Compliance system

The SCREEN Group has established the CSR Charter and Code of Conduct, which sets forth principles of conduct for all group officers and employees based on the corporate philosophy, and the Compliance Policy, which lays out principles of conduct related to compliance. Based on these, the SCREEN Group complies with all applicable laws and regulations, as well as ethical standards, of all relevant countries and regions and conducts business activities in a fair and transparent manner. Under the initiative of the officers in charge of compliance and of legal and intellectual property, we work to enhance and spread compliance awareness across the Group.The Legal & Intellectual Property Department and the Compliance Department play leading roles in promoting adherence to national and regional laws and regulations and international rules, as well as in providing compliance training. The Sustainability Committee, which meets three times a year, confirms and shares information on the state of compliance at each group company.

Compliance Policy

Compliance training

We offer group officers and employees compliance training courses, including compliance basics classes, job-levelspecific classes, specialist classes, and classes dedicated to the CSR Charter and Code of Conduct, as well as training focused on specific compliance topics. A total of 68 classes were held in the fiscal year ended March 31, 2025.Following the discovery of improper revenue recognition practices in the same fiscal year, we have taken measures to disseminate and strengthen compliance awareness. Employees of the business operating company directly involved and related group companies received training based on the issue that occurred. Additionally, employees across the Group were reminded of the need to adhere to laws and regulations, internal regulations, and other rules, and encouraged to use the whistleblowing system whenever necessary. We will continue group-wide efforts to enhance compliance training informed by this matter.

● FY2025/03  Training course achievements

● FY2025/03 SCREEN business school classes

Whistleblowing system

Tax transparency

The CSR Charter and Code of Conduct calls for highly transparent business management and compliance with laws, regulations, and standards of ethics. In the area of tax accounting, we abide by all local tax laws, filing requirements, and tax obligations. We have established a transfer pricing policy in accordance with various rules, such as transfer pricing taxation in relevant countries and the OECD Transfer Pricing Guidelines. We follow this policy when setting and verifying transfer prices between group companies. We do not use tax planning or tax havens to evade taxation.

Security export control

The SCREEN Group is committed to security export control to prevent weapons and dual-use goods and technologies from falling into the hands of high-risk nations or terrorists. We gather the latest information on export-related laws and regulations in relevant countries and disseminate it throughout the Group. Internal export control rules are applied to determine whether goods and technologies to be exported are subject to regulations and to confirm end-users’ identities and intended use of the goods and technologies. The Group’s business operating companies, as authorized exporters under Japan’s Authorized Economic Operator (AEO) program, conduct cargo management with periodic regulatory audits.

Compliance with competition laws and anti-corruption

We prevent violations of anti-monopoly and anti-trust laws, as well as collusion, such as bribery and unauthorized use of company assets, by prohibiting such misconduct in the CSR Charter and Code of Conduct and taking other necessary measures under the risk management system, including internal training to raise awareness among officers and employees. In the fiscal year ended March 31, 2025, there were no instances of anti-competitive practices, bribery, or other illegal activities in the SCREEN Group.

Managing trade secrets

The SCREEN Group has established Groupwide methods and internal rules regarding the management of trade secrets as well as usage standards. These measures, which are applied across all processes, facilitate the appropriate management and use of trade secrets and prevent leaks. Trade secrets received from outside the Group are also managed and used in accordance with these internal rules and standards. To ensure thorough, effective trade secret management, we work to educate Group employees through classes, e-learning and other training.

Exclusion of anti-social forces

The SCREEN Group will ban any relationships with anti-social forces, including organized crime groups, which pose a threat to public order and safety of society. We will stand firm against, and reject, unreasonable demands and requests of anti-social forces. Furthermore, we will not engage in any transactions or relationships of any kind with anti-social forces. We will also demand that our customers and business partners also eliminate any relationships with anti-social forces.

Compliance on products and services

SCREEN conducts a compliance evaluation once every six months for each business regarding its response to laws and regulations relevant to its products and services. The Company confirms its compliance related to labeling, including for products and CE markings, and reports on said compliance are issued to the Group EHS Committee. In addition, managing organizations and related organizations within the Group involved in legal affairs, intellectual property, CSR promotion, and public relations collaborate to verify product and service information prior to its external release. In this way, we work to ensure fair and accurate information disclosure. In the fiscal year ended March 31, 2025, there were no significant legal violations.