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 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. The Global Code of Conduct is available online in 18 languages.

Olympus Global Code of Conduct

Acting with Integrity Matters

The Olympus Global Code of Conduct reflects our enduring legacy of innovation, meaningful impact, 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 patients, customers, suppliers, and third-party business partners respectfully, fairly, and report concerns when they arise.

The Olympus Group is committed to fostering a business culture that upholds the highest standards of business integrity in all our relationships. The Chief Executive Officer is responsible for ensuring compliance with applicable laws and regulations across the Olympus Group’s business operations and has appointed the Global Chief Compliance Officer (GCCO), who reports to the Global General Counsel, to oversee the Compliance Management System for the Olympus Group.

The Board of Directors and its Audit Committee receive periodic reports on compliance activities from the CEO and consult with the GCCO as needed. The GCCO is responsible for all compliance activities across the Olympus Group. The GCCO works with the Regional Chief Compliance Officers and other members of their global leadership team to operationalize the Olympus Group's Compliance Management System based on current best practices. In FY2025, the Legal Function and the Governance, Risk and Compliance Function (GRC) were combined into a single organizational team, now known as the Legal, Risk and Compliance Function (LRC), under the leadership of the Global General Counsel. This enhanced LRC Function and organizational design, effective October 1, 2024, improve collaboration among these subfunctions, create a more streamlined and effective team, and further strengthen risk management across the Olympus Group.

Compliance Management System (As of October 1, 2024)

Initiatives

Compliance with Laws and Regulations

In FY2026 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 FY2026, improvements included a strategic focus on continuing to enhance the Global Internal Investigations Committee's oversight capabilities through improved reporting, as well as enhanced cross-functional training to strengthen investigation skills and improve the management of reported concerns.

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 FY2026, Olympus received 606 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 FY2026, 48% 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. The following provides an overview of the training courses and communications delivered globally by our Compliance Function in FY2026.

e-Learnings

Core Ethics & Compliance

In FY2026, 57,828 required Core e-Learning Assignments were deployed globally across our Global Code of Conduct and Anti-Bribery programs, reinforcing consistent compliance standards across all regions. These programs achieved a 98% overall completion rate, equipping employees to make informed, timely decisions and operate with confidence while meeting legal and regulatory requirements. A 93% on-time completion rate reflects disciplined execution and strong employee commitment to understanding company requirements.
Global, structured training and communications strengthen our culture, support responsible risk-taking, and build capability for ethical decision-making across the organization.

Emerging & Specialized Risk Programs

In FY2026, 40,372 Risk E-Learning Training Assignments were deployed across AI Literacy, Insider Trading, and Privacy for HR topics, expanding governance beyond core compliance into emerging and specialized risk domains. A 93% overall completion rate reflects strong organizational adoption of these newly introduced areas, reinforcing capability building in priority risk topics. All trainings were delivered in 17 languages, ensuring consistent global standards. Additionally, in Q4 FY2026, we initiated structured feedback collection to enable continuous quality improvement and further strengthen learning effectiveness.

Instructor-Led Training

Compliance Management	175 instructor-led sessions conducted. Focused on ethical standards, Anti-Bribery and Anti-Corruption requirements, and practical case discussion. 2,706 participants engaged. Supporting operational compliance awareness across functions.
HCPO Interactions	87 instructor-led sessions conducted. Addressing healthcare professional engagement standards and interaction-related risk scenarios. 2,262 participants engaged. Strengthening compliant conduct in sensitive commercial environments.
Third-Party Risk Management	21 instructor-led sessions conducted. Focused on strengthening risk awareness among Olympus employees and external third parties, reinforcing responsible conduct in partner relationships. 3,772 participants engaged. Enhancing accountability in partner and supplier relationships.
Privacy	33 instructor-led sessions conducted. Focused on regulatory data privacy requirements and applied risk scenarios. 1,997 participants engaged. Reinforcing practical privacy compliance in day-to-day operations.

Communications

Leadership Engagement & Speak-Up