dear colleagues, o · create trust we aim to 11 colleagues one of your colleagues may have been in...

Dear Colleagues,

3

Our common goal as a team is to develop and provide products that make people’s lives healthier, safer and more fulfi lling. However, what

matters is not only what we do, but also how we do it. As the world around us becomes in-creasingly global and competitive, we will con-tinue to run our business in an ethically correct and compliant manner.

Through our work and dedication, each and every one of us contributes to the good reputation of Olympus in society and in the industry. This can only happen if users trust us and our products. We have to earn and renew this trust every day.

The above applies equally to all of us, from general staff to management. We are all called upon to take responsibility, to show integrity and to do the right thing. The Code of Ethics and Business Conduct is intended to serve as a set of guide-lines. It sets out how we act as a reliable company for our business partners, of whom we also expect fully ethical behavior.

I would like these principles to become a natural part of our work and our actions. We will only remain successful as a company if we all adhere to these basic policies. After all, only by combining our success in business with a responsible approach can we meet our objective of developing and offering products that make people’s lives healthier, safer and more fulfi lling.

Many thanks for your support!

Stefan Kaufmann,Executive Managing Director Olympus Europa Management SE

Olympus Europa SE & Co. KG

Amsinckstraße 6320097 HamburgGermanywww.olympus-europa.com

Status: October 2018

INHALT

OUR CORPORATE PHILOSOPHY 5

OUR CODE OF CONDUCT 6

Checking Decisions ....................................................................... 08b

Recognizing and Responding to Incorrect Behavior ...................... 09

BUSINESS INTEGRITY 12

Corruption .................................................................................... 12

Exports .......................................................................................... 16

Competition .................................................................................. 16

Finance and Taxes .......................................................................... 18

Expectations towards Business Partners ......................................... 20

AMONG COLLEAGUES 21

Respectful Behavior ....................................................................... 21

Conflicts of Interest ....................................................................... 22

Health and Safety .......................................................................... 23

RESOURCES, INFORMATION AND COMMUNICATION 24

Assets ............................................................................................ 24

IT Security ..................................................................................... 25

Communication ............................................................................ 27

Data Protection ............................................................................. 29

Insider Information ....................................................................... 30

Product Safety ............................................................................... 31

SOCIETY AND THE ENVIRONMENT 33

Social Responsibility ...................................................................... 33

The Environment ........................................................................... 35

OUR CORPORATE PHILOSOPHYCONTENTS

OUR PURPOSE

Making people’s lives healthier, safer and more fulfilling

At Olympus, we are guided by a central purpose and five global core values. These corporate values shape our culture and guide us as we grow as a company and do business around the world as One Olympus.

Our core values determine the basis on which we act and cooperate with others, both within and outside our company. They also specify what kind of behavior is desired and what is to be avoided.

5

LONG-TERM VIEWWe look beyond the

present to deliver future value

AGILITYWe challenge the status

quo with open minds, focus and speed

LONG-TERM VIEWWe look beyond

the present to deliver future value

AGILITYWe challenge the status quo with

open minds, focus and speed

UNITYWe are strongest when we work

together as a team

INTEGRITYWe are trustworthy and

act in good faith

EMPATHYWe care about

all of ourstakeholdersOUR

CORE VALUES

UNSER LEITGEDANKEWir machen das Leben von Menschen gesünder, sicherer und erfüllender

4 | Code of Ethics & Business Conduct

The Code of Ethics and Business Conduct is a point of reference that tells us what behavior is legal as well as what is ethical and responsible for our company. It reflects our core values, national and international laws, internal policies, voluntary commitments and ethical principles.

The management team is firmly committed to the content of this document. It applies without exception to all employees and management staff at Olympus. Our managers in particular should act as role models in terms of compliance with the code of conduct. Naturally, we also expect our business partners and their employees to act in accordance with the code of conduct and to share the same ethical values.

Incorrect behavior by any individual brings the risk of long-term damage to colleagues and the company as a whole. Violations of statutory law can, among other things, lead to fines and claims for damages; they can also harm our good reputation.

The code of conduct tells us which actions are prohibited and what can be the legal conse-quences. In addition, it shows which behavior is preferable for you in certain situations. The guidelines contained in the code of conduct are not exhaustive. There are also national specifica-tions and internal operating procedures that apply to your individual area. The code of con-duct is regularly reviewed and adapted so that it is always up to date. Please contribute by suggesting possible changes to the document to the Compliance department.

OUR CODE OF CONDUCT

responsibilityWe demonstrate


“I know my manager has to tell me that, but we both

know that we’ll do it differently — unoffi cially.”

“The authorities haven’t taken an interest so far.”

9

We are open when dealing with mistakes. Only by discussing problems can we fi nd solutions and improve as a team. All employees are required to report illegal behavior by employees, managers, suppliers and business partners to the Compliance department or via the EthicsLine – for example, in case of fi nancial fraud or viola-tions of competition law. By speaking up you will help prevent damage to Olympus.

In everyday working life, the following state-ments may point to a legal infringement or a violation of our code of conduct:

The Code of Ethics and Business Conduct sets out principles for Olympus that explain which behavior is lawful and considered as ethical as well as responsible. We expect you to act in line with these principles in your day-to-day business. Here are some examples of questions you might ask to check any decisions or actions being made:

“Other companies do it, too, and they don’t

get into trouble.”

“Oh, it’s just part of the culture

in that region.”

“What else am I supposed to do? It’s a customer

demand and I’ll lose business otherwise.”

“Let’s talk on the phone instead.

We shouldn’t discuss that in writing.”

Checking Decisions

Recognizing and Responding to Incorrect Behavior


Do I have suffi cient information?

It is better to ask for more details than to know too little.

What do the Olympus guidelines say about how I should behave?

If you are unable to fi nd any applicable infor mation, the Compliance department will be happy to put you in touch with the right person.

Do I have a bad feeling about the decision?

If so, refl ect on why you feel that way. Your gut feeling is often an important indicator.

Would I have any concerns about justifying my decision to the management?

This may be the case if your decision is not in line with our expectations in terms of ethical behavior.

Could I explain the situation to my friends and family?

Most of the people we know in private wish us well in life, but they are not directly related to Olympus. Imagine telling these people about the situation. What advice would they offer?

What would happen if my situation were discussed in the media?

It is often not only a question of right or wrong, it also matters what impression others may have of a situation. Always ask your-self how a situation would be regarded and judged by a critical third party.

create trustWe aim to

11

Colleagues

One of your colleagues may have been in a similar situation before. Talk openly about your concerns and seek advice.

Management

Your manager is there to support you at work. This includes providing advice in relation to our code of conduct and following up your concerns.

Compliance

If you have any questions or concerns about the Code of Ethics and Business Conduct, our colleagues in the Compliance department will be pleased to help. It goes without saying that your inquiries and reports are kept strictly confi dential.

EthicsLine

The EthicsLine is a service offered by an inde-pendent company, available 24 hours a day, 365 days a year. All reports are kept strictly con-fi dential and are investigated thoroughly. Details on how to contact the EthicsLine can be found at the end of this document.

The EthicsLine is available to all employ-ees, business partners and other parties who would like to report a possible violation of the Code of Ethics and Business Conduct. All reports are kept strictly confi dential, and calls cannot be traced. Every one who contacts the EthicsLine has the option to remain anony mous. Your name and any other infor mation that may be used to identify you will only be shared with Olympus or others with your explicit consent.

In some countries, anonymous reports are prohibited by law. Those affected will be informed accordingly when they start making a report.

Olympus has been living an open door policy for years. Share your concerns. Taking action to protect our values is always right and appre-ciated at Olympus. We do not tolerate discri-mination against individuals who report their concerns or take part in an investigation in good faith. This also applies if insuffi cient evidence is found to confi rm a concern.

If you seek advice or identify incorrect behavior, you do not have to deal with the situation alone.


Documentation

Our relationships with business partners must be managed and documented in writing in such a

way that it is possible to examine and trace com-munications at all times. This includes recording

the nature and purpose of any cooperation as well as the performance and consideration, res-

ponsibility for costs and payment, and evidence of the services provided (e.g. activity reports etc.).

04

Separation

Paid or unpaid benefi ts in favor of individuals employed by business partners must not be abused. It is not acceptable to infl uence purchase decisions by awarding inappropriate or illegal benefi ts. These include invita-tions to professional training events, meal invitations and gifts. If any such benefi t is awarded, it is the responsibility of each emplo-yee to adhere to the rele-vant guidelines (e.g. value limits) in order to avoid the appearance of attempted infl uence.

13

BUSINESS INTEGRITY

Transparency

Our relationships with business partners must be transparent and adhere to all of the national and local laws, regula-tions and codes of conduct that apply to the professional groups concerned.

Equivalence

If business partners are instructed to provide a service for or on behalf of Olympus, the

performance and consideration must be rea-sonably proportionate and based on the

fair market value.

Image and Perception

Even a legally permissible cooperation should always be evaluated critically to see which image will be projected to the public. The public perception of Olympus is important

for both our reputation and our business success.

03

05

01Corruption We strive to conduct business fairly and with a high level of integrity. As part of this approach, we do not tolerate corruption or bribery in our company. It is forbidden to offer, give or accept bribes or payoffs. Even small gifts may not be offered directly or through a third party in order to infl uence the recipient to provide a service in return.

The fi ve principles set out on this page represent our guide to business integrity. They can be applied to a variety of day-to-day interactions and business activities. Feel free to contact the Compliance department for support and advice.

PRACTICAL ADVICE:

An administrator working for a customer offers to expedite the payment of an unsettled invoice if you give him some money personally. Requests of this kind are not met or accepted by Olympus.

02

Equivalence

Separation

Transparency

Image and Perception

Documentation


15

When working in cooperation with different customer groups and business partners, we need to respond to a variety of risks and requirements. Internal policies at Olympus take these into account.

IndividualsWhen doing business with private individuals, we ensure that business models are in line with legal and ethical standards. Discounts may only be granted in sales situations if they have been specifi ed in advance as a general guideline. Other benefi ts, not related to the sales trans action, may not be used or promised to infl uence a pur chase decision and thus to distort competition.

Offi cialsOffi cials and employees of public institutions are required to comply with high legal and moral standards. In almost every country, it is a criminal offense to bribe or award a benefi t to a public offi cial. You should therefore check to see whether any intended benefi t is permitted. In many European countries, you may not offer a benefi t to offi cials without prior permission from their employer.

Partnerships in healthcareApart from its activities in sales, Olympus works in collaboration with doctors and other healthcare professionals as well as healthcare organizations, for instance in the areas of education and training or as part of academic studies or lectures.

Customers and business partners

Gifts

Benefi ts and gifts may only be offered if they were not requested by the recipient. They should be of symbolic value and not exceed national tax limits. Exceptions are possible in individual cases. Please document the reasons for making an exception in advance and obtain written approval from your management team.

Integrity also means that we refrain from accept-ing benefi ts or gifts from third parties if these could potentially infl uence our business deci-sions — or if they may seem to do so. You may accept small gifts if it would probably be consi-dered rude to refuse them. However, you must not ask for a gift under any circumstances. As an employee, you are required to submit any gifts once their combined value per calendar year exceeds the maximum limit of €35. If the tax limit in your country is less than €35, the lower national limit applies. Gifts that cannot be accepted by individuals are collected and then donated, auctioned with all proceeds going to charity, or shared out or raffl ed off among our employees.

Invitations to business meals

You may invite third parties to business meals and events only on occasion, provided that the costs involved are reasonable and the recipient did not request the invitation.

In turn, you can accept third-party invitations to business meals and events if their fi nancial value is appropriate and they are made on an occasional basis. These invitations should be approved by your manager. Pure incentives cannot be accepted.

GIFTS

The gift has a symbolic value

The recipient may accept the gift (in accordance with employment regulations)

In line with local law or guidance

Requested by the recipient

In the form of cash or cash equivalent (e.g. vouchers)

Possible interpretation of bribery

There are special provisions in place concerning gifts and invitations for our partnerships in the healthcare sector. Please contact the Compliance depart-ment for more information.


Who can help?

These principles apply to every country in which we operate, even if it is custo-mary in the local culture for the exchange of gifts and benefi ts to be regarded as common business practice. Please contact the Compliance department if you have any questions.

INVITATIONS

There is a business purpose

The value and venue of the invitation are appropriate in a business context

The recipient may accept the invitation (in accordance with employment regulations)

In line with local law or guidance

Requested by the guest

Invitations provided as an incentive

Possible interpretation of bribery

MEDTECH EUROPE

Olympus is a member of MedTech Europe, a European trade association representing the medical technology industries, and acts in compliance with the MedTech Europe Code of Ethical Business Practice. Our active participation in the association means that we have a positive infl uence on the continuous improvement of ethical standards in the industry.

17

› Take great care and consider your words when communicating with competitors. This is especially important for informal dis-cussions, for example during a conference or association meeting.

› Openly identify yourself as an employee of Olympus.

› Never discuss confi dential topics with competitors, such as pricing, business areas, sales volumes or the type and quantity of products sold or produced.

› Do not talk to competitors about the way in which markets are divided or any suggestions to rule out business with certain customers.

› Never discuss sales prices with compe-titors. Price-fi xing is a clear infringement of competition law.

Exports We are required to adhere to export laws governing cross-border trade and to play an active role in control measures. Olympus Export Control Management controls all of the export restrictions pertaining to our business in Europe, the Middle East and Africa (EMEA), such as economic sanctions, embargoes and trade regulations concerning specifi c goods. The key foundations of this work are German foreign trade legislation, EU regulations as well as export regulations in Japan and the US.

CompetitionOur business relations are based on free and fair competition. In particular, we refuse to make any arrangements with competitors regarding prices, production volumes and market or customer segmentation. We do not apply unfair business practices, and we adhere to all laws concerning the restriction of competition. Violations of competition or antitrust laws can lead to high fi nes and penalties — also for employees.

Such partnerships help Olympus to develop safe, innovative and reliable technologies and related services. They are therefore critical when it comes to improving patient care.

Olympus is committed to fair and ethical beha-vior with regard to partnerships in the healthcare sector. These relationships must not be abused in order to infl uence purchase decisions, and they must not be made contingent upon certain sales transactions or the use or recommendation of Olympus products. With the support of our Medical Affairs department and by adhering to internal policies, we prevent ethical confl icts and reduce the risks for both sides.


Who can help?

Please always contact the legal department in advance in case of doubt.

Safe communication

with competitors

19

Finance and Taxes We pledge to comply with all the applicable laws, rules, regulations, as well as reporting and disclosure requirements whenever it is required by our business operations and transactions.

› We carry out our responsibilities honestly, in good faith, and with integrity and diligence. We act on our best impartial judgment at all times.

› We support the independent auditors of Olympus with maximum transparency during the audit of our financial results.

› We take every reasonable precaution to protect information about Olympus and our customers that is not in the public sphere.

› We file documents in accordance with the law and never destroy records that are, or could be, relevant to a potential or impending official investigation or court case.

› We use language that is clear and easy to understand so that the content cannot be misinterpreted, abused or taken out of context.

› We make every effort to protect our corporate values.

transparency at every level

We uphold


To ensure maximum

transparency and reliability:

Examples of harassment include racist statements, religious or sexist jokes, insulting statements, posters or cartoons of an offensive nature, intimidation tactics, the dissemination of inappro-priate jokes or offensive language in e-mails or on computers or networks belonging to Olympus and the use of pornographic materials or software.

21

AMONG COLLEAGUES

Respectful Behavior Dignity and mutual respect are at the heart of our interactions with each other and with third parties. We do not allow discrimination based on gender, age, nationality, ethnicity, skin color, political views, sexual orientation, religious beliefs, social background or disability.

Harassment-free workplace

Olympus is strongly opposed to any form of employee harassment by managers or colleagues and will not tolerate such behavior. Additionally, Olympus provides a work environment that protects employees from harassment by third parties.

The term “harassment” refers to any verbal, physical or visual behavior that creates an intimidating, offensive or hostile working atmosphere or that compromises cooperation.

Sexual harassment includes behavior such as asking for sexual favors, sexual advances and any other verbal, visual or physical behavior of a sexual nature.

Expectations towards Business PartnersWe feel responsible for the entire lifecycle of our products — from product design, material sourcing and production to environmental disposal. For that reason, we expect our suppliers and distributors to follow the rules of free and fair competition and to act in accordance with the Ten Principles of the United Nations Global Compact with regard to human rights, working conditions, environmental protection and the prevention of corruption.

We select our suppliers and distributors based on objective criteria. This includes obtaining comparative offers for goods and services, such as marketing, translations and consulting. Our decisions are made on the principle that we do not knowingly purchase goods and services from suppliers that offer unsafe products and services, violate the applicable law, use child workers or forced labor, or subject employees to corporal punishment. Any violation of law by a business partner may lead to the termination of contracts and claims for damages if they involve a loss for Olympus.


23

Confl icts of Interest When dealing with business partners, colleagues or third parties, we expect you to disclose any possible confl ict between your private interests and the interests of Olympus. This includes working with friends or family.

As a rule, we do not wish to prevent cooperation with business partners who are also family mem-bers or close personal friends of our employees and managers. However, the clear communica-tion of any possible confl ict of interest is intended to ensure that there is no actual or perceived infl uence on business relationships as a result of such collaboration.


Health and SafetyOccupational health and safety is a major prio-rity at Olympus. Preventing accidents at work as well as occupational illness is our ultimate goal. At the same time, it is very important to us that all employees work in an ergonomic and work-friendly environment. At Olympus, we do more than meet our legal obligations: our corporate culture includes offering support for long-term illness, special insurance policies and a varied range of initiatives to promote good health.

PRACTICAL ADVICE:

› The sister of a colleague in sales works in the purchasing department of an Olympus customer.

Possible solution: By disclosing the confl ict of interest and involving a manager when drafting the contract, it is possible to avoid the appearance of potentially providing a benefi t to the customer in the form of special conditions.

› In your role, you are assessing potential contractors for the award of a new con-tract. One of the potential contractors is your former employer.

Possible solution: Discuss the issue with your manager, who can then make a decision regarding the award of contract in consultation with the purchasing department. › An acquaintance of yours applies for a vacancy in your team.

Possible solution: Contact your manager and make arrangements together for a colleague from the HR department to be present at the fi rst interview to ensure that all discussions and evaluations are objective.

Who can help?

If you are uncertain in a specifi c situation, please speak to your manager fi rst. If there is a confl ict of interest, you will work together to fi nd an appropriate solution. The Compliance and HR departments will provide support and advice.

Personal relationships at the workplace

Many employees meet a future partner at the workplace. It goes without saying that we respect your privacy. There is no reason to hide a perso-nal relationship within the company. However, we would like to ask you to contact either the HR department or your manager if you see confl icts of interest at the workplace due to your relationship. Relationships between managers and their employees call for particular sensitivity.

The respective contact person and yourself will jointly seek a suitable solution. All of this happens in strict confi dence at your request.

Company assets include material assets, such as equipment and buildings, our fi nancial resources and our intellectual property as well as our trade secrets and confi dential information.

For our security

› Do not share usernames or passwords and make sure these cannot be viewed or read on screen.

› Store sensitive data on the Olympus network and not on local hard drives. Do not send confi dential data unless it is encrypted.

› Do not open or forward fi le attach-ments that you do not recognize. Do not use external memory devices unless they have been checked in advance by the IT department.

› When you leave the workplace, secure your computer by pressing the Windows key and “L” to lock the screen.

› Avoid visiting untrusted sites on the internet.

25

RESOURCES, INFORMATION AND COMMUNICATION

AssetsAll employees and managers are responsible for protecting the assets of our company. Third parties such as customers and suppliers also entrust their assets to us. We therefore ask you to ensure that any business assets entrusted to you are suffi ciently secure.

Assets may not be sold, pledged, loaned, trans-ferred or modifi ed in a manner that reduces their value unless there are reasonable business grounds for this and you have the approval of your line manager.

Company resources such as capital, personnel, software and work equipment may only be used for legitimate business purposes of Olympus.

IT SecurityWe all share responsibility for information security at Olympus. For that reason, make sure that sensitive data in particular is well protected. Take appropriate measures to protect your PCs, smartphones, iPads and notebooks.


PRACTICAL ADVICE:

› Employees and managers may not go on business trips or book fl ights at a higher price with the aim of collecting rewards or frequent fl yer points for private purposes.

› External parties may not be granted access to our IT systems without authorization.

Who can help?

If you receive a suspicious e-mail or you notice something unusual in relation to IT security, contact the IT service desk via phone +49 40 23773-4444 or via [email protected].

Always remember our motto: Stop. Think. Click.

27

Communication

Internal communication

Communicating in written language, be it on paper, in electronic documents or in e-mails, requires special attention. Statements can be taken out of context and suddenly express something completely different from what the author originally intended. As part of any external or internal investigations that might take place, company e-mails in particular are quickly accessible.

Communication with the media

Sharing internal company information with the media for any reason other than product marketing is the responsibility of the Corporate Communications department and the management team of each Olympus company in EMEA. Internal company information may pertain to fi nancial developments, incidents, accidents, crises, mergers and acquisitions or staff changes in the management structure.

You are all important ambassadors for Olympus and should be able to express yourselves freely in this sense. If communicating with the media is not one of your responsibilities, please do not speak on behalf of Olympus without prior authorization to do so.

1.

2.

3.

communicate based on professionalism and honesty

We aim to

Three simple guidelines for communicating at work:

Make sure that your communication is always fact-based, objective, transparent, professional and honest.


Bear in mind that e-mails cannot be recalled or permanently deleted once they have been sent.

Avoid communicating information that could be misunderstood.

Data Protection

29

Processing personal information about Olympus employees, customers and other business partners is important for many of our activities as a company. At the same time, protecting the personal rights of everyone involved is of utmost importance to us when it comes to handling personal data. An effi cient data pro-tection management system helps us to enact and document the various requirements of

data protection law. Data protection is also an important factor with regard to building trust and gaining new customers in a competitive environment. The privacy policy of Olympus in EMEA establishes a framework for the handling of personal data and must be followed by all employees.

Using social media Olympus has a number of social media profi les that are managed by a trained team. The content is based on global guidelines.

Some employees can be identifi ed as Olympus employees in their private social media profi le. Olympus cannot and does not wish to regulate your personal use of social media. However, we ask you to follow our social media etiquette to protect the reputation of Olympus.

Respect others, don’t be rude.Don’t say things that could be interpreted as defamatory, abusive or harassing and avoid provocative statements about race, gender, religion, or politics.

Be honest.Show responsibility for your contributions and remember that anything you say or post on social media is essentially public. Be truthful and accurate in all posts.

Obey the law; don’t tell secrets.Respect copyrights and don’t publish illegal content. Don’t post confi dential information concerning your employer.

Pay attention to your reputation and quality.You could damage your online reputation in one post. This could also affect your professional reputation or even adversely impact your employer’s brand image. Think twice before you hit the send button and make sure you are writing a quality post.

Read carefully before you respond privately; don’t respond in the name of Olympus.Sometimes we miss the point when we don’t read carefully what others say in comments or private messages. You should not respond in the name or on behalf of Olympus to inquiries in any public forum, including social media, without prior approval.

1.

2.

3.

4.

5.


Who can help?

In cooperation with the Group Data Protection Offi cer, the EMEA Data Protection department offers advice and support to ensure that we are responsible and legally compliant as far as personal data is concerned. The team can be reached at [email protected]

31

Olympus stands for high-quality products and services. To uphold our strong reputation, we have developed a quality management system that ensures compliance with international standards and allows us to continually improve our products, services and processes with the goal of maximum patient safety.

For that reason, any possible claim in connection with our products receives our utmost attention. A complaint where a patient has been injured or could have been harmed following the use of a medical device is referred to as a “Potential Adverse Event” (PAE). An internal process ensures that such complaints are managed quickly and that the patient’s welfare always comes fi rst. In order to meet the reporting deadlines set by relevant authorities around the world, all Olympus employees are required to follow this process without delay or deviation.

To test the effectiveness of this quality manage-ment system, it is constantly monitored by an independent certifi cation body, and internal inspections are carried out in the form of quality audits. We play a role in continuously improving quality by meeting all the requirements of the quality management system and taking proactive steps to optimize operational processes.

Our goal is to achieve outstanding customer satisfaction and patient safety through effi cient processes.

Product Safety

You may have access to information about Olympus or our business that is not known to the public. This is known as “insider informa-tion.” Such knowledge may never be used for inappropriate purposes and should not be disclosed to outsiders. The only exception is when this information pertains to a permitted business relationship.

Insider Information

Information on our share priceCertain inside information is considered critical, which means that it may affect the share price of our parent company (Olympus Corporation, Japan). Such information includes fi nancial results, plans to acquire another company and planned announcements of new products. If you are in possession of critical inside information about Olympus, you are prohibited from trading in company shares or other fi nancial instruments until the information is public.

While certain critical insider information about the business of Olympus may not affect our share price, it could affect the share price of other companies or the value of other invest-ment opportunities. As an employee, you may not use such critical insider information to secure a personal fi nancial advantage or infl uence the market. This type of insider information may include, for example, the intention of Olympus to make a substantial investment in another company or to outsource a large volume of business to a supplier.


These rules also apply to dealings in securities on behalf of third parties as well as the disclosure of insider information to third parties and the incitement of third parties to trade in securities.

Information on the share price of other companies

SOCIETY AND THE ENVIRONMENT

Social ResponsibilityOlympus is aware of its social responsibility. The purpose of Olympus is to make people’s lives healthier, safer and more fulfi lling. This is achieved fi rst and foremost through our products, but also through our activities in the community.

We want to make a meaningful contribution to society. In order to draw on a large amount of our own skills and expertise in community projects, we have selected some areas to focus on that refl ect our business divisions: Healthcare (Medical Systems Divi sion), Photography (Consumer Products Division) and Natural Sciences (Scientifi c Solutions Division). In addition, we are involved in local activities that focus on Future Careers, working with young people to make it easier for them to access the job market and supporting them on their professional pathway.

33

Healthcare Medical Systems

Division

Natural Sciences

Scientifi c Solutions Division

Photography Consumer Products

Division

Future Careers

Local activities

a commitmentto social issues

We demonstrate


DONATIONS

Olympus donates money and supplies to charitable organizations solely for altruistic or philanthropic purposes. Our donations support projects with goals such as ensuring the provision of medical care, developing structures or helping people to help themselves. We also support projects that encourage or facilitate access to education and the world of work.

GRANTS

Olympus allocates funds and material resources for specifi c purposes to support education, training and profes-sional development in areas related to our divisions. It also provides research grants to healthcare organizations and educational and research institutions. With these grants, we support a range of activities, such as independent research projects, external training events, scholar-ships and educational campaigns.

35

We act on our corporate social responsibility by addressing topical social issues in these four areas, contributing toward positive change. We do this primarily by donating money or materials to charitable organizations or by offering grants to support education, training and professional develop ment in areas related to our divisions. We also encourage our employees to volunteer in society.

The Environment We have taken a responsible and conservative approach to using natural resources at our business locations for many years. We employ sustainable technologies at our production sites and develop environmentally friendly products for our customers. By implementing and continuously improving our environmental management system, we ensure compliance with environmental laws as well as stringent internal standards.

Furthermore, we are committed to saving energy, using renew able sources where possible and optimizing logistic processes throughout the company. We take action to improve our carbon footprint year after year with the aim of becoming climate-neutral in the long term. One possible strategy is offsetting unavoidable greenhouse gas emissions through invest ments in climate-friendly projects.

the environment and nature

We protect


Who can help?

There is a transparent process at Olympus for donations and grants that is separate from all sales activities. For more information, please contact the Medical Affairs department.

Any social projects must be discussed with the Corporate Social Responsibility team.


YOUR SUPPORT COUNTS

In this Code of Ethics and Business Conduct, we have summarized how we aim to act responsibly and in accordance with ethic principles as well as applicable laws and regulations.

Although this guidance and the examples given are based on the practical world of work, we are unable to cover every imaginable situation you may encounter in your day-to-day job. Every decision and situation that you face calls for a personal judgment and differentiated conside-ration. We therefore emphasize our main mes-sage: Question yourself and your actions. If you are in any doubt, seek help from others and take advice. You can get in touch with the contacts named in this document or your Compliance depart ment at any time.

The Code of Ethics and Business Conduct sets out the basis of our culture with reference to every-day interactions and international cooperation. Furthermore, it sets the course for the continued success of our company.

Your support and responsible behavior help us to remain a reliable partner for our customers and business partners.

Thank you!

Telephone:1. From an outside line dial the direct access number for Germany:

0-800-225-5288

2. At the English prompt dial: 8442771698

The phone numbers for the EthicsLine in other countries can be found online at www.olympus.ethicspoint.com.

Online form:

www.olympus.ethicspoint.com

HOW TO CONTACT THE ETHICSLINE

dear colleagues, o · create trust we aim to 11 colleagues one of your colleagues may have been in...

Documents