. Compliance with Applicable Laws

Tokyo Electron Group board members and employees must comply at all times with the applicable laws and regulations of each country and region as
well as with international regulations, in doing the global business activities, while abiding with corporate ethics and putting them into practice in a spiritof good faith.
Tokyo Electron Group board members and employees must act in accordance with social conscience based on a high ethical awareness.

2. Acting in Accordance with SocialConscience
3. Maintaining Harmonious Relationships Tokyo Electron Group board members and employees must be aware that both themselves and the company are members of their local communities,
with Local Communities
and must strive to achieve mutually beneficial development while collaborating with these communities.
II. Honest and Fair Business Activities
II-1 Technology, Safety, and the Environment
4. Ensuring Safety and Pursuing
Quality
5. Promoting Environmental
Preservation Activities
6. Ethics in ManufacturingII-2 Fair Trade
7. Implementing Fair and OpenCompetition
8. Fair Business with SuppliersTokyo Electron Group board members and employees must ensure safety and pursue quality in all their business activities including development,manufacturing, sales, service, and administration.
Tokyo Electron Group must conduct its business activities while maintaining harmony with the global environment.
Tokyo Electron Group board members and employees must engage in manufacturing with a high ethical awareness and a spirit of good faith.
Tokyo Electron Group must not engage in any conduct that hinders competition in fair and open markets.

Tokyo Electron Group selects suppliers based on fair standards. When conducting business with suppliers, we must not use our dominant bargaining
position in a transaction to unfairly harm the interests of suppliers.
Tokyo Electron Group board members and employees must strictly manage confidential information of the company with special care and must notdisclose or improperly use confidential information during the term of their employment or after retirement from the company without following theproper procedures according to the company’s internal regulations and non-disclosure agreements. In addition, the confidential information of othercompanies must be respected and properly managed and must not be obtained by improper means.
10. Strict Export/Import Controls
Tokyo Electron Group board members and employees must comply with all applicable laws and the company’s regulations based thereon concerning
the import and export of goods and transfers of technology.
11. Reasonable Exchanges of Gifts
Tokyo Electron Group board members and employees must not give gifts to, or receive them from, a company or individual based on a businessand Entertainment within therelationship, beyond the bounds of common business practice in the relevant location. Giving or receiving gifts of cash or cash equivalents is prohibited,Bounds of Common Sense
regardless of the amount (except for purposes recognized as appropriate in common practice, such as condolences or expressions of sympathy insome countries and regions).
Furthermore, entertainment with companies or individuals with whom one has a work-based relationship must be carried out moderately within thebounds of common sense.
II-3 Relationship between the Company and Individuals
9. Handling of ConfidentialInformation

12. Prohibition of Conduct Causing
Conflicts of Interests
13. Prohibition of the Improper Use ofCompany Assets
14. Prohibition of Conduct ofHarassment
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
Personnel Policy
Respect for Human Rights
Diverse Workforce
Human Resource Development
Employee Assessment andTreatment
Occupational Safety and HealthWork-Life Balance
Safety Policy
Safety First
Pursuit of Safe Technologies
Management and Employees
Responsibility
Legal Compliance
Collaboration and Cooperation withSociety
Quality Policy
Quality Always
Quality Design and Assurance
Quality and TrustContinuous Improvement Activities
Communication with Stakeholders
Environment Policy

Tokyo Electron Group board members and employees must not, without due cause, engage in conduct that is, or appears to be, to their own personal
benefit and contrary to the interests of the company (conduct causing conflicts of interests), or which runs the risk of leading to such conduct. Inaddition, Tokyo Electron Group board members and employees must not use their position in their work for their own personal benefit.
Tokyo Electron Group board members and employees must not improperly use company assets for their own personal benefit.
Tokyo Electron Group does not allow any form of harassment in the workplace.

Tokyo Electron Group board members and employees must not engage in the purchase or sale of stocks on the basis of information not disclosed to thepublic that they obtained in connection to their work duties or business transactions (insider trading).
Tokyo Electron Group board members and employees must not engage in political activities at the workplace. In addition, Tokyo Electron Group does
not make donations of money or company assets to politicians (including candidates) or political parties.
Tokyo Electron Group must not have any relationship, including business relationships, whatsoever with antisocial forces that are likely to disrupt thepublic order, safety of the public, or corporate activities. In addition, Tokyo Electron Group must not provide any financial support or accommodation for
any reason to antisocial forces.
Tokyo Electron Group prohibits discrimination on the basis of gender, nationality, age, race, creed, religion or any other reason, while respecting each
person as an individual. Tokyo Electron Group does not use forced labor or child labor.
We respect the character and individuality of each person and strive to create work environments without any infringement of human rights.
We strive to respect and understand differences in values arising from gender, nationality, age, race, creed, religion, and other attributes and to be acorporation where a diverse range of employees can work to their full potential.
We believe that each employee is the source of value creation and support the development of skills by employees.
We provide opportunities to those employees with the enthusiasm for personal growth and engage in fair evaluation of skills and employee treatment sothat employees with significant results can be rewarded.
We place the highest priority on ensuring the safety and health of employees and maintain environments such that employees can work safely at ourworkplaces and local residents feel a sense of reassurance.
We implement measures to enable employees to achieve a good work-life balance.
Based on the principle of “safety first,” we strive to create safer products and work to maintain and improve the safety of all people involved with ourproducts and healthy workplace environments.
With an awareness of the factors that impair safety and health in our various business activities, we continuously strive to create safer and more secure
workplaces by making improvements concerning those factors and through intrinsically-safe equipment designs and superior service capabilities.
All employees maintain an awareness of potential problems and of the need for improvement concerning the maintenance and enhancement of safety
and health at all workplaces, and management and employees act in accordance with their respective responsibilities.
We comply with safety and health laws and regulations and international rules, take into consideration industry guidelines, and strive to promote safetyand health.
Based on common understanding with a broad range of stakeholders, we cooperate and collaborate with society and work to appropriately meet theirexpectations.
Quality is not only the foundation for customer satisfaction, but also the foundation for meeting expected production schedules and reducing downtime.
We prioritize quality over temporary cost increases.
We build quality into every TEL product during the design phase by focusing on leading-edge technology. By bringing quality into our processes earlyand focusing on quality throughout all processes, we succeed in providing high quality products and services.
When we find a quality problem, manufacturing, sales and service departments analyze the facts and complete a thorough investigation to determine
the cause, resolving the problem as quickly as possible. Our customer can trust in our commitment to address identified quality problems.
We improve quality with an effective quality management system. This includes using quality measures, improving by applying the PDCA cycle, andpracticing continuous improvement activities.
In addition to providing product quality information in a timely manner, we understand and align to the expectations of our stakeholders.

Environmental Goals and Continuous We continually enhance its knowledge of environmental issues to establish voluntary goals that are reviewed by Executive Management and drive
Improvement
continuous improvement and full regulatory compliance.
Promotion of Environmental Technology We aim to invest in the development of leading-edge, high value products and services that directly contribute to a sustainable society.
Environmental Contribution withWe develop eco-friendly products through our leading-edge technology. Group cooperates with our customers and suppliers to strive for the prevention
Productand improvement of a wide range of environmental concerns.
Operational Environmental Impact
We quantitatively analyze and reduce the environmental impact of its global operations with activity from all levels of employees and operations.
Reduction and Preservation
Collaboration and Cooperation with We actively promote collaboration and cooperation with all our stakeholders to achieve mutual understanding and conformance to expectations.
Stakeholders and Society
Procurement Policy
Compliance with Applicable Laws
We engage in procurement activities with integrity in compliance with the laws and regulations of each country and social norms based on our corporate ethics.
and Social Norms
Priority on the Environment
We conduct procurement with full consideration for reduction of environmental impact and protection of the global environment.
Fair Business Practices
We continuously seek high-value technologies and create broad opportunities for their business transactions based on the precondition of opencompetition.
Partnership
We prioritize relationships of trust based on mutual understanding with suppliers and conduct activities in the pursuit of mutual continuous growth.
Information Management
We properly manage the confidential information of suppliers that we obtain in the course of business.

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