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.

• Olympus Global Code of Conduct
• Olympus Group guidelines covering the prevention of bribery

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. In August 2022, we enacted the "Rules for Insider Information Management" to consolidate internal information within the Olympus Group, determine whether certain information qualifies as internal information, and establish the necessary fundamentals for managing internal information, including methodologies and organizational structure. In addition to the above, the Insider Trading Prohibition Rules, formulated in June 2012, clearly forbid the 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 FY2023, 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 FY2023, same as past years.

International Trade and Economic Sanctions

The movement of products, services, and investment across borders subjects Olympus and other companies to extensive trade regulations. A variety of laws and regulations in the countries in which Olympus transacts business apply to the sale, shipment, and provision of medical goods, services, and technology across borders. Governments also impose economic sanctions against certain countries, persons, or entities. In addition to our need to comply with such regulations in connection with our direct activities, Olympus also sells and provides goods, technology, and services to agents, representatives, and distributors who may export such items to various customers and end-users throughout various levels of public and private procurement chains. Sanctions are the regulatory restrictions applicable to dealings with certain countries, territories, governments, groups, entities, individuals, or controlled goods or services. If Olympus, or the third parties through which Olympus does business, are not in compliance with applicable laws and regulations on import/export controls or economic sanctions, Olympus (and those third parties) may be subject to civil or criminal action and varying degrees of liability.

It is Olympus’s policy to comply with all applicable trade regulations in our operations wherever located worldwide. The nature and extent of those restrictions may vary (prohibitions on any or all transactions, limitations on imports/exports, controls on specific goods and services, restrictions on financial operations, etc.), but it is important that all Olympus Group employees, customers, vendors, and contractors are aware of and comply with those restrictions. To maintain this system, Olympus manages a program for the purpose of identifying direct or indirect risks associated with transactions subject to economic sanctions. This program includes identifying potential threats to or vulnerabilities of (i) the Olympus Group’s customers and customers’ customers through to the ultimate consumer, the supply chain, intermediaries (including financial institutions), and counterparties; (ii) the products and services offered by the Olympus Group, including how and where such products or services fit into other commercial products or services; and (iii) Olympus geographic locations, as well as the geographic locations of our customers and customers’ customers through to the ultimate consumer, the supply chain, intermediaries (including financial institutions), and counterparties.