Einhaltung und Integrität

HOYA Anti-Bribery and Anti-Corruption Policy

PENTAX Medical, as a subsidiary of HOYA, adheres to the HOYA Anti-Bribery and Anti-Corruption Policy (“ABAC Policy”) that is based on the principle that we work honestly and with integrity and will never offer or accept bribes or allow others to offer or accept bribes on our behalf. The ABAC Policy sets forth our commitment to:

• win and award business on the merits of products and services;

• avoid improper payments, regardless of local practices or the practices of our competitors;

• keep accurate books and records; and

• perform due diligence on our third party partners.

Compliance Training

PENTAX Medical has established a robust compliance training program to ensure that all its employees and business partners understand and adhere to all legal and ethical requirements. PENTAX Medical's compliance training program is developed to provide ongoing compliance training to employees, managers and business partners.

The compliance training program covers a range of topics, including anti-bribery laws and regulations, harassment, data privacy, engagement with healthcare professionals and healthcare organizations.

The program provides in‑depth knowledge on the risks of non-compliance and the consequences of violating relevant regulations or codes of conduct. The training is delivered through a variety of methods, including classroom sessions, online modules, and webinars.

PENTAX Medical offers role‑based training to ensure that employees receive the necessary training specific to their job functions. The training program is regularly updated to ensure that the training material aligns with PENTAX Medical's evolving policies and regulations.

PENTAX Medical's compliance training program is designed to complement other compliance measures and internal controls, reinforcing the importance of compliance at every level of the organization. The program also offers a feedback mechanism for employees to express their concerns or raise questions to their managers or compliance officers directly. PENTAX Medical's compliance training program is a key component of the company's business ethics and regulatory compliance framework. Through its compliance training program, PENTAX Medical is committed to maintaining the highest standards of business integrity and compliance.

Risk Management

PENTAX Medical conducts regular risk assessments to ensure that its compliance program takes into account the company's evolving business environment, regulatory landscape, and risk exposure. These assessments help identify and prioritize potential compliance risks across all operations, enabling the company to develop targeted measures and deploy resources to address them effectively. Risk assessments are conducted systematically and serve as a key element in updating policies, procedures, and training to better mitigate risks. By continuously adapting the compliance program to real‑world challenges, PENTAX Medical reinforces its commitment to proactive and effective compliance management.

Third Party Management

PENTAX Medical, a subsidiary of HOYA Corporation, maintains a risk‑based third‑party compliance program led by Global Compliance function and overseen by the Chief Compliance Officer, with regular reporting to the HOYA Board of Directors. All PENTAX Medical distributors are subject to risk‑based due diligence prior to engagement, including screening for bribery and corruption risk, sanctions exposure, and export control laws and regulations. In addition, all distributor agreements include contractual safeguards such as clauses for anti-bribery and anti-corruption, export, and termination, as well as audit rights. Higher-risk partners undergo enhanced due diligence screening.

Following onboarding, all PENTAX Medical distributors are required to complete compliance training and annual certifications. PENTAX Medical’s third party compliance program includes ongoing monitoring, automated re-screening against global watchlists, and audits for cause. Allegations of misconduct are addressed through formal intake, investigation, and remediation procedures. Any allegations of wrongdoing can be reported directly to PENTAX Medical’s compliance team or anonymously through its hotline that is managed by an independent provider.

This structured approach reflects PENTAX Medical’s commitment to responsible distributor oversight, ensuring third parties operate in line with our ethical standards and regulatory obligations across all markets.

Monitoring & Audit

PENTAX Medical actively monitors the implementation and effectiveness of its compliance measures through periodic audits and other activities to help verify whether compliance requirements are understood and followed at all levels of the organization. These monitoring efforts provide valuable insights and enable improvements and adjustments to the compliance program. PENTAX Medical believes that monitoring and auditing are key tools in fostering a culture of accountability and continuous improvement.

Data Privacy

PENTAX Medical is committed to protecting and responsible handling of personal data of its employees, business partners, and customers. Data privacy is a legal requirement but also a fundamental element of trust and corporate responsibility. Our compliance program includes comprehensive data privacy measures to ensure that personal data is collected, stored, used, processed, shared and transferred in accordance with applicable data privacy laws and in a manner that keeps that information safe. By fostering a company culture of privacy awareness, we aim to uphold individual rights and support responsible innovation in healthcare.

Data Security

Data security is essential to safeguarding the integrity and confidentiality of information in today’s digital environment. PENTAX Medical implements robust technical and organizational measures to protect sensitive data against unauthorized access, loss, or misuse. Ensuring data security is vital for maintaining trust, business continuity, and regulatory compliance. As part of our compliance program, we continuously evaluate and improve our data protection strategies to respond to emerging threats and technological developments.