Olympus America

Social Responsibility: Ethics and Corporate Compliance

Code of Ethics

Olympus* hereby declares that it has established and is operating in accordance with a Comprehensive Compliance Program (“CCP”). Because Olympus is a medical device manufacturer and not a pharmaceutical manufacturer, certain guidance set forth in the PhRMA Code on Interactions with Health Care Professionals and the OIG Compliance Guidance for Pharmaceutical Manufacturers does not apply to Olympus and its operations. Consistent with this, Olympus is making good faith efforts to conform its CCP to applicable requirements of Sections 119400-119402 of the California Health & Safety Code and will generally follow the Code of Ethics adopted by the Advanced Medical Technology Association (AdvaMed).

A copy of Olympus’ Code of Ethics can be obtained here.

AdvaMed

Olympus utilizes AdvaMed’s Code of Ethics to provide guidance on ethical principles on interactions with Health Care Professionals (HCPs), not only in the United States, but in all of the countries in which it does business. The first duty of Olympus Representatives is to act in the best interests of patients by fostering compliance in our relationships with HCPs.


COMPLIANCE CODE OF CONDUCT

Olympus is committed to complying with the laws and regulations that govern our interactions with HCPs. This demonstrates our commitment to integrity in our operations and builds trust with patients, HCPs, institutions and governments. The Olympus Health Care Compliance Code of Conduct (“Compliance Code”) is driven by Olympus’ Code of Ethics which sets forth our adherence to the highest standards of business integrity. The purpose of our Compliance Code is to define the principles that govern our interactions with HCPs to ensure Olympus’ interactions with such individuals comply with applicable laws, regulations and industry guidance, as well as our own policies and procedures.

Olympus has summarized our Compliance Code in our guide entitled Keeping our Focus: Compliance Summary for Customers and Health Care Professionals ("Focus Guide") for your reference.

A copy of Olympus' Focus Guide can be obtained here

Ethics Point

Integrity Hotline

Olympus strives for ethical and compliant behavior.  Every Olympus Representative has a duty to report any suspected violations or inappropriate actions.To ensure that allegations of improper or illegal conduct, activities or practices are heard and addressed, we provide an anonymous, confidential reporting system (the "Integrity Hotline").

The Integrity Hotline is maintained by a third-party, EthicsPoint. You can make reports to the Integrity Hotline 24 hours a day, 7 days a week, every day of the year, by telephone or by using the internet.

When using the Integrity Hotline, you may elect to remain anonymous. In all cases, reports are treated with the utmost discretion.

The Integrity Hotline is accessed in the following manner:

Telephone:

U.S., Canada & Puerto Rico: 1-844-277-1698
Canada-French: 1-855-350-9393
Costa Rica: 0800-011-1248
Mexico: 001-855-232-1301
Brazil: 0800-892-0649

Encrypted website: http://olympusamerica.ethicspoint.com

After you complete your report, you will be assigned a unique code called a “report key”. Write down your report key and password and keep them in a safe place. After 5-6 business days, use your report key and password to check your report for feedback or questions. Company policy prohibits retaliation against any individual for reporting concerns to the Integrity Hotline in good faith.

In addition to the Integrity Hotline, you may continue to report concerns about unethical or unlawful conduct directly to management, Human Resources, the OCA Ethics Compliance Officer, the OCA Legal Department and/or the OCA Compliance Department. The OCA Compliance Department can be reached directly via phone at 484-896-4472 or via email at compliance@olympus.com.

* As used throughout this website, “Olympus” or the “Company” refer collectively to Olympus Corporation of the Americas, Olympus America Inc., Olympus Imaging America Inc., Olympus Latin America, Inc., Olympus Canada Inc., Olympus Memory Works America Inc., Gyrus ACMI, Inc., Gyrus ACMI, L.P., Gyrus ENT, L.L.C., and Gyrus Medical, Inc.

**All Olympus employees and other representatives engaged (directly or indirectly) to perform work for, or on behalf of Olympus, including temporary agency personnel and other independent contractors such as independent sales entities or representatives and distributor entities or representatives, or sales agents, wherever located, (referred to collectively as “Olympus Representatives”).