Compliance

Approach to Compliance

To practice our Corporate Philosophy, it is vital that each employee performs their daily duties with strong interest in and a deep understanding of compliance. We established “Tokyo Electron Group Code of Ethics” as a code of conduct to ensure that our employees are aware of the risks around them and conduct themselves appropriately. We have built a global system that can directly raise questions and concerns about compliance and business ethics to quickly address potential problems.

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Compliance System

In order to effectively promote a compliance program that is expected of a global company, we have appointed a Chief Compliance Officer (CCO) and established a dedicated Compliance Department at our headquarters. We have also appointed Regional Compliance Heads at key overseas sites, and have established a framework for direct reporting to the CCO and Compliance Department.

Compliance Initiatives

Business Ethics and Compliance

We have formulated “Tokyo Electron Group Code of Ethics” as a code of conduct for all executives and employees and established the Business Ethics Committee, and are working to promote business ethics and compliance more effectively and ensure that these permeate the entire Group.
We have set up the Disciplinary Committee as a subordinate organization of the Business Ethics Committee to ensure the implementation of reasonable and appropriate disciplinary action and proper procedures. In addition, through regular meetings with each of the Group companies, we discuss and implement measures to promote compliance.

We have also set up an award system for employees who have engaged in particularly excellent activities relating to business ethics and compliance, to raise awareness within the Group and fostering a compliance-oriented culture.

Initiatives for Anti-Bribery and Corruption and for Competition Laws

We have globally established the Basic Policy on the Prevention of Bribery and Corruption and the Guidelines for Gift, Hospitality and Entertainment in the area of anti-bribery and corruption, and the Basic Policy on Competition Law Compliance and Guidelines in the area of competition laws. In order to prevent violations, we regularly provide training to promote understanding of these Policies and Guidelines and ensure their permeation throughout the entire Group.

Internal Reporting System

We have established an internal reporting system that ensures complete confidentiality, anonymity and the prohibition of retribution and unfavorable treatment, so that employees can safely and in peace of mind provide information and seek redress outside the chain of command about behavior that is, or may be, in violation of laws, regulations or business ethics. In addition, the introduction of an internal leniency system, whereby any disciplinary action may be reduced or exempted in the event that the employee involved in a compliance violation has made a report or sought advice on their own volition, is encouraging employees to proactively provide information and is leading to problems being discovered and resolved at earlier stages.

As part of this internal reporting system, we have established and are operating the Tokyo Electron Group Ethics & Compliance Hotline—a global common internal point of contact that uses a third-party system and is also accessible to our suppliers and retirees—as well as an external point of contact that allows direct consultation with an outside law firm.
The internal point of contact can be accessed via phone or a dedicated website 24 hours a day, 365 days a year, and accommodates all languages used by employees.

Reports and consultations received via these points of contact are handled with sincerity and investigations are undertaken in accordance with internal regulations. If a compliance violation is found, disciplinary actions in accordance with the Rules of Employment, corrective measures such as improvements to the workplace environment and preventive measures are implemented as necessary.

Global Response to Internal Reports

In fiscal year 2023, a total of 130 reports and consultations were received via the internal reporting system, of which 19 were recognized as compliance violations. The reports and consultations were primarily related to harassment and the workplace environment. Based on this result, we have conducted regular education programs for our employees with the goal of preventing harassment and have provided thorough follow-up with those concerned or involved. In fiscal year 2023, the COO carried out compliance training for managers, which included coverage of prevention of harassment and the importance of establishing an appropriate workplace environment.

There were no reports or cases of violations of laws/regulations in our operations that could have had a serious impact on our business or on local communities.