Anti-Corruption
Systems and Mechanisms
Prevention of Bribery
The Olympus Group will never engage in actions that could be deemed to be bribery in its dealings with any of its business partners, such as government officials, and employees of government agencies (including international agencies), or any other parties. In addition to having established our own rules based on key laws and regulations and thoroughly educating our employees on those rules, we are working on the prevention of actions that could be interpreted as bribery by tightening the rules governing external business dealings and internal approval system as well as by implementing process controls. With the Global Code of Conduct 
, the Olympus Group has established a key guideline to preventing bribery, which has been disclosed on its website.
Exclusion of Antisocial Forces
The Olympus Group will have no involvement with organized crime syndicates, or any other antisocial forces that threaten the order of society and will never engage in actions that could support their activities.
We will respond resolutely and in accordance with the law to any fraudulent demands from antisocial forces. In July 2012, "Regulations for the Elimination of Antisocial Forces" covering the Olympus Group were formulated.
For Olympus and its Japan subsidiaries, in principle, we conclude contracts or memorandums of understanding incorporating provisions relating to the exclusion of antisocial forces with all new business partners (including clients and suppliers as well as partners in joint research) of.
For subsidiaries outside Japan, we are confirming that our business suppliers and partners do not have any ties with antisocial forces in compliance with the "Regulations for the Elimination of Antisocial Forces."
Prevention of Insider Trading
The Olympus Group is determined to ensure the fairness and soundness of security markets and earn the trust of shareholders and investors by working to prevent insider trading. Formulated in June 2012, the Insider Trading Prohibition Regulations clearly forbid use of undisclosed information gained through activities related to trading in stocks, and continuous education and training about these regulations is provided to all employees.
We have adopted rules, such as those concerning the buying and selling of our own shares by directors and employees, and we consistently comply with those requirements, including the submission of notices concerning such transactions. In FY2022, an e-learning program to prevent insider trading was implemented for all employees of Olympus Group in Japan. At the same time, lecturers were invited once a year from the Tokyo Stock Exchange to training sessions for those employees from our Olympus headquarters corporate divisions who have ample opportunity to come into contact with insider information. There have not been any insider trading matters in FY2022, same as past years.
Security Export Control and Appropriate Import Declaration
The Olympus Group works in compliance with security export control regulations around the world in order to contribute international peace and safety. In Japan, we set up an export control system that conforms to the Compliance Programs designated by the Ministry of Economy, Trade and Industry. Since 2007, we have certified as an Authorized Economic Operator (AEO)* by Japan Customs and received preferential treatment as a company with superior export controls. To maintain this system, we renewed the internal training system in FY2022. While conducting basic training programs to cover nearly all executives and employees in Japan, we also continued to provide specialized training programs covering import-export transaction based on employees' degree of involvement in such work.
On the other side, paying the appropriate tax for imported goods is also an important area of responsibility as a business. Therefore, as a general rule with respect to products and parts procured from overseas, it is assumed that the import control department of Olympus and its Japan subsidiaries will have assessed the import declaration price, which forms the basis of the tax payment, prior to the placement of the order from FY 2018. Such activities for Olympus and its Japan subsidiaries continued in FY2022 to prevent import declarations with inappropriate prices and revisions to customs declarations.
*AEO (Authorized Economic Operator):
A program that offers relaxed or simplified custom processes to operators certified as having sufficient security and legal compliance systems in place for managing shipments, in order to ensure both security and smooth operations in international distribution. In Japan, the program is certified by Japan Customs.
Implementation Status of Training Designed to Maintain Security Export Control and Appropriate Import Declaration (Olympus and its Japan subsidiaries/FY2022)
| Target | Aim/Description of Training | Participants |
|---|---|---|
| Departments involved in AEO (authorized exporter declaration) | Obligations of AEO providers and sharing of accident cases. | 150 |
| Departments responsible for import-export transaction as a main task | Obligations of AEO providers and sharing of accident cases. | 92 |
| Departments responsible for import-export transaction as a supplementary task (import- export system users) | Internal operation of import-export control transactions, and contacts for inquiry (e-learning program). | Export: 1,852 Import: 329 |
| Nearly all directors and employees working in Japan (including subsidiaries) | Basic awareness of import-export controls (e-learning program). | 10,355 |