EthicsPoint - Olympus

About the Olympus Integrity Line

Reporting Security & Confidentiality

About EthicsPoint

What is EthicsPoint?

EthicsPoint is a comprehensive and confidential reporting tool created by NAVEX that enables employees, business partners, and anyone with relevant information, to report issues, concerns, or questions to the organization, which allows management and employees to work together to address fraud, abuse, and other misconduct in the workplace while cultivating a positive work environment.

Why do we need a system like EthicsPoint?

At Olympus our employees are our most important asset. By creating open channels of communication, we promote a positive work environment and maximize productivity.
Olympus values its relations with its business partners and believes that providing an independent channel of communication reinforces our expectation that third parties working with Olympus conduct themselves ethically and in compliance with applicable laws and requirements.
An effective reporting system augments our other efforts to foster a culture of integrity and ethical decision-making.
Olympus is required by law in many jurisdictions to provide employees and third parties with an independent channel for reporting misconduct.

About the Olympus Integrity Line

What is the Olympus Integrity Line?

The Olympus Integrity Line is the Olympus-branded global hotline tool available 24 hours a day, 7 days a week, and 365 days a year, in multiple languages – either by phone or on-line. The Olympus Integrity Line is powered by EthicsPoint and has translators available to ensure we understand your concern.

If I call the Olympus Integrity Line, will I be connected to an Olympus employee?

No. All calls to the Olympus Integrity Line are handled by NAVEX agents who will document your concern and submit it to Olympus.

Reporting – General

May I report using either the Internet or the telephone?

Yes. EthicsPoint enables you to submit a confidential, anonymous report via either the telephone or the internet through the Olympus Integrity Line. Employees may also report concerns directly to their manager, or a member of the HR, Legal, GRC/Compliance Function(s).

What types of situations should I report?

The EthicsPoint system allows employees to report any violation of our Global Code of Conduct, or other concern you may have.

If I see a violation, shouldn't I just report it to my manager, security, or human resources and let them deal with it?

When you observe some behavior that you believe violates our Global Code of Conduct, we expect you to report it. Ideally, you should bring any concerns forward to your direct manager or other member of our management team. We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner. It is for such circumstances that we have partnered with NAVEX. We would rather you report anonymously than keep the information to yourself.

Why should I report what I know? What’s in it for me?

Speaking up is often the only way to detect misconduct which may expose patients, employees, and Olympus to harm. By reporting misconduct, you will help prevent damage to Olympus, protect patients, and contribute to the long-term success of the Company.

Further, we all have the right to work in a positive environment and with that right comes the responsibility of acting in an ethical manner and letting the appropriate people know if someone is not acting appropriately. By working together, we can maintain a healthy and productive environment.

Does management really want me to report?

We certainly do. In fact, we need you to report. You know what is going on in our company - both good and bad. You may have initial knowledge of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on the company and our people. Also, offering positive input may help identify issues that can improve corporate culture and performance.

Where do these reports go? Who can access them?

Reports are entered directly on the EthicsPoint secure server. NAVEX makes these reports available only to specific individuals within the company who are charged with evaluating the report, based on the type of violation and location of the incident. Each of these report recipients has had training in keeping these reports in the utmost confidence.

Who reviews a report of concern?

An internal case manager who has had extensive training on our Global Code of Conduct and how to resolve reported issues will be assigned to each reported concern. The case manager will thoroughly review the concern, only discreetly involving those parties necessary to bring it to resolution.

Isn’t this system just an example of someone watching over me?

No. EthicsPoint is a positive aspect of our overall philosophy that allows us to ensure a safe, secure and ethical workplace. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate a concern. Effective communication is critical in today’s workplace and this is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

If I’m contacted about a conduct concern, do I have to answer questions and/or provide information, if I’m asked to do so?

Yes. If someone has contacted the Olympus Integrity Line with a concern, you are required to participate as necessary as we thoroughly look into the concern.

How long will it take for someone to look into my reported concern?

While it is always the case manager’s goal to complete their review or investigation as swiftly and thoroughly as possible, the length of time may vary depending on the complexity of the concern or availability of information and participants involved. The case manager is responsible for keeping you informed on the progress as necessary, although the level of information they can share with you may be limited due to confidentiality.

Reporting Security & Confidentiality

It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the report originator?

NAVEX does not generate or maintain any internal connection logs with IP addresses, so no information linking your PC to EthicsPoint is available.

If you feel uncomfortable making a report on your work PC, you have the option of using a PC outside our work environment (such as one located at an Internet café or at a friend’s house) through the EthicsPoint secure website. Many people choose this option, as NAVEX data shows that fewer than 12% of reports are generated during business hours.

Can I file a report from home and still remain anonymous?

A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the EthicsPoint system strips away Internet addresses so that anonymity is totally maintained.

I am concerned that the information I provide EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

The EthicsPoint system protects your anonymity. However, if you wish to remain anonymous, you - as a reporting party - need to ensure that the body of the report does not reveal your identity by accident. For example, “From my cube next to Jan Smith…” or “In my 33 years…”.

Is the telephone toll-free hot line confidential and anonymous too?

Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the EthicsPoint Web site. These reports have the same security and confidentiality measures applied to them during delivery.

What if I want to be identified with my report?

Most employees that report concerns do identify themselves. This is helpful to gain useful information, identify witnesses and have additional detailed interviews in order to fully review a concern. There is a section in the report to identify yourself, if you wish.

Tips & Best Practices

I am aware of some individuals acting unethically, but it doesn't affect me. Why should I bother reporting it?

Our company promotes ethical behavior. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. You only have to consider what happened in recent corporate scandals to see the disastrous effects that a lapse in ethics can have on an otherwise healthy company. If you know of any incidents of misconduct or ethical violations, consider it your duty to yourself and your coworkers to report it.

I am not sure if what I have observed or heard is a violation of company policy, or involves unethical conduct, but it just does not look right to me. What should I do?

Report a concern. NAVEX can help you prepare and submit your concern so it can be properly understood. We'd rather you report a situation that turns out to be harmless than let possible unethical behavior go unchecked.

What if my boss or other managers are involved in a violation? Won’t they get the report and start a cover-up?

The EthicsPoint system ensures that implicated parties are not notified or granted access to reports in which they have been named.

What if I remember something important about the incident after I file the report? Or what if the company has further questions for me concerning my report?

When you file a report at the EthicsPoint Web site or through the EthicsPoint Call Center, you receive a unique, randomized number called a “Report Key” and are asked to choose a password. You can return to the EthicsPoint system again either by Internet or telephone and access the original report to add more detail or answer questions posed by a company representative. We strongly suggest that you return to the site in the time specified to answer company questions. You and the company now have entered into an “anonymous dialogue,” where situations are not only identified, but can also be resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondences are held in the same strict confidence as the initial report, continuing under the umbrella of anonymity.

What if I lose my Report Key or forget the Password I created?

To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.

Can I still file a report if I don’t have access to the Internet?

You can file an EthicsPoint report from any computer that can access the Internet. You can file from home. Many public locations, including the public library, have Internet computers. If you don’t have access to or are uncomfortable using a computer, you can call the EthicsPoint toll-free hotline, which is available 24 hours a day, 365 days a year.