Olympus 2010 Annual Report Download - page 28

INTERNAL CONTROLS
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 compli-
ance in every aspect of its corporate activities, encompass-
ing fair trading, 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, which offers products involved with
human life, Olympus is responsible for ensuring high-level
product safety, quality and services. Based on this view,
we established the Pharmaceutical Affairs Div. to develop
rules and standards in Pharmaceutical Affairs Law-related
fields to comply with a host of regulations around the world.
In addition, Olympus established an Ethics Committee
comprising knowledgeable people in order to conduct inves-
tigations in the area of bioethics upon the commencement of
regenerative medicine and genome businesses.
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 com-
munication.
In October 2005, Olympus established the Compliance
Department to further strengthen its compliance structure
and set up a help line 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 compli-
ance 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 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 continuous
efforts to ensure that its internal control activities are being
implemented efficiently.
Risk Control Structure
As part of its risk management rules, the Company estab-
lished a Risk Management Committee, chaired by the presi-
dent, 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.
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