M A N AG E M E N T R E P O RT

Compliance
The Tokyo Electron Group conducts fair and trustworthy business activities in strict
compliance with corporate ethics, laws, and regulations.

Approach to Corporate Ethics and Legal
Compliance

Establishing Ethical Standards
We believe that common standards must be applied throughout
our divisions in order to create the globally excellent company
that we envision. In 1998 we established a Code of Ethics,
which concretely describes our basic views. At the same time,

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
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 Open Competition
8. Fair Business with Suppliers
9. Handling of Confidential Information
10. Strict Export/Import Controls
11. Reasonable Exchanges of Gifts andEntertainment within the Bounds for Common
Sense
II-3 Relationship between the Company andIndividuals
12. Prohibition of Conduct Causing Conflicts ofInterests
13. Prohibition of the Improper Use of CompanyAssets
14. Prohibition of Conduct of Harassment
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

We established our Compliance Regulations in 2004. TheRegulations, which provide for basic matters concerning compliance, are designed to help those engaged in the business
operations of the Tokyo Electron Group understand fully therelevant laws, regulations, and international rules as well as
in-house rules and act accordingly at all times.
In 2006, we provided all employees in Japan with webbased training on export compliance. Due to the tense international situations, controls on exports from Japan have beenstrengthened and it is becoming very important for all thedepartments, including both the sales and service departments
who directly contact overseas customers, and those indirectly
involved in export to understand the basic export rules.
We provide compliance-related information on the intranet
and give employees web-based education to ensure that they all
understand our compliance policies and are more aware of theirimportance, thereby further strengthening our compliancesystem.

Protection of Personal Information
Leakage of personal information has become a social concern inrecent years and companies are required to manage the personal
information they hold in an appropriate manner.
In Japan following the enactment of the Act on theProtection of Personal Information in April 2005, the Tokyo
Electron Group formulated its basic policies and rules on theprotection of personal information. We educate employees on
the implementation of the policies and rules, endeavoring to
make them more aware of these policies and rules. Furthermorein Japan, we investigated personal information stored on
approximately 13,000 PCs leased to employees and created aledger of personal information to be managed by each Groupcompany and department. Also, we installed servers to be used
exclusively for storing personal information and prohibited
employees from storing important personal information on theirPCs. Through these measures, we ensure that personal information is managed in an appropriate way.

Implementation of the Code of Ethics** The “Implementation” section provides the specific matters and procedures.

TOKYO ELECTRON Environmental and Social Report 2007

15Compliance

The Code of Ethics of Tokyo Electron Group
Introduction

Measures to Strengthen the Compliance
SystemMANAGEMENT REPORT

Trust is and will always be the lifeline of the Tokyo ElectronGroup. The fundamental requirements for maintaining trust are
rigorous conformity to our ethical standards and compliancewith the law, by our employees as individuals, and by each of
our organizations. We give first priority to compliance with highethical standards and laws in conducting our business operations.

we established the Ethics Committee as an organization foractual operations.
In June 2007, in response to the results of a survey conducted on our Code of Ethics and compliance measures in theGroup in 2005, we revised our Code of Ethics, including adding
items and modifying expressions, to make them easier tounderstand and more consistent with the current business environment and sense of ethics.