Basic Approach and Policy

Because What We Do Matters
Olympus Global Code of Conduct

What we do at the 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 have 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 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's 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 management teams and employees with the resources and training they need to do business with integrity, treat customers, suppliers, and third-party business partners fairly, and report concerns when they arise.

The Olympus Group is committed to fostering a business culture that follows the highest standards of business integrity in all our relationships. The Chief Executive Officer is responsible for compliance with applicable laws and regulations within the business operations of the Olympus Group and has appointed the Global Chief Compliance Officer (CCO), an Executive Officer, who is responsible for the Compliance Management System within the Olympus Group. The Board of Directors and its Audit Committee receive periodic reports on compliance activities from the CCO, and they consult with the CCO as needed. The CCO chairs the Global Leadership Team (GLT) consisting of the Regional Chief Compliance Officers, Chief Privacy Officer, and other persons designated by the CCO. Together with members of the GLT, the CCO ensures that relevant internal regulations are observed in the regional business centers and that compliance activities are carried out in accordance with the requirements of the management systems overseen by the CCO and are reflective of best practices. During FY2023 the CCO led an organizational design activity that resulted in the integration of the Risk & Controls, Compliance, Privacy, and Information Security functions into the new and more unified Governance, Risk & Compliance (GRC) Function. This enhanced GRC Function and organizational design, effective April 1, 2023, will improve collaboration among these subfunctions and further strengthen risk management for Olympus.

Compliance Management System (As of April 2023)

Compliance Management System (As of April 2023)


Compliance with Laws and Regulations

In FY2022 there were no violations that caused penalties or other punitive measures concerning 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 the Unfair Competition Prevention Act
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 the Labor Standards Act and Industrial Safety and Health Act
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

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 provides a global reporting system, which is available to all Olympus employees, business partners, and other third parties who wish to report a concern. This system is known as the Olympus Integrity Line and is managed by a third-party company that is independent of Olympus. The Olympus Integrity Line can be used at any time (24 hours a day, 7 days a week, 365 days a year). The system can be accessed via telephone or online. Translators are available to ensure concerns are understood. The compliance function maintains a cross-functional team that meets regularly, collaborating to continuously improve the effectiveness of the reporting system and processes. In FY2023 improvements included the enhanced tracking of policy violations, the integration of additional regional reporting of conflicts of interest, and global adoption of the Olympus Internal Investigations Policy, which establishes the Global Internal Investigations Committee and provides the framework for the Company’s internal investigations process as we strive to ensure that legitimate reports of concern will be investigated and treated according to the same high standards regardless of location or department.

Whistleblowing System

Facilitating an Environment That Encourages Use of the Integrity Line

Additionally, the Global Compliance function, at the direction of the Global Chief Compliance Officer and Regional Chief Compliance Officers, raises awareness of this system through consistent messaging in the Global Code of Conduct and related e-learning programs and communications. During FY2023 Olympus received 809 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, termination in accordance with local regulations. In FY2023, 82.1% of closed reports were substantiated following review.

Compliance Training

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.

Anti-Bribery & Anti-Corruption Total Employees, Assignments, and Completion by Regions

Olympus Global Code of Conduct Total Employees, Assignments, and Completion by Regions