Our basic policy of compliance management is that we keep the company, executives and employees legally safe and secure by preventing their misconduct and negligence. In this respect, we keep reminding our executives and employees of the importance of compliance and put in place and operate a proper mechanism of organizational and procedural preventive measures to ensure compliance in our management and execution of duties.
We have a senior executive assigned to the oversight of the company’s compliance, and the administration of compliance-related affairs is mainly tasked to Corporate Planning and Control Department. When an issue affecting the company’s overall compliance arises, Corporate Planning and Control Department will check relevant laws and regulations, put in place necessary internal rules, and keep all related parties informed. If an issue affecting only one or a few specific departments such as a technical issue arises, it will be dealt with by the relevant departments. We make a coordinated effort within our organization.
We convene a compliance meeting chaired by the executive in charge of compliance as necessary to discuss compliance-related questions and issues and decide on preventive and/or corrective measures and disciplinary actions.
We provide in-person training for new permanent and temporary employees about compliance basics and important laws and regulations related to our business. We also provide follow-on training regularly using e-learning. In our training, we make sure that employees understand our corporate philosophy and code of conduct and emphasize the prevention of briberies and corruption, compliance with anti-trust laws and export control regulations, and information security. We also discuss our whistleblower protection system. Through these efforts, we are increasing the awareness of employees about the importance of compliance.
Compliance with laws and regulations, and fair trade
In “Lasertec Code of Conduct”, we set forth our commitment to complying with laws and regulations, articles of incorporation, and social norms, and conducting fair trade and proper business activities.
Prevention of briberies and corruption
- We do not engage in or accept any entertainment or gift giving in violation of relevant laws and regulations in each country or against business practices and social norms.
- We do not make any political contributions or donations in violation of relevant laws and regulations in each country.
Compliance with anti-trust laws
- We do not engage in any activities that are in violation of anti-trust laws in the countries where we operate.
Prevention of tax avoidance, and tax transparency
- We follow tax laws of the countries where we operate, act in compliance with the OECD’s transfer pricing guidelines and base erosion and profit sharing (BEPS) action plans and engage in proper tax administration. We will follow the spirit of the law.
- We do not engage in any tax planning that is intended for improper tax evasion and that has no connection with our business operation.
- We make proper disclosures on taxes in compliance with relevant laws and regulations.
- We engage in export controls by putting in place “Export Control Regulation” and “Supplement to Export Control Regulation” to maintain international peace and security and to prevent rogue nations and terrorists from gaining access to products and technologies. We comply with export control laws and regulations including foreign exchange and trade restrictions by checking the origin of goods being exported, the purpose of trade, and its flow, and judging compliance with regulations. We have an officer assigned to the oversight of national security and export control regulation compliance to ensure that we take necessary measures to maintain and enhance our export control system and comply with export regulations.
Basic principles for exclusion of anti-social forces
We have a compliance helpline in place to receive reports and inquiries from executives and employees at HQ and subsidiaries concerning human rights violation and other compliance-related issues. A neutral outside attorney’s office serves as a point of contact, to which a whistleblower can report their case, either with name or anonymously, by mail, by electronic mail, by FAX, by phone, or in person. Whistleblowers are protected against any type of unfavorable treatment under our internal rules. We investigate the reported case in accordance with our internal rules, and if we find a violation as a result, we will take necessary corrective and preventive measures.
Ethics and compliance oversight
We have set a basic principle on the institution of an internal control system to put in place a system that ensures the proper operation of our business. The members of the Audit and Supervisory Board are responsible for the oversight and examination of the internal control system pursuant to its audit policy and schedule. They conduct audits in coordination with the Board of Directors and Auditing Office, which is responsible for conducting internal audits.
Auditing Office conducts internal audits pursuant to the company’s internal audit rules. Auditing Office examines whether the company’s operation follows its rules on compliance, asset management, subsidiary management and others regularly, at least once a year. The results of audits are reported to the president and shared with the members of the Audit and Supervisory Board. Auditing Office also audits the company’s subsidiaries in the United States, Korea, Taiwan, China and Singapore every year. For compliance-related internal audits, Auditing Office reviews the company’s practices in the area of labor management, industrial waste disposal, export controls and others regularly, at least once a year.