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

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

Whistleblowing System

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.