M ANAG E M E N T R E POR TCompliance
The Tokyo Electron Group acts in strict compliance with corporate ethics andapplicable laws to ensure that its corporate activities are fair and reliable.

The lifeline of the Tokyo Electron Group is trust. The
basis for maintaining this trust is for each individual
employee and organization within the Group to strictly
conform to our corporate ethics standards and comply
with applicable laws and regulations. In carrying out ourbusiness activities, we have placed the highest priority oncompliance with strict ethical standards and laws.

Adopting Ethical StandardsIntroduction

Ⅱ. Honest and Fair Business
Activities
Ⅱ-1 Technology, Safety, and theEnvironment
4. Ensuring Safety and Pursuing
Quality
5. Promoting Environmental
Preservation Activities
6. Ethics in Manufacturing
Ⅱ-2 Fair Trade
7. Implementing Fair and OpenCompetition
8. Fair Business with Suppliers
9. Handling of Confidential
Information
10. Strict Export/Import Controls
11. Reasonable Exchanges of Gifts
and Entertainment within theBounds of Common Sense

Ⅲ. Being a Good Corporate Citizen
15. Prohibition of Insider Trading
16. Prohibition of Political Activities
and Contributions
17. Prohibition of Involvement inAntisocial Forces18. Respect for Individuals
Implementation of the Code ofEthics** The “Implementation” section provides specific matters and procedures.

Measures to Reinforce Compliance Systems
The Tokyo Electron Group adopted Compliance Regulations
specifying basic matters regarding compliance. These

Protection of Personal Information
When the Act on the Protection of Personal Information
came into full effect in April 2005, the Tokyo ElectronGroup adopted a basic policy and regulations concerning
the protection of personal information, while preparing
various guidelines and manuals regarding the handling ofpersonal information. We are also conducting Web-basedtraining for employees, distributing information via ourintranet, and taking other measures to ensure the proper
implementation of these policies and regulations when
conducting business operations. In addition, we identified
personal information stored on PCs loaned to employees
using software to better understand the current status of
personal information.
The Group has also taken a variety of measures
to reinforce the management of personal information,
including: installing servers specially equipped to handle
the storing of personal information, storing important
personal information exclusively on those servers,
restricting employees’ individual access to PCs by using
IC cards, changing passwords periodically, introducing
encryption functions, and using auxiliary storage units withpassword-based access control.

TOKYO ELECTRON Environmental and Social Report 2009

SOCIAL REPORT

Ⅱ-3 Relationship between theCompany and Individuals
12. Prohibition of Conduct Causing
Conflicts of Interests
13. Prohibition of Improper Use ofCompany Assets
14. Prohibition of Conduct ofHarassment

EHS REPORT

Ⅰ. Principles
1. Compliance with ApplicableLaws
2. Acting in Accordance withSocial Conscience
3. Maintaining Harmonious
Relationships with LocalCommunities

MANAGEMENT REPORTThe Code of Ethics of Tokyo Electron GroupHIGHLIGHT

Based on the belief that shared standards are necessary
for the creation of a globally excellent company, we
adopted a “Code of Ethics” in 1998 as a detailed statementof our stance on ethical standards; and that same year
we established the Ethics Committee as an operationalorganization.
We revised the Code of Ethics in June 2007 in responseto the results of a survey on the status of compliance. We
made the code easier to understand and made certainchanges that reflect the current business environment.
To enhance understanding of the Code of Ethics, wealso revised a booklet that contains the code and explains
its content in a Q&A format, which we distributed to
all Group officers and employees, including overseas
personnel.

regulations are intended to ensure proper understandingof applicable laws and regulations, international rules,
and internal rules by all persons engaged in the business
operations of the Group, while also ensuring that conduct
accords with those guidelines at all times.
The Group also has a hotline (internal reportingsystem) for use by employees and others to directly reporton suspected violations of the Code of Ethics or applicablelaws and regulations. Matters are dealt with fairly andin good faith by the Chief Business Ethics Director andthe Business Ethics Committee Chairman in the case ofmatters regarding the Code of Ethics, and by the Directorof the General Affairs Department in the case of mattersconcerning compliance, taking into consideration theemployee who made the report and other factors.
In August 2008, the Compliance Regulations wereadopted for overseas group companies and hotlines wereestablished at overseas sites. In addition, the Groupappointed an Executive Officer in charge of Compliance& Internal Control in April 2009 to raise awareness ofcompliance and strengthen enforcement within the Group.
We are also distributing information concerning thesecompliance-related activities via our intranet, conducting
Web-based training and carrying out other programs toensure that employees understand compliance policies,
thereby raising awareness of compliance and strengthening
our compliance systems.

Compliance

Stance on Corporate Ethics and Legal
Compliance11