Olympus 2008 Annual Report Download - page 28

Compliance Structure
> In September 2004, the Olympus Group put in place
the Olympus Group Corporate Conduct Charter and the
Olympus Group Code of Conduct with the aim of complying
with laws and regulations, to maintain a high level of
ethics in carrying out fair and honest corporate activities,
and to consolidate a system to share its sense of value
and action principles on a global scale. Based on these
guidelines, Olympus encouraged compliance in every
aspect of its corporate activities, encompassing fair trad-
ing, trade controls, product safety and the environment. In
addition to comprehensive in-house rules, we established
a unique, Companywide set of operational standards—the
Olympus International Standards (OIS)—to act as an
employee code of behavior. As a company that specifically
engages in the Medical Systems Business, that offers
products involved with human life, Olympus is responsible
for ensuring high-level product safety, quality and
services. In addition, we developed rules and standards in
Pharmaceutical Affairs Law-related fields to comply with
a host of regulations around the world. In response to the
Revised Pharmaceutical Affairs Law, Olympus established
the Pharmaceutical Affairs Division in April 2004 to further
reinforce its business structure.
Since awareness of compliance is enhanced in an
open corporate culture, the President makes use of the
Company’s intranet system to send a monthly message
to all employees. To provide the President with feedback,
Olympus set up a system for employees to send their
opinions directly to the president. To that end, we promote
active Groupwide communication.
In October 2005, Olympus established the Compliance
Department to further strengthen its compliance structure
and set up a helpline as a point of contact for any
employee inquiries about compliance. Should compliance-
related problems arise, Olympus has in place a system
that enables the directors responsible to report problems
to the Board of Directors and the Board of Auditors. In
addition, further evidence of the Company’s commitment
to thorough compliance is provided by the distribution of
a compliance card, explaining the Code of Conduct, among
all directors and employees, as well as the provision of
e-learning and group training sessions.
INTERNAL CONTROLS
Internal Controls regarding
Financial Reporting
> Olympus established its J-SOX Act Compliance Dept., a
special division to ensure the evaluation and reporting
of internal controls regarding financial reporting, when
this was required under the Financial Instruments and
Exchange Law enforced in April 2008. Olympus makes con-
tinuous efforts to ensure that its internal control activities
are being implemented efficiently.
Risk Control Structure
> As part of its risk management rules, the Company
established a Risk Management Committee, chaired by
the president, to decide risk management policies and
the evaluation, verification and procedural standards to
respond to such risks. In addition, Olympus set up a Risk
Management Bureau to collect and assess information,
formulate countermeasures and ensure the effectiveness
of any countermeasures initiated by full-time staff.
Simultaneously, each in-house company, business site and
affiliate company has developed its own risk management
structure. Should any risks arise that have a significant
impact on the maintenance of Olympus’ corporate value,
such risks shall be immediately reported to the president
and the Risk Management Committee to determine the
countermeasures and seek a prompt settlement of the
issue. In the event that the level of risk escalates, Olympus
has a structure in place to minimize any impact on its
corporate value.
26 OLYMPUS 2008