Compliance system

The SCREEN Group has established the CSR Charter and Code of Conduct, setting forth principles of conduct for all officers and employees across the Group to follow based on the corporate philosophy, as well as 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 conducts business activities in a fair and conscientious manner.
Led by our Legal & Intellectual Property Department and Compliance Department, we promote abidance with international rules and each country’s laws and regulations. We offer compliance education for officers and employees across the Group to develop awareness and understanding of compliance. The CSR Committee, which meets twice a year, confirms and shares information on the state of compliance at each company.

Compliance Policy

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 FY2024, 54 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 Japan, December was designated as “Harassment Elimination Month” and all employees were provided with harassment prevention education.In addition, personnel from overseas subsidiaries (U.S.A., Taiwan, South Korea, the Netherlands, Germany, and Singapore) visited each company to provide education on the use of the internal reporting system and corporate ethics helpline of each company.

● FY2024/03  Educational course achievements

● FY2024/03 SCREEN business school classes

Whistleblowing system

Tax transparency

The CSR Charter clearly stipulates that the SCREEN Group will implement highly transparent business management 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 business activities in a fair and transparent manner. In accordance with these directives, each group company is responsible for full compliance with all local tax laws, filing requirements, and tax obligations, with the SCREEN Holdings CFO being ultimately 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. 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 places a high priority on implementing security export control. The aim is to help preserve international peace and security 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 security. Our Security Export Control Department gathers the latest information on the Foreign Exchange and Foreign Trade Act, the U.S. Export Administration Regulations (EAR), and other related export laws and regulations, and disseminates this information throughout the Group. The department also ensures conformity with export control processes that are internally established to determine whether goods and technologies to be exported are subject to regulations and to confirm end-users’ identity and their intended use of the goods and technologies.
The Group’s business operating companies are authorized exporters under Japan’s Authorized Economic Operator (AEO) program. To maintain compliance with this program, we share 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, 2024, 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, 2024, there were no significant legal violations.