Compliance System

The SCREEN Group has established a CSR Charter / Code of Conduct that all Group employees should follow and provides principles of conduct based on our corporate philosophy. Based on the CSR Charter / Code of Conduct, the SCREEN Group will comply with all applicable laws and regulations, as well as standards of ethics in all relevant countries, and will conduct business activities in a fair and sensible manner. Led by our Legal, IP & Compliance Department, we promote abidance with international rules and each country’s laws and regulations, and we offer a range of compliance education in efforts to raise awareness and make it fully understood across the Group companies in Japan and abroad. The CSR Committee, which meets twice a year, confirms and shares information on the state of compliance at each company.

Compliance Education

Through both in-person class and e-learning, new hires, mid-career hires, and employees at SCREEN companies worldwide receive education including compliance basics, job-level-specific classes, specialist classes, and classes on CSR Charter / Code of Conduct. In FY2023, 45 compliance classes were conducted in total. These included periodic classes on harassment prevention and compliance with laws related to unfair competition, anti-corruption, anti-monopoly (including the Subcontract Act), personal information protection, worker dispatching, and insider trading, as well as education on technology contracts and development contracts for engineers involved in R&D and new businesses at our business operating companies. In addition, we provided learning materials on personal information protection, non-disclosure agreement, and trade secrets management to subsidiaries in Europe, North America, and Asia. We also supplied Group companies in Japan with educational materials for 16 courses that were available through e-learning, allowing each company to build its own educational system.

Fiscal Year Ended March, 31 2023: Face-to-Face Education

Course Name Participant No. of Sessions Course Content
Training for New Employees New employees at SCREEN Group in Japan 2 Legal and trade secret basics, compliance
Mid-career Hires Education Mid-career hires at SCREEN Group in Japan 11 Compliance, trade secrets
Overseas Assignment Education Employees scheduled for overseas assignment at SCREEN Group in Japan  5 Compliance
Newly Appointed Qualified Personnel Education New General staffs(Leaders), Managers, Senior manegers, General staffs(Leaders) at SCREEN Group in Japan  4
(1 each)
Harassment Contact Education New harassment contact person at SCREEN Group in Japan  2 Role of the contact person, harassment
Harassment (Abuse of Authority) Prevention Education Directors, managers, general staff, temporary employees, contracting company managers, etc. of five SCREEN Group in Japan  13 Harassment prevention education (power harassment, sexual harassment, harassment related to childcare/caregiving), ethics, etc.
Worker Dispatching and Subcontracting Leadership positions or above (including management positions) at one  SCREEN Group in Japan 1 Worker dispatching and subcontracting
Basics of Contracts and Trade Secrets Young employees of one SCREEN Group in Japan 1 Basics of Contracts and Trade Secrets
Business Basics Course General and managerial positions at SCREEN Group in Japan (voluntary) 2 Contract Basics and Practice (Non-Disclosure Agreement : NDA)
Engineer education lectures New technical employees at SCREEN Group in Japan 1 Compliance with laws for on-site subcontracting and worker dispatching,Trade secrets
Knowledge of Purchase Agreement Sales representative of one overseas subsidiary 1 Purchase Agreement
Knowledge of NDA Sales representative of one overseas subsidiary 1 NDA
Study meetings on institutional management Person in charge of institutional management of  SCREEN Group in Japan 1 Study meetings on institutional management (General Meeting of Shareholders, Board of Directors)

 Fiscal Year Ended March, 31 2023: SCREEN Business School Classes

Course Name Course Aim
Antimonopoly Act With regard to the Antimonopoly Act, develop a proper understanding of specific regulatory content aimed at promoting free and fair trade, as well as develop an understanding of the risks arising from violation of this Act.
Product Liability Act (PL Act) Learn the basics of the PL Act and develop a proper understanding of key issues. Be able to identify product liability-related risks and to take action to reduce such risks of liability for damages through business activities.
Contract Basics Develop an understanding of how contracts/agreements are essential to business operations and of the significance of entering into them. Also, learn the basic points to keep in mind when, and SCREEN Group process for, concluding agreements and put them to use in your own work duties.
Insider Trading Regulations Develop a basic, proper understanding of insider trading regulations. Reaffirm the structures and rules put in place by the SCREEN Group, and facilitate a greater compliance-focused mindset among each and every employee.
Copyright Act Basics Learn the basics of copyright (e.g., an overview of the Copyright Act, points to remember when performing your work duties, etc.). Furthermore, be able to identify hidden copyright-related risks during day-to-day software development, and develop an understanding of the importance of contracts as a means of mitigating these risks.
NDA Basics, Application, and Related Agreements Learn the basics of NDAs (e.g., key contractual terms, points to remember when applying, relationship to other types of agreements, etc.).
Basic Transaction Agreements Learn the Basics transaction agreement  (e.g., contract  structure , typical issues, points to remember when applying, etc.).
Act on the Protection of Personal Information Learn the basics of the Act on the Protection of Personal Information (e.g., what constitutes personal information, context-specific rules, etc.).
Points to Remember when Concluding Agreements with Other Companies Learn how to carry out business in line with agreements and how to make use of legal affairs tools available in-house.
Equipment Sales Agreements with Chinese Customers Develop an understanding of key contractual terms, negotiation-related approaches, and other points to remember when dealing with equipment sales agreements with Chinese customers, and be able to mitigate the risks associated with such agreements.
Software Business-Related Points to Remember Learn essential information pertaining to the implementation of software business, centering on Copyright Act revisions and open-source software-related basics, and be able to mitigate the risks associated with software business.
The Act against Delay in Payment of Subcontract Proceeds Learn the basics of the Act against Delay in Payment of Subcontract Proceeds and understand the obligations and prohibitions imposed on main subcontracting enterprise to ensure that we do not violate the act in their daily operations.
Trade Secrets Due to the potential that issues of trade secrets and mishaps cause severe damage to a company, we acquire correct knowledge regarding trade secrets and properly guard trade secrets in daily work in order to mitigate associated risks.
Worker Dispatching and Outsourced Contracting (Onsite Contracting) Acquire knowledge of the differences between worker dispatching and outsourced contracting (onsite contracting) and point of attention.
Use of Standard Contracts and the Legal Case Request System To understand how to use standard contracts and the legal case request system in order to facilitate operations for legal, intellectual property, and compliance offices within the Holdings and the contracting department.
Basic Knowledge of Contract Clauses and Bankruptcy Procedures We acquire basic knowledge of contract clauses and bankruptcy procedures, which are important for protecting and collecting claims from domestic business partners.

Whistleblowing System

We have established the Internal Reporting Hotline, a whistleblowing system independent of the company that helps to prevent improprieties and misconduct through the early detection of harassment and suspected violations of domestic and overseas laws and regulations, international rules, corporate ethics, and internal regulations. We have raised awareness of the system through compliance education and the display of posters. We also comprehensively work to prevent corruption, such as bribery, excessive entertainment and collusion. Our global whistleblowing system accepts inquiries from all Group officers, employees and supplier companies in Japan and overseas.
In line with the amended Whistleblower Protection Act, there is also Internal Reporting Hotline System Operating Regulations in place regarding anonymity and privacy protection, as well as for ensuring that no one will be given disadvantageous treatment for having used the whistleblowing system. Periodic in-house audits are conducted to see how well we are complying with laws, regulations and corporate ethics.
Inquiries received through the Internal Reporting Hotline are mainly handled by Legal, IP & Compliance Department, and are regularly reported to the representative director and auditor. In the fiscal year ended March 31, 2023, there were 22 inquiries made through the whistleblowing system, and we responded to all of them.

● Internal Whistleblowing Response Overview
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Tax Transparency

Our CSR Charter / Code of Conduct clearly stipulates that the SCREEN Group will implement highly transparent management of our businesses through sound and effective corporate governance and that the Group will comply with all applicable laws and regulations, as well as the ethical standards of all relevant countries, and will conduct our business activities in a fair and sensible manner. In accordance with these directives, each Group company is responsible for full compliance with all local tax laws, filing requirements and tax obligations, and the CFO is responsible for tax matters. We have established a transfer pricing policy in light of various rules, such as transfer pricing taxation in relevant countries and the OECD Transfer Pricing Guidelines, and we follow it when setting and verifying transfer prices between Group companies. We will not resort to tax planning or use tax havens to evade taxation.

Security Export Control

The SCREEN Group places a high priority on carrying out security export control. The aim is to help preserve international peace and safety by preventing weapons or goods and technologies that could be converted for military use from falling into the hands of governments or terrorists who could threaten world safety. Our Security Export Control Department gathers the latest information on the Foreign Exchange and Foreign Trade Act and other related export rules and disseminates this information throughout the Group. It also confirms that goods and technologies we export correspond to regulations, and it formulates and checks conformity with in-house rules supporting export control processes that are aimed at confirming end users’ identity and their intended use of goods and technologies.
The Group’s business operating companies have been approved as “authorized exporters” under the Authorized Economic Operator (AEO) program. To ensure ongoing compliance with this program, we disseminate information on relevant laws and regulations throughout the Group and conduct periodic legal audits.

Compliance with Competition Laws and Anti-Corruption

Under its CSR Charter, the SCREEN Group formulated the Guidelines on Preventing Bid-rigging and Cartels, and conducts education for all officers and employees on improper activities. The goal is to prevent collusion, monopolies, unfair advantages to one’s own suppliers, and other actions that violate anti-monopoly and anti-trsut laws, as well as prevent bribes and other such improper acts. In the fiscal year ended March 31, 2023, there were no instances in the SCREEN Group of anticompetitive or antitrust practices or illegal monopolistic activities.

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, 2023, there were no significant legal violations.