Compliance

• Basic Approach and Policy
• Promotion Structure
• Initiatives
• Systems and Mechanisms

Basic Approach and Policy

Because What We Do Matters
Olympus Global Code of Conduct

What we do at Olympus Group matters to the people we serve, and how we do our work matters to our stakeholders. To help our management team and employees put Our Purpose and Our Core Values into practice, we developed a single, simplified resource, the Olympus Global Code of Conduct, which replaces the Olympus Group Corporate Conduct Charter and Code of Ethics. The updated Global Code of Conduct went into effect in 2019, and is available online in 18 languages.

Olympus Global Code of Conduct

Acting with Integrity Matters

The Olympus Global Code of Conduct builds on our 100-year tradition of innovation, positive contributions to society, and our unwavering commitment to integrity. It explains the standards of conduct expected of our management team and employees, and guides them as they conduct business with integrity. The Olympus Global Code of Conduct reflects a comprehensive declaration of Olympus' stance on Environmental, Social, and Governance sustainability matters (ESG), and we formulate specific ESG-related policies based on this Code.
Our activities are based on Our Purpose of "making people's lives healthier, safer and more fulfilling." Following Our Purpose, we are committed to conducting our affairs with integrity, and accordingly, will comply with applicable laws and regulations. The Olympus Global Code of Conduct is the foundation for our policies and is required to be read, understood and followed by our management team and employees. We are committed to acting in accordance with the Global Code of Conduct in our global corporate activities.

Promotion Structure

Compliance Management System

Our global Compliance function works to raise awareness of the Olympus Global Code of Conduct and related-compliance policies by providing the management teams and employees with the resources and training they need to do business with integrity, treat customers, suppliers, third-party business partners fairly, and report concerns when they arise.
Olympus has appointed a Global Chief Compliance Officer (CCO), who leads global collaboration across the Company to continuously assess whether business activities are consistent with applicable legal requirements and Company policies and procedures. Our CCO reports regularly to the Chief Executive Officer and the Audit Committee of our Board of Directors and more frequently as needed. We have also established a Global Compliance Leadership Team (GCLT), which is composed of the CCO as head of the committee, Regional Compliance Officers (RCOs), and the head of Global Planning and Operations, to implement compliance-related policies and measures globally, understand regional situations and challenges, and carry out necessary corrective measures. The GCLT meets on a quarterly basis and more frequently as needed.
Policies and measures confirmed and directed by the GCLT are applied to each region by RCOs. In addition, compliance circumstances and issues throughout the Olympus Group identified by the GCLT and RCOs are reported by the CCO on a regular basis to the Audit Committee and are discussed at Board of Directors' meetings as needed.

Compliance Management System (As of April, 2022)

Initiatives

Compliance with Laws and Regulations

In FY2022, there were no violations that caused penalties or other punitive measures concerning these key laws/regulations (as stated below) and other socially important legislation.

Strengthening Compliance with Key Laws and Regulations

Jurisdiction	Name of Law/Regulation, etc.
Laws, regulations and guidelines in Japan	Laws and regulations relating to anti-bribery such as Unfair Competition Prevention Act, etc. National Public Service Ethics Act/rules of ethics Agreements relating to fair competition Transparency guidelines for the medical device industry in relation to medical institutions, etc. (formulated by the Japan Federation of Medical Devices Associations) Act on Prohibition of Private Monopolization and Maintenance of Fair Trade (Antimonopoly Act) Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors (Subcontract Act) Laws and regulations relating to labor such as Labor Standards Act/Industrial Safety and Health Act, etc. Laws and regulations relating to insider trading Personal information protection laws/My Number ID Act Laws and guidelines relating to measures against antisocial forces
Laws, regulations and guidelines in other countries	Foreign Corrupt Practices Act (FCPA, United States) U.K. Bribery Act 2010 (United Kingdom) Anti-Kickback Statute (United States) OECD agreements concerning the prevention of the bribery of foreign public officials in international commercial transactions United Nations agreements concerning the prevention of corruption Other laws and regulations relating to the prevention of unfair competition Physician Payment Sunshine Provision (United States) Laws and regulations relating to anti-monopoly Laws and regulations relating to measures against antisocial forces

Systems and Mechanisms

Reporting System

The Olympus Group is committed to comply with the laws and industrial guidelines as well as acting based on high ethical standards. As a system to support its practice, we implemented a reporting system that can be used by both our employees and suppliers.
In April 2019, we established the Integrity Line, for the Olympus organization worldwide.

Whistleblowing System

Integrity Line (Global Reporting System)

As stated in the Olympus Global Code of Conduct, all employees are responsible for immediately reporting any suspected violation of the Code or Company policy.
Olympus is committed to our culture of integrity and provides a safe and open workplace for all employees to ask questions and raise concerns. We provide a global reporting system, known as the Olympus Integrity Line, which is available to all Olympus employees, third parties, and the general public who may wish to report a concern. The Olympus Integrity Line is operated by an independent third party and is available 24 hours a day, seven days a week, 365 days a year, in multiple languages. The Global Compliance function expanded efforts to promote our Integrity Line and Disclosure Program. Olympus does not tolerate retaliation against individuals who report concerns in good faith.
The Global Compliance function manages and monitors the Integrity Line, and refers matters for review, as appropriate, to other functions, such as Human Resources, depending on the nature of the concern. The Integrity Line system is continuously assessed and improved. In 2020, enhancements were implemented to improve reporting and trending capabilities, which reporting is designed to support employee confidence that speaking-up and raising concerns can make a difference in their organizations.

Website for the Olympus Integrity Line

Facilitating an Environment That Encourages the Use of the Integrity Line

Additionally, the Global Compliance function, at the direction of the Global Chief Compliance Officer and the Regional Compliance Officers, raises awareness of this system through consistent messaging in the Global Code of Conduct, and related e-learning programs and communications. During Fiscal Year 2022 Olympus received 347 reports, whether through the Integrity Line or other means. Olympus takes all reports of concern seriously. If a concern of misconduct is substantiated following appropriate review, Olympus takes corrective action, including policy/process remediation, enhanced training and education for individuals/groups, issuance of warning to individuals, and in serious cases, up to termination, in accordance with local regulations. In FY2022, 55.8% of closed reports were substantiated following review.
Specifically, with the aim of enhancing the internal reporting system and increasing its trustworthiness, we conduct systematic training of internal reporting system supervisors at Olympus and its subsidiaries.

Compliance Education

In order to raise compliance awareness and promote an understanding of important laws and internal rules, as well as to ensure consistent compliance with them, the Global Compliance function strives continually to enhance compliance education programming. By example, in Japan, the Compliance Promotion Department conducts education programs for various individuals using a variety of tools, course participants and training methods in accordance with the characteristics of applicable laws. At the subsidiaries outside Japan, the Regional Compliance division undertakes compliance education at each regional headquarters according to its annual plan.

Major Results in Compliance Education (Olympus and its Japan subsidiaries)