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ETHICS AND CORPORATE COMPLIANCE
Ethics and Corporate Compliance
Olympus Corporation of the Americas (OCA) and all of our businesses are subject to the laws, regulations and ethical standards in each industry we serve, some of which are unique to the health care and life sciences areas of our business.
We are committed to complying with the laws, regulations and highest ethical standards, and adhering to our own Codes of Conduct which guide our business processes, decisions and behavior.
CODE OF ETHICS
Conducting Business Within a Culture of Compliance
For Olympus Group companies worldwide, compliance with the law does not only mean following the letter of the law. It also means operating within a culture of compliance, and conducting our business in the spirit of corporate social responsibility. Earning and keeping the respect of our employees, business partners and our communities is of paramount importance.
To assist in maintaining the highest ethical standards, and to ensure that our core ethical values are embraced and understood at all levels of the Olympus organization and throughout our global operations, Olympus Corporation of the Americas has established a Code of Ethics (“Code”). Upon employment, each OCA employee is required to certify that he or she has read the Code, understands it and agrees to comply with it. Furthermore, on an annual basis, all OCA employees are required to successfully complete on-line Ethics training and recertify their understanding and agreement to comply with the Code.
The core principles of our Code focus on:Fostering a culture of complianceAccomplishing innovation with integrityRespecting one another Engaging in corporate social responsibilityClick the following link to view or download a copy of the Olympus Corporation of the Americas’ Code of Ethics.
COMPLIANCE CODE OF CONDUCT
Governing our Interactions with the Health Care and Life Sciences Industries
The Olympus Health Care Compliance Code of Conduct (“Compliance Code”) governs our interactions with our customers and health care professionals (“HCPs”). It also helps define our commitment as a corporation and as individuals to abide by the laws and industry standards that apply to our day-to-day interactions with our customers and HCPs.
Our Compliance Code is based on three fundamental principles:Medical decisions should be focused on the best interests of patients.Products must be promoted in a manner consistent with the Food and Drug Administration’s (FDA) approved uses (indications) as listed in the product labeling.Training HCPs and others how to utilize our products and services in a safe and effective manner is important to enhance the well-being of the patients they serve.
The Compliance Code for Olympus Corporation of the Americas is summarized in a guide entitled Keeping our Focus: Compliance Summary for Customers and Health Care Professionals (Focus Guide). View or download a copy of Olympus’ Focus Guide
Olympus's commitment to a culture of compliance is fully supported by senior management and Olympus expects all Olympus Representatives to reflect that commitment through their actions and decision-making. Olympus fosters this culture of compliance by developing clear and consistent policies, conducting regular compliance trainings, encouraging open communication, responding timely to concerns and identified risks and administering corrective action when necessary. In the United States, Olympus plays an active role in the Advanced Medical Technology Association (AdvaMed). The Olympus Compliance Program has been developed based upon published guidance from the U.S. Federal Government, and its foundational elements are also consistent with the AdvaMed Code of Ethics on Interactions with Health Care Professionals (AdvaMed Code). Olympus has certified to the AdvaMed Code. Olympus has strict anti-bribery policies in place and is committed to complying with anti-corruption laws in every place in which we do business.
Olympus is committed to ethical behavior by all employees in compliance with the laws and regulations that govern our industry. Olympus strives for ethical and compliant behavior. If there is ever an instance where you believe we have failed to live up to our standards, please let us know so we can take corrective action and address the issue. Every Olympus Representative (including Company personnel and agents) has a duty to report any actual or suspected violations of any laws, regulations, government health care program requirements, internal policies and procedures, or inappropriate actions. To ensure that allegations of improper or illegal conduct, activities or practices are heard and addressed, OCA maintains an anonymous, confidential reporting system (the "Integrity Hotline").
The Integrity Hotline is maintained by a third-party, Ethics Point. Employees, customers, business partners and other third parties may 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. Ethics Point provides issue reporters with multi-lingual Hotline support and translation services.
When using the Integrity Hotline, issue reporters may elect to remain anonymous. In all cases, reports are treated with the utmost discretion. To maintain anonymity, issue reporters are assigned a unique code, called a “report key” within the Ethics Point system after reports are submitted, which is intended for the reporter’s eyes only.
The Integrity Hotline is accessed in the following manner:
Telephone:U.S., Canada & Puerto Rico: 1-844-277-1698Canada-French: 1-855-350-9393Costa Rica: 0800-011-1248Mexico: 001-855-232-1301Brazil: 0800-892-0649
Encrypted website: http://olympusamerica.ethicspoint.com
In addition to the Integrity Hotline, OCA welcomes any reporting of 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 email@example.com. Company policy prohibits retaliation against any individual for reporting concerns to the Integrity Hotline or directly to management in good faith.
OPEN PAYMENTS REPORTING
Open Payments is a U.S. national disclosure program created by the Affordable Care Act that increases public awareness of financial relationships between the health care industry (like medical device manufacturers and pharmaceutical companies) and physicians or teaching hospitals. Olympus is required to report payments or transfers of value they make to U.S. physicians or teaching hospitals. The Centers for Medicare & Medicaid Services (CMS) collects this data annually and makes it publicly available and searchable online.
Visit https://openpaymentsdata.cms.gov to use the CMS Open Payments Data search tool to search for information regarding payments made by Olympus to doctors or teaching hospitals. You can download all Open Payments data in detail, or search based on the Physician or Teaching Hospital receiving the payment, or the Company making the payment. Additional information on Open Payments is available on the Centers for Medicare and Medicaid Services website at https://www.cms.gov/OpenPayments/.
Any questions/inquiries regarding the Olympus Open Payments report can be directed to AggSpend@olympus.com.
REPORTABLE PAYMENTS AND TRANSFERS OF VALUE
Olympus collaborates and interacts with health care providers in order to advance new, safe and effective medical technologies that lead to improvements in patient care, helping people around the world lead safer, healthier and more fulfilling lives.
Olympus values its relationship with health care providers and is committed to the transparency afforded by the Open Payments Reporting. Olympus’ Open Payments report includes the following types of transfers of value it makes to U.S. Physicians and Teaching Hospitals:Compensation paid to health care professionals for services performed for the CompanyEducational items (e.g., medical text books, scientific journal articles)Food, beverage, travel, and lodging relating to consulting services, product training, and other business related activitiesEducation on the use of our products and related treatmentsResearch on new products to help advance patient careCharitable contributionsRoyalties or license paymentsGrants to support independent healthcare educationSpace rental or facility fees associated with product training, clinical studies, or booth/exhibit space
“Foreign Corrupt Practices Act” or “FCPA” means a U.S. based law that is applicable globally, and makes it unlawful for a U.S. person to corruptly pay, promise, authorize, or offer to pay or give anything of value, directly or indirectly, to any non-U.S. government official, to any non-U.S. political party or party official, or to any candidate for public office in order to obtain or retain business, to direct business, or to gain an improper business advantage.“Anything of value” means any type of benefit and includes, for example:
- Money (including discounts or credit)
- Services: healthcare, home improvement, education, spa treatments
- Money (including discounts or credit)
- Gifts: jewelry, clothes, art, cars, equipment
- Donations: political contributions, payment of mortgages, car leases
- Charitable contributions to an organization in which a Government Official is involved
- Travel: vacations for the official, his/her family or friends or per diems
- Investment opportunities (e.g., “joint ventures”), offer of employment
“Government Official”means: (1) any officer or any employee of a non-U.S. government entity, government department, or government agency; (2) any officer or any employee of a commercial enterprise that is fully or partly government owned or controlled; (3) any officer or employee of a public international organization such as the International Monetary Fund, the World Health Organization, and the World Bank; (4) any non-U.S. political party official or political party; (5) any candidate for a non-U.S. political office; or (6) any individual who acts on behalf of any of the above listed organizations or individuals. Health care professionals, such as physicians, employed by or acting on behalf of a health care entity, owned or controlled by a government entity, such as public hospitals or state universities are considered Government Officials under the FCPA.
Other Local, National, and international laws and regulations:
It is an obligation for Olympus, its subsidiaries, affiliates, third parties (agents, distributors, custom brokers), and customers to comply with local, national and international laws and regulations applicable to its business, including anti-corruption laws. Please make sure that you and your company comply with all applicable local, state and federal laws and regulations including those in the jurisdiction where are registered and the jurisdiction where the services are provided or to be provided.