Corporate Responsibility

California Transparency in Supply Chains Act of 2010

The California Transparency in Supply Chains Act of 2010 is intended to provide public information from manufacturers and retailers regarding their efforts to prevent human trafficking and slavery, which will allow businesses and consumers to make more informed decisions regarding the products they choose to purchase and the companies with whom they choose to conduct business. PENTAX Medical Company, an affiliate of HOYA Corporation, is committed to conducting business only with suppliers who adhere to the highest ethical standards and comply with laws and regulations applicable to their business, including laws relating to human trafficking and slavery.

HOYA Business Conduct Guidelines

HOYA Business Conduct Guidelines outlines the company's expectations for business conduct and practices and includes provisions on conducting business with high ethical and legal standards.

Supplier Assessments and Qualification

All suppliers are expected to comply with the HOYA Business Conduct Guidelines.   Prior to engagement of a supplier, PENTAX Medical Company evaluates the supplier's ability to meet PENTAX Medical Company's requirements, which may include supplier questionnaires and audits of supplier facilities. PENTAX Medical Company's expectations for compliance with ethical and quality standards are communicated to all potential suppliers.

Supplier Audits

PENTAX Medical Company periodically audits suppliers to confirm compliance with supplier performance and quality standards. Audits are performed by PENTAX Medical Company or third parties contracted by PENTAX Medical Company.

Supplier Agreements

PENTAX Medical Company has signed statements of compliance and purchase order terms and conditions with all of its suppliers. These statements include agreements to comply with all Local, State and Federal Laws and Regulations which may apply.

Employee Training and Compliance

All PENTAX Medical Company employees, including employees responsible for supply chain management, are required to comply with the HOYA Business Conduct Guidelines. All PENTAX Medical Company employees participate in annual training on the HOYA Business Conduct Guidelines, which includes training on ethical decision making and upholding laws and regulations, to ensure understanding and compliance with the requirements of the guidelines. To promote compliance with the HOYA Business Conduct Guidelines, PENTAX Medical Company maintains a compliance program that conducts regular audits of the requirements under the guidelines, investigates potential violations of the guidelines and takes disciplinary action when necessary.