Ethics And Corporate Compliance

ETHICS AND CORPORATE COMPLIANCE

Our Commitment to Integrity

Olympus Corporation of the Americas (OCA) and all of our businesses are subject to the laws, regulations and ethical standards in each industry we serve, some of which are unique to the health care and life sciences areas of our business. 

We are committed to complying with the laws, regulations and highest ethical standards, and adhering to our own Codes of Conduct which guide our business processes, decisions and behavior.

CODE OF ETHICS

Conducting Business Within a Culture of Compliance

For Olympus Group companies worldwide, compliance with the law does not only mean following the letter of the law. It also means operating within a culture of compliance, and conducting our business in the spirit of corporate social responsibility. Earning and keeping the respect of our employees, business partners and our communities is of paramount importance.

To assist in maintaining the highest ethical standards, and to ensure that our core ethical values are embraced and understood at all levels of the Olympus organization and throughout our global operations, Olympus Corporation of the Americas has established a Code of Ethics (“Code”). Upon employment, each OCA employee is required to certify that he or she has read the Code, understands it and agrees to comply with it. Furthermore, on an annual basis, all OCA employees are required to successfully complete on-line Ethics training and recertify their understanding and agreement to comply with the Code.

The core principles of our Code focus on:

• Fostering a culture of compliance
• Accomplishing innovation with integrity
• Respecting one another
• Engaging in corporate social responsibility

Click the following link to view or download a copy of the Olympus Corporation of the Americas’ Code of Ethics.

COMPLIANCE CODE OF CONDUCT

Governing our Interactions with the Health Care and Life Sciences Industries

The Olympus Health Care Compliance Code of Conduct (“Compliance Code”) governs our interactions with our customers and health care professionals (“HCPs”). It also helps define our commitment as a corporation and as individuals to abide by the laws and industry standards that apply to our day-to-day interactions with our customers and HCPs.

Our Compliance Code is based on three fundamental principles:

• Medical decisions should be focused on the best interests of patients.
• Products must be promoted in a manner consistent with the Food and Drug Administration’s (FDA) approved uses (indications) as listed in the product labeling.
• Training HCPs and others how to utilize our products and services in a safe and effective manner is important to enhance the well-being of the patients they serve.

The Compliance Code for Olympus Corporation of the Americas is summarized in a guide entitled Keeping our Focus: Compliance Summary for Customers and Health Care Professionals (Focus Guide). View or download a copy of Olympus’ Focus Guide.

Olympus's commitment to a culture of compliance is fully supported by senior management and Olympus expects all Olympus Representatives to reflect that commitment through their actions and decision-making. Olympus fosters this culture of compliance by developing clear and consistent policies, conducting regular compliance trainings, encouraging open communication, responding timely to concerns and identified risks and administering corrective action when necessary. In the United States, Olympus plays an active role in the Advanced Medical Technology Association (AdvaMed). The Olympus Compliance Program has been developed based upon published guidance from the U.S. Federal Government, and its foundational elements are also consistent with the AdvaMed Code of Ethics on Interactions with Health Care Professionals (AdvaMed Code). Olympus has certified to the AdvaMed Code. Olympus has strict anti-bribery policies in place and is committed to complying with anti-corruption laws in every place in which we do business.

INTEGRITY HOTLINE

Olympus is committed to ethical behavior by all employees in compliance with the laws and regulations that govern our industry.  Olympus strives for ethical and compliant behavior.  If there is ever an instance where you believe we have failed to live up to our standards, please let us know so we can take corrective action and address the issue.  Every Olympus Representative (including Company personnel and agents) has a duty to report any actual or suspected violations of any laws, regulations, government health care program requirements, internal policies and procedures, or inappropriate actions. To ensure that allegations of improper or illegal conduct, activities or practices are heard and addressed, OCA maintains an anonymous, confidential reporting system (the "Integrity Hotline").

The Integrity Hotline is maintained by a third-party, Ethics Point. Employees, customers, business partners and other third parties may make reports to the Integrity Hotline 24 hours a day, 7 days a week, every day of the year, by telephone or by using the internet. Ethics Point provides issue reporters with multi-lingual Hotline support and translation services.

When using the Integrity Hotline, issue reporters may elect to remain anonymous. In all cases, reports are treated with the utmost discretion. To maintain anonymity, issue reporters are assigned a unique code, called a “report key” within the Ethics Point system after reports are submitted, which is intended for the reporter’s eyes only.

The Integrity Hotline is accessed in the following manner:

Telephone:
U.S., Canada & Puerto Rico: 1-844-277-1698
Canada-French: 1-855-350-9393
Costa Rica: 0800-011-1248
Mexico: 001-855-232-1301
Brazil: 0800-892-0649
Encrypted website: http://olympusamerica.ethicspoint.com

In addition to the Integrity Hotline, OCA welcomes any reporting of concerns about unethical or unlawful conduct directly to management, Human Resources, the OCA Ethics Compliance Officer, the OCA Legal Department and/or the OCA Compliance Department. The OCA Compliance Department can be reached directly via phone at 484-896-4472 or via email at compliance@olympus.com. Company policy prohibits retaliation against any individual for reporting concerns to the Integrity Hotline or directly to management in good faith.