Compliance System

"The SCREEN Group has established a CSR Charter / Code of Conduct that all group executives and employees should follow and includes 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.
To this end, we have appointed a compliance officer in efforts to raise awareness of compliance and make it fully understood across the entire SCREEN Group. Our Legal & Compliance Department takes the lead in promoting abidance with international rules and each country’s laws and regulations and offering compliance education.
The CSR Committee, chaired by the HD Representative Director, President, Member of the Board is held quarterly, with members comprising Chief Sustainability Promotion Officer, Chief Compliance Officer, CSR officers and CSR department General Managers of the business operating and functional support companies. At meetings, members confirm and share information on the state of compliance efforts at each company."

Compliance Education

"Through both classroom work and e-learning, newly graduated employees and mid-career hires receive education including compliance basics, job-level-specific classes,
specialist classes, and classes on SCREEN Group’s CSR Charter / Code of Conduct. Education also includes periodic classes on harassment prevention and on compliance with laws related to unfair competition, subcontracting, personal information protection, worker dispatching and insider trading."

Fiscal Year Ended March, 31 2019: Face-to-Face Education      

Course Name     

Target Audience No. of Sessions Course Content
Legal Affairs and Intellectual Property for Engineers Semiconductor production equipment engineers 10 Legal affairs training for engineers
New Employee Orientation and Basics of Legal Affairs New employees 1 Basic legal affairs-related information
New Employee Orientation and Trade Secrets New employees 2 Trade-secrets related information
Training for Mid-Career Recruits Compliance and Trade Secrets-related  Mid-career recruits 12 Compliance and trade secrets-related information
Scheduled for Overseas Assignment
Compliance Training  for Employees 
Employees scheduled for overseas assignment 13 Compliance
Training for Newly Qualified Appointments Newly appointed supervisors, assistant managers, managers, senior managers 6 Compliance
Technical Training New engineers at business operating companies 1 Trade secrets, on-site contracting, worker dispatch
Subsidiary Employee Training Display production equipment subsidiary employees 1 On-site contracting and worker dispatch-related compliance
Harassment Consultation Office Representative Training Representatives at group companies, offices, and production sites 2 Roles, responsibilities, and points to remember for harassment consultation 
Compliance Training for Overseas Subsidiaries Employees at Chinese subsidiaries 1 Compliance-related information pertaining to Chinese commercial anti-bribery regulations, key contractual points, trade secrets, etc.
Fiscal Year Ended March, 31 2019: SCREEN BUSINESS SCHOOL e-Learning
       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.

Soft ware 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.

Whistleblowing System

We have established an Internal Reporting Hotline, a whistleblowing system that helps to prevent improprieties through the early detection of harassment and suspected violations of corporate ethics and corporate regulations. Our global whistleblowing system has hotlines in all SCREEN worldwide regions to accept inquiries from all Group employees, officers, and employees of supplier companies. There are also rules in place regarding anonymity and privacy protection, as well as for ensuring that no one will be given unfair treatment for having used the whistleblowing system. The Internal Reporting Hotline is operated by our Legal & Compliance Department. We have also established external hotlines operated by law firms and third-party agents. 
Periodic in-house audits are conducted on our compliance with laws and corporate ethics and on the hotlines.

Security Export Control

The Security Export Control Department handles one of the key issues of the Group: ensuring total compliance with legislation on exporting products and components. The department obtains updates on the Foreign Exchange and Foreign Trade Act and other export control-related legislation, making this information available to executives and employees involved in export-related businesses. Furthermore, the department supports compliance with export control processes as defined by internal regulations, such as product classification and transaction screening. After the transition to the holding company structure, the Group’s four business operating companies were approved by the Director of Osaka Customs as “authorized exporters” under the Authorized Economic Operator (AEO) program. As the legal auditing department within the Group’s AEO system, the Security Export Control Department supports the four business operating companies’ activities aimed at maintaining their AEO status.

Preventing Anti-Competitive Behavior and Corruption

To prevent collusion, the formation of private monopolies and other behaviors that run counter to anti-monopoly and other competition legislation as well as both the giving and acceptance of hospitality or gifts for trade benefits, in addition to maintaining the CSR Charter, which espouses fair transactions, the Group formulates guidelines and provides training for the prevention of anti-competitive behaviors. We thereby ensure awareness among executives and employees. During the fiscal year ended March 31, 2019, no violations constituting anti-competitive behavior or anti-trust or monopolistic practices were observed.

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.

Providing Appropriate Product Information

Each departments involved in company, IR, Legal, and Intellectual Property, 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, 2019, there were no significant legal violations by any Group company in areas related to the provision of information about or labeling of products and services or marketing. Going forward, we intend to conduct thorough checks of each Group company to continue to prevent infractions.