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STAAR Surgical Company

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FY2020 Annual Report · STAAR Surgical Company
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form 10-K

(Mark One)
☑

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the fiscal year ended January 1, 2021

Or

☐

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from          to
Commission file number: 0-11634

STAAR SURGICAL COMPANY

(Exact name of registrant as specified in its charter)

Delaware
(State or other jurisdiction of incorporation or organization)
25651 Atlantic Ocean Drive
Lake Forest, California
(Address of Principal Executive Offices)

95-3797439
(I.R.S. Employer Identification No.)

92630
(Zip Code)

(626) 303-7902
(Registrant’s telephone number, including area code)
Securities registered pursuant to Section 12(b) of the Act:

Title of each class
Common

Trading Symbol(s)
STAA

Name of each exchange on which registered
NASDAQ

Securities registered pursuant to Section 12(g) of the Act:  None

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.  Yes ☑      No ☐

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act.  Yes ☐      No ☑

Indicate  by  check  mark  whether  the  registrant  (1)  has  filed  all  reports  required  to  be  filed  by  Section  13  or  15(d)  of  the  Securities  Exchange  Act  of  1934  during  the
preceding  12  months  (or  for  such  shorter  period  that  the  registrant  was  required  to  file  such  reports),  and  (2)  has  been  subject  to  such  filing  requirements  for  the  past
90 days. Yes ☑     No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of Regulation S-T

(§ 232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).    Yes ☑     No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, a smaller reporting company, or an emerging growth
company. See the definitions of “large accelerated filer,” “accelerated filer,” “smaller reporting company,” and “emerging growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer
Non-accelerated filer
Emerging growth company

☑  
☐  
☐  

Accelerated filer
Smaller reporting company

☐
☐

If  an  emerging  growth  company,  indicate  by  check  mark  if  the  registrant  has  elected  not  to  use  the  extended  transition  period  for  complying  with  any  new  or  revised

financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.  ☐

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control over financial

reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued its audit report.  ☑

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).  Yes ☐     No ☑

The aggregate market value of the voting and non-voting common equity held by non-affiliates of the registrant as of July 3, 2020, the last business day of the registrant’s

most recently completed second fiscal quarter, was approximately $2,821,465,125 based on the closing price per share of $61.62 of the registrant’s Common Stock on that date.

The registrant has 46,564,866 shares of common stock, par value $0.01 per share, issued and outstanding as of February 19, 2021.

DOCUMENTS INCORPORATED BY REFERENCE

Portions  of  the  registrant’s  definitive  proxy  statement  relating  to  its  2021  annual  meeting  of  stockholders,  which  will  be  filed  with  the  Securities  and  Exchange

Commission pursuant to Regulation 14A within 120 days of the close of the registrant’s last fiscal year, are incorporated by reference into Part III of this report.

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY

TABLE OF CONTENTS

PART I
ITEM 1.
ITEM 1A.
ITEM 1B.
ITEM 2.
ITEM 3.
ITEM 4.
PART II
ITEM 5.
ITEM 6.
ITEM 7.
ITEM 7A.
ITEM 8.
ITEM 9.
ITEM 9A.
ITEM 9B.
PART III
ITEM 10.
ITEM 11.
ITEM 12.
ITEM 13.
ITEM 14.
PART IV
ITEM 15.
ITEM 16.
SIGNATURES

Business
Risk Factors
Unresolved Staff Comments
Properties
Legal Proceedings
Mine Safety Disclosures

Market for Registrant’s Comment Equity, Related Stockholder Matters, and Issuer Purchases of Equity Securities
Selected Financial Data
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Quantitative and Qualitative Disclosures About Market Risk
Financial Statements and Supplementary Data
Changes in and Disagreements with Accountants on Accounting and Financial Disclosure
Controls and Procedures
Other Information

Directors, Executive Officers, and Corporate Governance
Executive Compensation
Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters
Certain Relationships and Related Transactions, and Director Independence
Principal Accounting Fees and Services

Exhibits and Financial Statement Schedules
Form 10-K Summary

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1

 
 
 
 
 
 
 
 
 
 
 
 
 
PART I

This Annual Report on Form 10-K contains statements that constitute “forward-looking statements” within the meaning of Section 27A of the Securities Act
of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended, and the Private Securities Litigation Reform Act of 1995, and is subject
to the safe harbor created therein. These statements include comments regarding the intent, belief or current expectations of the Company and its management.
Readers can recognize forward-looking statements by the use of words like “anticipate,” “estimate,” “expect,” “intend,” “plan,” “believe,” “will,” “should,”
“forecast” and similar expressions in connection with any discussion of future operating or financial performance. STAAR Surgical Company cautions investors
and prospective investors that any such forward-looking statements are not guarantees of future performance and involve risks and uncertainties, and that actual
results  may  differ  materially  from  those  projected  in  the  forward-looking  statements.  We  caution  you  not  to  place  undue  reliance  on  these  forward-looking
statements and to note they speak only as of the date hereof. Factors that could cause actual results to differ materially from those set forth in the forward-looking
statements  are  included  in  the  risk  factors  set  forth  in  Item  1A,  “Risk  Factors.”  We  disclaim  any  intention  or  obligation  to  update  or  revise  any  financial
projections or forward-looking statements due to new information or other events.

ITEM 1.

Business

STAAR Surgical Company designs, develops, manufactures, and sells implantable lenses for the eye and delivery systems used to deliver the lenses into the
eye. We are the leading manufacturer of lenses used worldwide in corrective or “refractive” surgery. We have been dedicated solely to ophthalmic surgery for over
30 years.  Our goal is to position our refractive lenses throughout the world as primary and premium solutions for patients seeking visual freedom from wearing
eyeglasses  or  contact  lenses  while  achieving  excellent  visual  acuity  through  refractive  vision  correction.  We  also  make  lenses  for  use  in  surgery  that  treats
cataracts.  Unless the context indicates otherwise, “we,” “us,” the “Company,” and “STAAR” refer to STAAR Surgical Company and its consolidated subsidiaries.

A glossary explaining many of the technical terms used in this report begins on page 15. The reader may also find it helpful to refer to the discussion of the

structure and function of the human eye that begins on page 7.

Operations

STAAR has significant operations globally. Activities outside the United States (U.S.) accounted for 96% of our total sales in fiscal year 2020, primarily due
to the pacing of product approvals and commercialization that tend to occur first outside the United States. STAAR sells its products in more than 75 countries,
with  direct  distribution  (i.e.,  via  STAAR  representatives)  in  Japan,  Germany,  Spain,  the  U.S.,  Canada,  the  U.K.  and  Singapore,  with  a  combination  of  direct
distribution  and  independent  distribution  (i.e.,  via  distributors  and  STAAR  representatives)  in  China,  Korea,  India,  France,  Benelux,  and  Italy,  and  with
independent distribution in the remainder of the countries where we sell.

STAAR maintains operational and administrative facilities in the U.S., Switzerland, and Japan. Its current global operations are as follows:

•

•

•

United  States. STAAR  operates  its  global  administrative  offices  and  principal  manufacturing  facility  in  Monrovia,  California.  The  Monrovia
manufacturing facility primarily makes the Visian implantable Collamer lens product family, including the EVO Visian ICL (collectively referred to as
ICLs), preloaded silicone intraocular lenses (IOLs), and injector systems. We manufacture the raw material for Collamer lenses in our facility in Aliso
Viejo, California.  STAAR also operates a Technology Center housing its Research & Development team and labs in Tustin, California.  STAAR’s
facility  in  Lake  Forest,  California  serves  as  our  corporate  headquarters.   It  contains  executive  offices  and  operational  facilities  we expect  to  use  for
future manufacturing of STAAR’s Presbyopia lenses, EVO Viva.

Switzerland. STAAR operates an administrative, distribution and operational facility in Brugg, Switzerland under its wholly owned subsidiary, STAAR
Surgical AG. We are in the process of expanding our manufacturing capabilities for STAAR’s ICL products in our Nidau, Switzerland facility.

Japan.  STAAR  operates  administrative  and  distribution  facilities  in  Japan  under  its  wholly  owned  subsidiary,  STAAR  Japan  Inc.  STAAR  Japan’s
administrative  facility is in Shin-Urayasu and its distribution facility  is in Ichikawa City. STAAR performs final packaging of its silicone preloaded
IOL injectors and final inspection of its acrylic preloaded IOL injectors at the Ichikawa City facility.

2

 
 
 
 
Financial Information about Segments and Geographic Areas

100% of the Company’s sales are generated from the ophthalmic surgical product segment and, therefore, the Company operates as one operating segment
for  financial  reporting  purposes.  The  Company’s  principal  products  are  ICLs  used  in  refractive  surgery  and  IOLs  used  in  cataract  surgery.  See  Note  17  to  the
Consolidated Financial Statements for financial information about product lines and operations in geographic areas.

Principal Products

In designing our products, we seek to delight patients and surgeons by:

•

•

•

Improving patient outcomes;

Minimizing patient risk; and

Simplifying ophthalmic procedures and post-operative care for the surgeon and the patient.

EVO Visian  ICL, EVO Viva  ICL, and Visian  ICL.  Refractive  surgery  corrects  visual  disorders  that  eyeglasses  or contact  lenses  have traditionally  treated
(myopia,  hyperopia,  astigmatism,  and  presbyopia).  The  field  of  refractive  surgery  includes  both  lens-based  procedures,  using  products  like  our  ICL,  and  laser-
based  procedures  like  LASIK.  The  ICL  product  line  treats  a  wide  range  of  refractive  errors  within  commonly  known  vision  disorders  such  as  myopia
(nearsightedness), hyperopia (farsightedness), astigmatism and presbyopia.

The ICL folds for minimally invasive implantation behind the iris and in front of the natural crystalline lens, using techniques similar to those used to implant
an IOL during cataract surgery, except that the natural lens remains intact in the eye. Lenses of this type are generically called “phakic IOLs” or “phakic implants”
because they work along with the patient’s natural lens, or phakos, rather than replacing it. The surgeon typically implants the ICL using topical anesthesia on an
outpatient basis. The patient usually experiences immediate vision improvement within a day.

Our ICL is the only posterior chamber phakic IOL (PIOL) approved by the Food and Drug Administration (FDA) for marketing and sale in the U.S., and we
believe it is the world’s largest selling phakic IOL. Our biocompatible Collamer material belongs to a family of materials known as collagen copolymers. Collagen
copolymers are compounds formed by joining molecules of collagen derived from biological sources with synthetic monomer molecules. The proprietary Collamer
material is exclusive to us. We believe that the biocompatibility of the Collamer material used for the ICL product line is a significant factor in the ability to place
this lens safely in the posterior chamber of the eye.

The ICL has been implanted into more than 1,000,000 eyes worldwide. STAAR began selling the ICL for myopia for use outside the U.S. in 1997. U.S. sales
commenced in 2006. In September 2011, STAAR launched the ICL with CentraFLOW technology, which uses a port in the center of the ICL optic in markets
outside the U.S. The port is of a size intended to optimize the flow of fluid within the eye without affecting the quality of vision.  The central port also eliminates
the need for the surgeon to perform a YAG peripheral iridotomy procedure days before the ICL implant. The CentraFLOW technology makes the visual outcomes
of the ICL available through a simpler and more comfortable surgical implantation experience. We are authorized to sell the ICL with CentraFLOW technology in
the  following  ex-U.S.  regions:    the  approximately  31  countries  that  require  the  European  Union  CE  Mark,  China,  Canada,  Korea,  Japan,  India,  Argentina,
Singapore,  and  several  countries  in  the  Middle  East.  In  December  2015,  we  received  the  CE  Mark  for  EVO+,  an  ICL  with  CentraFLOW  technology  and  an
expanded  optical  zone  of  up  to  20%.  We  believe  the  expanded  optical  zone  may  further  improve  certain  patients’  visual  experience,  thus  making  the  ICL
increasingly  desirable  for  both  patients  and  ophthalmic  surgeons.  We  are  authorized  to  sell  the  EVO+  in  the  following  ex-U.S.  regions:    the  approximately  31
countries that require the European Union CE Mark, Korea, Japan, India, Canada, Hong Kong, Turkey, and several countries in the Middle East.  The Hyperopic
ICL, which treats far-sightedness, is sold primarily in countries that require the European Union CE Mark. In July 2020, we received the CE Mark for EVO Viva, a
presbyopia-correcting ICL with an aspheric EDOF optic. We commenced a limited launch of the EVO Viva lens in Spain, Belgium and Germany. The EVO Viva
lens  adds  near  and  intermediate  vision  correction  for  patients  with  presbyopia.  We  believe  the  EVO  Viva lens  will  assist  certain  patients  with  eliminating  the
burdens of reading glasses or frequent replacement contact lenses. Typically, ICL surgery is an elective procedure paid for or financed by the patient.

Globally,  the  ICL  is  available  for  myopia  and  hyperopia  and  is  available  in  multiple  models,  powers  and  lengths  totaling  hundreds  of  different  types  of
inventoried lenses. This requires us to carry a significant amount of inventory to meet customer preference for rapid delivery.  The Toric ICL (TICL), which also
corrects for astigmatism, is

3

 
 
 
available for myopia in the same powers and lengths and carries additional parameters of cylinder and axis. The EVO Viva lens is available for myopia in the same
powers and lengths and carries additional parameters relating to presbyopia correction.  

According to Market Scope, LLC a publisher of ophthalmic industry data, approximately 3.6 million refractive procedures, primarily laser vision procedures,
were  performed  worldwide  in  2020.  The  incidence  of  myopia  is  growing  globally,  with  high  myopia  becoming  more  common  according  to  recently  published
articles, affecting nearly 5 billion and 1 billion people, respectively, by 2050 (Global Prevalence of Myopia and High Myopia and Temporal Trends from 2000
through 2050, Ophthalmology,  Vol. 123, No. 5, May 2016;  Global trends in myopia  management  attitudes  and strategies  in clinical  practice,  Contact Lens and
anterior Eye, Vol. 39, 2016).  We believe this will result in a significantly increased number of patients seeking refractive procedures. We believe that over the past
decade negative publicity  regarding LASIK has reduced patient  interest  in the LASIK procedure.  The ICL is a lens-based refractive  procedure (unlike LASIK)
with over 1,000,000 ICLs implanted to date. Surgeons have published over 100 peer-reviewed articles with clinical data regarding the safety, effectiveness, and
visual quality of the ICL. We believe the ICL provides a safe and effective solution for the growing number of myopic patients who will seek visual freedom from
eyeglasses and contact lenses.

We plan to continue to develop and launch innovative products to support clinical needs and to address the increasing demands of our customers. As part of
our sales and marketing efforts, we attend and participate in major ophthalmic conventions around the world and invest in market development, practice support,
healthcare  professional  training  and  patient  outreach.  We  have  started  working  more  closely  with  leading  refractive  clinics  in  the  area  of  training,  product
awareness and practice development. Our marketing programs seek to position the ICL as a premium and primary option for appropriate patients at the clinic and
via digital and social media.

In September 2018, the FDA granted approval of our PMA Supplement for the Visian Toric ICL for the correction of myopia with astigmatism for marketing
and sale in the United States.  In August 2019, the FDA notified us that it had determined that STAAR had provided sufficient data to support initiation of a human
clinical  study  in  the  United  States  of  the  EVO/EVO+  VISIAN®  Implantable  Collamer®  Lens  for  Myopia,  and  EVO/EVO+  VISIAN®  Toric  Implantable
Collamer® Lens for Myopia with Astigmatism. In November 2020, we completed enrollment for the primary study analysis cohort of 300 subjects in our U.S.
EVO clinical trial. These subjects have been implanted with the EVO lens and will be followed pursuant to the clinical trial protocol.     

Sales of ICLs (including EVO+ and TICLs) accounted for approximately 87% of our total sales in fiscal 2020, 86% of our total sales in fiscal 2019 and 82%

of our total sales in fiscal 2018.

Other Products

Intraocular Lenses (IOLs). We sell in parts of Asia and parts of Europe a “Preloaded Injector” with an acrylic IOL packaged and shipped in a pre-sterilized,
disposable  injector  ready  for  use  in  cataract  surgery.  We  also  sell  a  silicone  lens-based  Preloaded  Injector  in  Japan.  We  believe  the  Preloaded  Injector  offers
surgeons improved convenience and reliability. The acrylic lens-based Preloaded Injector uses a lens supplied by a third party. The supplier also assembles and
sells the acrylic Preloaded Injector under its own brand, using injector parts purchased from us.

The  silicone  lens-based  Preloaded  Injector  uses  a  lens  produced  and  marketed  by  STAAR. This  line  of  foldable  IOLs  is  manufactured  from  silicone  in  a
three-piece  design  with  Polyimide  loop  haptics  attached  to  the  optic,  they  are  largely  aspheric  IOLs  that  use  optical  designs  that  produce  a  clearer  image  than
traditional spherical lenses, especially in low light.

In most of the countries where STAAR sells IOLs, government agencies reimburse most or all of the cost of cataract surgery and IOLs. Government agencies
continue to reduce the reimbursement rates for cataract surgery and IOLs. In response, we continue to assess and rationalize our low margin IOLs. For example,
during the fourth  quarter  of 2019, we decided  to phase out our nanoFLEX IOL, a single  piece aspheric  IOL and to only sell our silicone  lens-based  Preloaded
Injector in Japan.

Sales of IOLs accounted for approximately 8% of our total sales in fiscal 2020, 11% of our total sales in fiscal 2019 and 13% of our total sales in fiscal 2018.

Other Surgical Products.  We sell injector parts to our acrylic lens supplier for their preloaded acrylic IOL that they sell under their own brand. Also, we sell
other related instruments and devices that we manufacture, or that are manufactured by others. Generally, these products have lower overall gross profit margins
relative to our ICLs and

4

IOLs. Sales of other surgical products accounted for approximately 5% of our total sales in fiscal 2020, 3% of our total sales in fiscal 2019 and 5% of our total
sales in fiscal 2018.

Sources and Availability of Raw Materials

STAAR uses a wide range of raw materials in the production of its products. STAAR purchases most of the raw materials and components from external
suppliers. Some of our raw materials are single-sourced due to regulatory constraints, cost effectiveness, availability, quality, and vendor reliability issues. Many of
our  components  are  standard  parts  or  materials  and  are  available  from  a  variety  of  sources.  We  do  not  typically  pursue  regulatory  and  quality  certification  of
multiple sources of supply.

Patents, Trademarks, and Licenses

We  strive  to  protect  our  investment  in  the  research,  development,  manufacturing,  and  marketing  of  our  products  through  the  use  of  patents,  trademarks,
licenses,  trade  secrets,  and  copyrights.  We  own  or  have  rights  to  a  number  of  patents,  licenses,  trademarks,  copyrights,  trade  secrets,  know-how  and  other
intellectual property related and important to our business. As of January 1, 2021, we owned approximately 80 United States and foreign patents and had 26 patent
applications pending. We rely more on trade secrets than patents and believe that no particular patent is so important that its loss or expiration would materially
adversely affect our operations as a whole.

Our intellectual property generally relates to the design, production, and manufacture of the Collamer lens material, ICLs, IOLs, and lens delivery systems for
folding  intraocular  lenses  (injectors  and  cartridges,  both  stand-alone  and  preloaded)  used  with  ICLs  and  IOLs.  We  believe  it  would  require  extensive  time  and
effort for a competitor to duplicate our intellectual property and processes to develop a product with comparable capabilities to our ICL product lines.

Worldwide, we sell all of our major products under trademarks we consider to be important to our business. STAAR®, EVO Visian ICL™, EVO Viva™,
Evolution  in  Visual  Freedom®,  Visian®,  Collamer®,  CentraFLOW®,  AquaPORT®,  nanoFLEX®  nanoPOINT®  and  Afinity®  are  trademarks  or  registered
trademarks of STAAR in the U.S., the European Union, or other countries. The scope and duration of trademark protection varies widely throughout the world. In
some countries, trademark protection continues only as long as the mark is used. Other countries require registration of trademarks and the payment of registration
fees. Trademark registrations are generally for fixed but renewable terms.

We  protect  our  proprietary  technology,  in  part,  through  confidentiality  and  nondisclosure  agreements  with  employees,  consultants,  and  other  parties.  Our
confidentiality  agreements  with  employees  and  consultants  generally  contain  standard  provisions  requiring  those  individuals  to  assign  to  STAAR,  without
additional consideration, inventions conceived or reduced to practice by them while employed or retained by STAAR, subject to customary exceptions. We cannot
provide any assurance that employees and consultants will abide by the confidentiality or other terms of their agreements. Despite measures taken to protect our
intellectual property, unauthorized parties may copy aspects of our products or obtain and use information that we regard as proprietary.

Seasonality

While certain individual markets may be impacted by seasonal trends on a quarterly basis, in the aggregate, seasonality does not materially affect our sales.

Working Capital Requirements

There are no special inventory requirements or credit terms extended to customers that have a material adverse effect on our working capital.

Distribution and Customers

We market our products to a variety of health care providers, including ophthalmic surgeons, vision centers, surgical centers, hospitals, government facilities,

and distributors. The primary user of our products is an ophthalmologist.

We sell our products directly through our own sales representatives in Japan, Germany, Spain, the U.S., Canada, the U.K. and Singapore. We sell through a
combination of our own representatives and independent distributors in China, Korea, India, France, Benelux, and Italy. We sell through independent distributors
in other countries.  Our products are sold in more than 75 countries worldwide. We maintain a global marketing team, as well as regional marketing personnel to
support the promotion and sale of our products. The global marketing

5

department supports selling efforts by developing and providing promotional materials, speakers’ programs, digital and social media sites, participation in trade
shows  and  technical  presentations.  Where  we  distribute  products  directly,  we  rely  on  local  sales  representatives  to  help  generate  sales  by  promoting  and
demonstrating our products with physicians. In the U.S., we also rely on independent sales representatives to sell our products under the supervision of directly
employed sales managers. Our clinical affairs personnel provide training and educational courses globally.

One customer, Shanghai Lansheng, our China distributor who sells in to China and Hong Kong, accounted for approximately 44% of our consolidated net

sales during fiscal 2020.  Net sales to Shanghai Lansheng during each of the last three fiscal years were as follows:

Fiscal Year
2020
2019
2018

Backlog

Net Sales to Shanghai Lansheng

Net Sales
($, in thousands)

  $
  $
  $

71,692   
64,820   
46,070   

Net Sales as Percentage of
Consolidated Net Sales

43.9%
43.2%
37.2%

The dollar amount of STAAR’s backlogged orders is not material in relation to total annual sales. We generally keep sufficient inventory on hand to ship

product immediately or shortly after receipt of an order. 

Government Contracts

No material portion of our business is subject to renegotiation of profits or termination of any particular contract or subcontract at the election of the U.S.

Government.

Competition

Competition in the ophthalmic surgical product market is intense and is primarily driven by technological innovation and the regulatory approval required to
commercialize products in the key markets around the world. The development of new or improved products may make existing products less attractive, reduce
them to commodity status or even make them obsolete. To remain competitive, companies such as STAAR must devote continued efforts and significant financial
resources to enhance their existing products and to develop new products.

In  the  refractive  market,  our  ICL  technology  competes  with  other  elective  surgical  procedures  such  as  laser  vision  correction  (e.g.,  LASIK)  for  those
consumers who are looking for an alternative to eyeglasses or contact lenses to correct their vision. In the cataract surgery market, our IOLs primarily compete
based on our technology’s quality and value.

We believe our primary competition in selling the ICL to patients seeking surgery to correct refractive conditions lies not in similar products to the ICL, but
in laser surgical procedures.  Alcon (formerly a part of Novartis), Johnson & Johnson (formerly Advanced Medical Optics or AMO), Bausch Health Companies
(formerly Valeant, Bausch & Lomb or B+L), and Carl Zeiss Meditec AG, all market lasers for corneal refractive surgery and promote their sales worldwide.  

Phakic implants that compete with the ICL are also available in the marketplace. The two principal types of phakic IOLs are (1) posterior chamber designs
like  the  ICL,  and  (2)  iris  clip  anterior  chamber  PIOLs  like  the  Artisan®  and  Artiflex®  lenses  made  by  Ophtec.  We  believe  the  ICL  has  compelling  clinical
advantages over the other lenses, which are reflected in our strong market share of the global phakic IOL market. The ICL is the only foldable, minimally invasive
PIOL approved for sale in the U.S. In addition, competitors from Asia are beginning to appear in the market with their low-cost version of a posterior chamber
implantable contact lens, increasing the level of competition.

The global cataract IOL market is highly concentrated, with the top five competitors (Alcon, Johnson & Johnson, Hoya, Bausch Health Companies and Carl

Zeiss Meditec) combined accounting for approximately 69% of total market revenue, according to a 2020 report by Market Scope.

6

 
 
 
   
 
 
 
 
 
The Human Eye

The following discussion provides background information on the structure, function, and some of the disorders of the human eye to enhance the reader’s
understanding of our products described in this report. The human eye is a specialized sensory organ capable of receiving visual images and transmitting them to
the visual center in the brain. The eye has an anterior segment and a posterior segment that are separated by the natural crystalline lens.

The anterior segment consists of the cornea, the iris and ciliary body and the trabecular meshwork. It is filled with a water-based fluid called aqueous humor
and is divided, by the iris, into an anterior chamber and a posterior chamber. The cornea is a clear lens at the front of the eye through which light first passes and is
focused towards the back of the eye. The interior surface of the cornea is lined with a single layer of flat, tile-like endothelial cells, whose function is to maintain
the transparency of the cornea. The iris is a pigmented muscular curtain located behind the cornea which opens and closes to regulate the amount of light entering
the eye through the pupil, an opening at the center of the iris. The crystalline lens, located behind the iris, completes the focusing of light and can change shape to
focus objects at different distances onto the retina, located in the back of the eye. The trabecular meshwork, a drainage channel located between the iris and the
surrounding white portion of the eye, maintains a normal pressure in the anterior chamber of the eye by draining excess aqueous humor.

The posterior segment of the eye that is behind the natural lens is filled with a jelly-like material called the vitreous humor. The retina is a layer of nerve
tissue in the back of the eye consisting of millions of light receptors called rods and cones, which receive the light image and transmit it to the brain via the optic
nerve.

Common visual disorders, disease or trauma can affect the eye. One of the most prevalent ocular disorders is cataracts. Cataract formation is generally an

age-related disorder that involves the hardening and loss of transparency of the natural crystalline lens, impairing visual acuity.

Refractive disorders, which generally are not age-related, include myopia, hyperopia, and astigmatism. A normal, well-functioning eye receives images of
objects at varying distances from the eye and focuses the images on the retina. Refractive errors occur when the eye’s natural optical system does not properly
focus  an  image  on  the  retina.  Myopia,  also  known  as  nearsightedness,  occurs  when  the  eye’s  lens  focuses  images  in  front  of  the  retina.  Hyperopia,  or
farsightedness,  occurs  when  the  eye’s  lens  focuses  images  behind  the  plane  of  the  retina.  Individuals  with  myopia  or  hyperopia  may  also  have  astigmatism.
Astigmatism is due to an irregular curvature of the cornea or defects in the natural lens that causes light to not focus at a single depth in the eye resulting in blurred
vision. Presbyopia is an age-related refractive disorder that limits a person’s ability to see in the near and middle-distance range as the natural crystalline lens loses
its elasticity, reducing the eye’s ability to accommodate or adjust its focus for varying distances.

Regulatory Matters

Nearly all countries where we sell our products have regulations requiring premarket clearance or approval of medical devices by governmental or regulatory
authorities.  Various  federal,  state,  local  and  foreign  laws  also  apply  to  our  operations,  including,  among  other  things,  working  conditions,  laboratory,  clinical,
advertising and promotions, and design and manufacturing practices, and the use and disposal of hazardous or potentially hazardous substances.

The  requirements  for  clearance  or  approval  to  market  medical  products  vary  widely  by  country.  The  requirements  range  from  minimal  requirements  to
rigorous requirements comparable to those established by the FDA. Obtaining clearance or approval to distribute medical products is complex, costly, and time-
consuming  in  virtually  all  the  major  markets  where  we  sell  medical  devices.  We  cannot  give  any  assurance  that  any  new  medical  devices  we  develop  will  be
cleared  or  approved  in  any  country  where  we  propose  to  sell  our  medical  devices  or,  if  approved,  whether  such  approvals  will  be  granted  in  a  timely  or  cost-
effective manner, be as broad in scope as we seek, or be conditioned on post-market study requirements or restrictive labeling. We also cannot give any assurance
that if our medical  devices are approved for sale in a country, subsequent action will not be taken by the responsible regulatory authorities  in the country with
respect  to  our  medical  devices  that  might  affect  our  ability  to  maintain  the  required  approvals  in  the  country  or  to  continue  to  sell  our  medical  devices  in  the
country.  The regulatory requirements in our most important current markets, China, Europe, Japan, Korea and the U.S., are discussed below.

Regulatory Requirements in the United States.

Under the United States Federal Food, Drug & Cosmetic Act, as amended (the Act), the FDA has the authority to regulate, among other things, the design,

development, manufacturing, preclinical and clinical testing, labeling,

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product safety, marketing, sales, distribution, premarket clearance  and approval, recordkeeping, reporting, advertising, promotion, post-market surveillance, and
import and export of medical devices.

Most of our products are classified as medical devices intended for human use within the meaning of the Act and, therefore, are subject to FDA regulation.

Each medical device we seek to commercially distribute in the United States must first receive clearance to market under a notification submitted pursuant to
Section 510(k) of the Act, known as the 510(k) premarket notification, or premarket approval (PMA) from the FDA, unless specifically exempted by the agency or
subject  to  another  form  of  FDA  premarket  review.  The  FDA  classifies  all  medical  devices  into  one  of  three  classes.  The  FDA  establishes  procedures  for
compliance based upon the device’s classification as Class I (general controls, such as establishment registration and device listing with FDA, labeling and record-
keeping  requirements),  Class  II  (performance  standards  in  addition  to  general  controls)  or  Class  III  (premarket  approval  (PMA)  required  before  commercial
marketing). Devices deemed to pose lower risk are categorized as either Class I (low risk) or II (moderate risk). Manufacturers of Class II devices are generally
required to submit to the FDA a 510(k) premarket notification requesting clearance of the device for commercial distribution in the United States. Most low risk
(Class  I)  devices  and  some  Class  II  devices  are  exempt  from  this  requirement.  The  FDA  deems  Class  III  devices  to  pose  the  greatest  risk  and  are  the  most
extensively regulated. These devices include life-supporting, life sustaining, or implantable devices, or devices deemed not substantially equivalent to a previously
510(k) cleared device. The effect of assigning a device to Class III is to require each manufacturer to submit to the FDA a PMA that includes information on the
safety and effectiveness of the device. The FDA reviews device applications and notifications through its Office of Device Evaluation (ODE).

510(k) Clearance. Our  lens  injector  systems  are  Class  I  devices  subject  to  the  510(k)  premarket  review  and  clearance  process.  A  medical  device  that  is
substantially equivalent to either a previously-cleared medical device or a device that was in commercial distribution before May 28, 1976 for which the FDA has
not yet called for the submission of a PMA, or is a device that has been reclassified from Class III to either Class II or I may be eligible for the FDA’s 510(k)
premarket notification process. FDA clearance under Section 510(k) of the Act does not imply that the safety, reliability, and effectiveness of the medical device
has been approved or validated by the FDA. The review period and FDA determination as to substantial equivalence generally takes from three to twelve months
from the date the application is submitted and filed. However, the process may take significantly longer, and clearance is never assured. Although many 510(k)
premarket notifications are cleared without clinical data, in some cases, the FDA requires significant clinical data to support substantial equivalence. In reviewing a
premarket notification, the FDA may request additional information including clinical data, which may significantly prolong the review process.

After a device receives 510(k) clearance, any modification that could significantly affect its safety or effectiveness, or that would constitute a major change in
its  intended  use,  will  require  a  new  510(k)  clearance  or  could  require  premarket  approval.  The  FDA  requires  each  manufacturer  to  make  its  own  initial
determination as to whether a change meets this threshold. However, the FDA can review any such decision and can disagree with a manufacturer’s determination.
If the FDA disagrees with a manufacturer’s  determination, the FDA can require the manufacturer to cease marketing or recall the modified device until 510(k)
clearance or a PMA is obtained.

Premarket Approval.  Our  ICLs  and  IOLs  are  Class  III  devices  subject  to  the  PMA  approval  process  and  not  510(k)  clearance.    The  more  rigorous  PMA
process requires us to demonstrate that a new medical device is safe and effective for its intended use. The FDA may require that a PMA be supported by, among
other  things,  extensive  technical,  pre-clinical,  clinical  testing,  manufacturing,  and  labeling  data  to  demonstrate  to  the  FDA’s  satisfaction,  the  safety  and
effectiveness of the device.

After a PMA application  is submitted and filed, the FDA begins an in-depth review of the submitted information, which typically takes between one and
three  years,  but  may  take  significantly  longer.  During  the  review  period,  the  FDA  may  request  additional  information  or  clarification  of  information  already
provided. In addition to its own review, the FDA may organize an independent advisory panel of experts to review the PMA whenever a device is the first of its
kind or the FDA otherwise determines panel review is warranted. The FDA holds panels on a regular basis, but the need to schedule panel review usually adds
some weeks or months to the review process. In addition, the FDA will conduct a pre-approval inspection of the manufacturing facility to ensure compliance with
Quality System Regulation (QSR) which imposes elaborate design, development, testing, control, validation, documentation, complaint handling, supplier control,
and other quality assurance procedures in the design and manufacturing process. The FDA may approve a PMA application with post-approval conditions intended
to ensure the safety and effectiveness of the device including, among other things, restrictions on labeling, promotion, sale and

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distribution and conduct of additional post-approval clinical studies or collection of long-term follow-up from patients in the clinical study that supported approval.
Failure to comply with the conditions of approval can result in materially adverse enforcement action, including the loss or withdrawal of the approval.

If a manufacturer plans to make significant modifications to the manufacturing process, labeling, or design of an approved PMA device, the manufacturer
must  submit  an  application  called  a  “PMA  Supplement”  regarding  the  change.  The  FDA generally  reviews  PMA  Supplements  on  a  180-day  agency  timetable,
which may be extended if significant questions arise in review of the supplement. A manufacturer may implement limited changes prior to the FDA’s review of a
PMA Supplement. The FDA designates some PMA Supplements as “panel-track” supplements, which means that the agency believes review by an advisory panel
may be warranted. Designation as a panel-track supplement does not necessarily mean that panel review will occur.

Clinical or Market Trials. A clinical trial is typically required to support a PMA application and is sometimes required for a 510(k) premarket notification.
Clinical trials conducted to support premarket clearance or approval generally require submission of an application for an Investigational Device Exemption (IDE)
to the FDA. Appropriate data must support the IDE application, such as animal and laboratory testing results, showing that it is safe to test the device in humans
and  that  the  investigational  protocol  is  scientifically  sound.  The  IDE  application  must  be  approved  by  the  FDA  for  a  specified  number  of  patients,  unless  the
product  is  deemed  eligible  for  more  abbreviated  IDE  requirements.  Clinical  trials  for  a  significant  risk  device  may  begin  once  the  FDA  approves  the  IDE
application. All FDA-regulated clinical studies, whether significant or non-significant risk, must be approved and overseen by the appropriate institutional review
boards (IRBs) at the clinical trial sites, and informed consent of the patients participating in the clinical trial must be obtained. After a trial begins, the FDA may
place it on hold or terminate it, if, among other reasons, it concludes that the clinical subjects are exposed to an unacceptable health risk. Any trials we conduct in
the United States must be conducted in accordance with FDA regulations as well as other federal regulations and state laws concerning human subject protection
and privacy. Moreover, the results of a clinical trial may not be sufficient to obtain clearance or approval of the product.

Oversight of compliance with quality, medical device reporting, clinical study, and other regulations. Both before and after we receive premarket clearance
or approval and release a product commercially, we have ongoing responsibilities under FDA regulations. The FDA reviews design and manufacturing practices,
labeling  and  record  keeping,  product  complaints  and  manufacturer’s  required  reports  of  adverse  experiences,  product  corrections  and  removals,  and  other
information to identify potential problems with marketed medical devices. We are also subject to periodic inspection by the FDA for compliance with the FDA’s
QSR  and  other  requirements,  such  as  requirements  for  advertising  and  promotion.  The  Good  Manufacturing  Practice  (GMP)  regulations  for  medical  devices
embodied  in  the  QSR  govern  the  methods  used  in,  and  the  facilities  and  controls  used  for,  the  design,  manufacture,  packaging,  labeling,  and  servicing  of  all
finished medical devices intended for human use.

The FDA’s Bioresearch Monitoring Program (BIMO), reviews our activities as a sponsor of clinical research. BIMO conducts facilities inspections as part of
a program designed to ensure that data and information contained in requests for IDEs, PMA applications and 510(k) submissions are scientifically valid, reliable,
and accurate. Another objective of the program is to ensure that human subjects are protected from undue hazard or risk during scientific investigations.

If the FDA were to conclude that we are not in compliance with applicable laws or regulations, or that any of our medical devices are ineffective or pose an
unreasonable health risk, the FDA could require us to notify health professionals and others that the devices present unreasonable risk or substantial harm to public
health, order a recall, repair, replacement, or refund of the devices, detain, or seize adulterated or misbranded medical devices, or ban the medical devices. The
FDA  may  also  issue  warning  letters  or  untitled  letters,  refuse  our  request  for  510(k)  clearance  or  PMA  approval,  revoke  existing  510(k)  clearances  or  PMA
approvals previously granted, impose operating restrictions, enjoin, and restrain certain violations of applicable law pertaining to medical devices and assess civil
or criminal penalties against our officers, employees, or us. The FDA may also recommend prosecution to the Department of Justice. In the case of devices subject
to  pending  premarket  clearance  or  approval  applications,  FDA  has  broad  authority  to  halt  the  review  of  applications  and  require  significant  additional  data
analyses, audits, and other corrective actions where clinical data contained in an application are deemed to be actually or potentially unreliable, inaccurate, or not in
compliance with clinical study or good clinical practice requirements.

For example, on May 27, 2014, we received a warning letter from the FDA (2014 Warning Letter) citing alleged violations of current good manufacturing
practice  (cGMP)  regulations  that  were  identified  by  the  FDA during  an  inspection  of  our  manufacturing  facility  in  Monrovia,  California  between  February  10,
2014, and March 21, 2014. On November 14, 2014 and continuing through February 4, 2015, the FDA again inspected our Monrovia

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facility.  On  February  4,  2015,  at  the  conclusion  of  the  inspection,  the  FDA  issued  an FDA-483  with  ten  inspectional  observations  (2015  FDA-483).  STAAR
responded to the 2014 Warning Letter and the 2015 FDA-483 and implemented its corrective action plans relating to the 2014 Warning Letter and the 2015 FDA-
483.  On June 19, 2018, we received a close-out letter from the FDA lifting the 2014 Warning Letter.

Healthcare Fraud and Abuse Laws and Regulations.

Even though we do not control referrals of healthcare services or bill directly to Medicare, Medicaid or other third-party payers, certain federal, state and
international healthcare laws and regulations pertaining to fraud and abuse and patients’ rights may be applicable to our business. We may be subject to healthcare
fraud  and  abuse  and  patient  privacy  regulation  by  the  federal  government,  the  states  and  the  international  jurisdictions  in  which  we  conduct  our  business.  The
regulations that may affect our ability to operate include, without limitation:

•

•

•

•

•

•

the  federal  Anti-Kickback  Statute,  which  prohibits,  among  other  things,  any  person  from  knowingly  and  willfully  offering,  soliciting,  receiving,  or
providing remuneration, directly or indirectly, to induce either the referral of an individual, for an item or service or the purchasing or ordering of a
good or service, for which payment may be made under federal healthcare programs such as the Medicare and Medicaid programs;

the federal False Claims Act, which prohibits, among other things, individuals, or entities from knowingly presenting, or causing to be presented, false
claims, or knowingly using false statements, to obtain payment from the federal government, and which may apply to entities that provide coding and
billing advice to customers;

federal  criminal  laws  that  prohibit  executing  a  scheme  to  defraud  any  healthcare  benefit  program  or  making  false  statements  relating  to  healthcare
matters;

the  federal  physician  sunshine  requirements  under  the  Patient  Protection  and  Affordable  Care  Act  of  2010,  which  requires  manufacturers  of  drugs,
devices, biologics, and medical supplies to report annually to the Centers for Medicare & Medicaid Services information related to payments and other
transfers of value relating to certain drugs, devices, biologics, and medical supplies to physicians, other healthcare providers, and teaching hospitals,
and ownership and investment interests held by physicians and other healthcare providers and their immediate family members;

the federal Health Insurance Portability and Accountability Act of 1996, as amended by the Health Information Technology for Economic and Clinical
Health Act of 2009, which governs the conduct of certain electronic healthcare transactions and protects the security and privacy of protected health
information; and

state  and  international  law  equivalents  of  each  of  the  above  federal  laws,  such  as  anti-kickback  and  false  claims  laws  which  may  apply  to  items  or
services reimbursed by any third-party payer, including commercial insurers; state laws that require device companies to comply with the industry’s
voluntary compliance guidelines and the applicable compliance guidance promulgated by the federal government, or otherwise restrict payments that
may  be  made  to  healthcare  providers  and  other  potential  referral  sources;  state  and  international  laws  that  require  device  manufacturers  to  report
information  related  to  payments  and  other  transfers  of  value  to  physicians  and  other  healthcare  providers  or  marketing  expenditures;  and  state  and
international laws governing the privacy and security of health information in certain circumstances, which may differ from each other and may not
have the same effect, thus complicating compliance efforts.

Because  of  the  breadth  of  these  laws  and  the  narrowness  of  the  statutory  exceptions  and  safe  harbors  available,  it  is  possible  that  some  of  our  business
activities could be subject to challenge under one or more of such laws. In addition, recent health care reform legislation has strengthened these laws. For example,
the Health Care Reform Law, among other things, amends the intent requirement of the Federal Anti-Kickback Statute and criminal healthcare fraud statutes. A
person  or  entity  no longer  needs  to  have  actual  knowledge  of  the  statute  or  specific  intent  to violate  it.  In  addition,  the  Patient  Protection  Affordable  Care  Act
provides that the government may assert that a claim including items or services resulting from a violation of the Federal Anti-Kickback Statute constitutes a false
or fraudulent claim for purposes of the False Claims Act.

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Regulatory Requirements Outside the United States.

CE Marking.  In  the  European  Economic  Area  (EEA),  which  is  comprised  of  the  27  Member  States  of  the  European  Union  plus  Norway,  Iceland,  and
Liechtenstein,  medical  devices  must  comply  with  the  essential  requirements  of  the  EU  Medical  Devices  Directive  (Council  Directive  93/42/EEC).  Compliance
with the essential requirements of the EU Medical Device Directive is a prerequisite to be able to affix a Conformité Européenne Mark (CE Mark), without which
medical devices cannot be marketed or sold in the EEA. To demonstrate compliance with the essential requirements, medical device manufacturers must undergo a
conformity assessment procedure, which varies according to the type of medical device and its classification.

The  method  of  assessing  conformity  varies  depending  on  the  class  of  the  product,  but  normally  involves  a  combination  of  self-assessment  by  the
manufacturer  and a third-party  assessment  by a “Notified  Body.” Notified Bodies are a group of private  quality-monitoring  organizations that are accredited  to
review medical devices and to monitor quality systems and adverse event reporting. The independent  Notified Bodies perform,  on a privatized basis, functions
similar to the FDA in the U.S. and the Pharmaceuticals and Medical Devices Agency (PMDA) in Japan. Our facilities in the United States and Switzerland are
subject to regular inspection by a designated Notified Body. Other countries, such as Switzerland, have voluntarily adopted laws and regulations that mirror those
of the European Union with respect to medical devices, and a number of countries outside of Europe permit importation of devices bearing the CE Mark.

The  European  Union  regulatory  bodies  finalized  a  new  Medical  Device  Regulation  (MDR)  in  2017,  which  replaced  the  existing  Directives  and  provided
three years for transition and compliance. The MDR will change several aspects of the existing regulatory framework, such as updating clinical data requirements
and  introducing  new  ones,  such  as  Unique  Device  Identification  (UDI).  We  and  the  Notified  Bodies  who  will  oversee  compliance  to  the  new  MDR  face
uncertainties and increased costs as the MDR is rolled out and enforced by the European Commission and EEA Competent Authorities, creating risks in several
areas, including the CE Marking process and data transparency, in the upcoming years. In April 2020, the European Parliament postponed implementation of MDR
to May 2021 due to the COVID pandemic. The exit of the UK from the European Union (BREXIT) has resulted in the requirement to re-certify our preloaded
acrylic IOL under a non-UK Notified Body, and to separately register our CE Marked products for sale in the UK.

We  have  affixed  the  CE  Mark  to  all  our  principal  products  sold  in  CE  Mark  jurisdictions  including  ICLs,  IOLs  and  injector  systems.  In  July  2017,  our
Notified Body in the European Union, DEKRA, re-certified the CE Marking for all our currently certified and commercially available medical devices. In March
2018, DEKRA performed audits of our US and Swiss facilities certifying them to EN ISO 13485:2016 as well as to the “Medical Device Single Audit Program”
(MDSAP).  MDSAP  provides  for  a  single  audit  recognized  by  Australia,  Brazil,  Canada,  Japan  and  the  United  States  demonstrating  routine  compliance  with
QSR/GMP requirements. DEKRA performed an unannounced audit in December 2018, and surveillance audits in 2019. In 2020, DEKRA audited and approved
our new facility in Brugg, Switzerland and completed surveillance audits of all our facilities, reconfirming our compliance to EN ISO 13485:2016 and MDSAP.

Medical Device Regulation in Japan. The Japanese Ministry of Health, Labor, and Welfare (MHLW) regulates the sale of medical devices under Japan’s
Pharmaceutical  Affairs  Law  (PAL).  The  Pharmaceuticals  and  Medical  Devices  Agency  (PMDA),  a  quasi-governmental  organization,  performs  many  of  the
medical device review functions for MHLW. Medical devices generally must undergo thorough safety examinations and demonstrate medical efficacy before the
MHLW  grants  shonin (premarket  device  approval)  or  ninsho (certification).  Manufacturers  and  resellers  (referred  to  as  Marketing  Authorization  Holders  or
MAHs)  must  also  satisfy  certain  requirements  before  the  MHLW  grants  a  business  license,  or  kyoka.  Requirements  for  manufacturers  and  MAHs  include
compliance with Japanese regulations covering GQP (good quality control practice) and GVP (good vigilance practice), which largely include conformity to the
ISO 13485 standard and are similar to good manufacturing practice and post-market surveillance requirements in the United States, as well as the assignment of
internal supervisors over marketing, quality assurance, and safety control.

Approval for a new medical device that lacks a substantial equivalent in the Japanese market will generally require the submission of clinical trial data. Only
a licensed MAH can apply for premarket device approval in Japan, and in most cases, the clinical trial data must include data gathered from Japanese subjects. For
example, STAAR Japan conducted a separate clinical trial in Japan for the shonin application for the ICL. Also, approval for a new medical device will require the
manufacturer to undertake to reexamine the safety and efficacy of the device with a review of post-market data gathered within a certain period - normally four
years - after approval. The specific post-market reexamination requirement for a medical device is announced at the time of approval.

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STAAR Japan currently holds shonin approval for the ICL products, preloaded injectors, and their associated lenses, and kyoka licensing as a manufacturer
and MAH of medical devices. The sponsor of a clinical trial submitted to the MHLW must strictly follow Good Clinical Practice (GCP) standards, and must follow
the  trial  with  standard  Good  Post-Market  Study  Practice  (GPSP)  reporting  and  a  follow-up  program.  MHLW  and  PMDA  also  assess  the  quality  management
systems  of  manufacturers  and  the  conformity  of  products  to  the  requirements  of  PAL.  STAAR  is  subject  to  inspection  for  compliance  by  these  agencies.  A
company’s failure to comply with PAL can result in severe penalties, including revocation or suspension of a company’s business license and possible criminal
sanctions. If the PMDA were to conclude that we are not in compliance with applicable laws or regulations, or that any of our medical devices are ineffective or
pose an unreasonable health risk, they could take a variety of regulatory or legal actions, similar to the FDA, which could have a material and negative impact on
the Company.

Medical Device Regulation in China and Korea. Sales of our products in China and Korea, as in other countries, are also subject to regulatory requirements.  

In China, medical devices such as our ICLs are mainly regulated by Supervision and Regulation of Medical Devices (Decree No. 680) promulgated by the
State Council. National Medical Products Administration (NMPA) is the governmental authority principally responsible for the supervision and administration of
medical devices in China.  

Each  medical  device  intended  for  commercial  distribution  in  China  is  subject  to  a  mandatory  filing  or  registration  regime  regulated  by  the  NMPA.  The
classification of such devices mainly determines the filing pathways. China has a three-class classification system, from Class I (lowest risk) to Class III (highest
risk). Most of STAAR’s medical devices are Class II and Class III devices and are subject to a restricted registration pathway. Applicants are required to submit a
product  technical  requirements  (PTR)  document,  which  shall  mainly  include  the  performance  indicators  and  testing  methods  of  the  medical  device.  Also,
applicants must submit samples of the device to a government recognized laboratory qualified as a medical device testing center in accordance with the PTR and
Chinese  standards.    Results  from  the  testing  center,  together  with  other  registration  documents,  ,  are  submitted  to  the  Center  for  Medical  Device  Evaluation
(CMDE) division of the NMPA for technical evaluation.

If approved, NMPA issues the medical device a registration license that is valid for five years. To renew a medical device's registration, the manufacturer

submits a renewal application before the license expiration date.

After approval, in case of substantial changes to the design, raw materials, manufacturing process, and indications, among other things, that may affect the
medical device's safety and effectiveness, the manufacturer applies to NMPA for approval of such registration changes. In case of minor changes that do not affect
the medical device's safety and effectiveness, the manufacturer submits a change notification to NMPA.

In  China,  we  obtain  the  registration  licenses  of  our  products  from  NMPA  ourselves.  Therefore,  we  are  the  market  authorization  holder  (MAH).  As  an
overseas manufacturer, we are also required to have a China-based agent. The agent provides maintenance support and technical service, oversees the registration
and clinical trial process, and helps to manage adverse events (AE) in case of device malfunction.  

Under Decree 1 Medical Device Adverse Event Reporting and Reevaluation, the MAH bears the primary responsibility for monitoring medical device AEs,
and establishing an AE monitoring system. In addition, Periodic Risk Assessment Reports are needed to describe the likelihood, consequences, and tolerances of
the possible risks of using a device.  Such reports are required annually for the first five years of registration and then during each license renewal submission.

In Korea, a registration of medical devices such as our ICLs and IOLs is overseen by the Ministry of Food and Drug Safety (MFDS) pursuant to the Medical
Device Act. The Medical Device Safety Bureau of the MFDS holds primary responsibility for medical device regulations, while departments within the National
Institute  of  Food  and  Drug  Safety  (NIFDS)  Evaluation  oversee  the  evaluation  and  research  of  medical  devices.    Medical  devices  require  registration  and/or
approval  prior  to  commercialization.    In  Korea,  medical  device  classification  closely  follows  the  Global  Harmonization  Task  Force  (GHTF)  Classification
guidelines, with Class I, II, III and IV designation ranked from low to high risk categorization. The registration review route depends on the risk classification of
the device. Typically, the MFDS requires similar documentation as required to obtain a CE Mark.  Our distributor in Korea is contractually required to obtain, with
our  assistance,  the  necessary  health  registrations,  governmental  approvals,  or  clearances  to  import,  market  and  sell  our  products.    In  Korea,  we  provide  our
distributor  with  information  and  data  to  obtain  appropriate  registrations  and  approvals,  and  the  distributor  obtains  such  registrations.  In  addition  to  the  device
registration, MFDS requires all devices Class II and above to comply with Korean Good Manufacturing Practice (KGMP) quality system standards in order to be
marketed in Korea. KGMP standards are based on ISO

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13485 quality system standards. However, they are not identical. Therefore, ISO 13485 certificates issued by a notified body in the EU will not be sufficient. To
obtain  KGMP  certification,  documents  that  pertain  to  all  areas  of  compliance,  including  design,  risk  assessment,  technical  requirements  and  any  other  quality
system requirements, need to be submitted to an MFDS-authorized third party. Our distributor in Korea submits the application on behalf of STAAR. After the
application is submitted, the manufacturing site undergoes either a paper audit or an onsite inspection/audit by an authorized third party and MFDS. Medical device
registration licenses do not expire, but the KGPM certificate must be renewed every three years.

If the NMPA or MFDS were to conclude that we are not in compliance with applicable laws or regulations, or that any of our medical devices are ineffective
or pose an unreasonable health risk, they could take a variety of regulatory or legal actions in their respective countries, similar to the FDA, which could have a
material and negative impact on the Company.

Third Party Coverage and Reimbursement.

Health  care  providers  generally  rely  on  third-party  payers,  including  governmental  payers  such  as  Medicare  and  Medicaid,  private  insurance  plans  and
workers’  compensation  plans,  to  cover  and  reimburse  the  cost  of  medical  devices  and  related  services.  These  third-party  payers  may  deny  coverage  or
reimbursement  for  a  medical  device  if  they  determine  that  the  product  or  procedure  using  the  product  was  not  medically  appropriate  or  necessary  and  are
increasingly challenging the price of medical devices and services.

Our ICL products generally are not covered by third-party payers, and patients incur out-of-pocket costs for these products and related procedures using our
products. Our IOL products used in cataract procedures generally are covered by third-party payers, such as Medicare, in whole or in part depending upon a variety
of factors, including the specific product used and geographic location where the procedure using the covered product is performed. The market for some of our
IOL products therefore is influenced by third-party payers’ policies.

In the United States, the Centers for Medicare & Medicaid Services (CMS), the agency responsible for administering the Medicare program, sets coverage
and  reimbursement  policies  for  the  Medicare  program.  CMS  may  modify  its  coverage  and  reimbursement  policies  related  to  IOLs,  including  IOLs,  as  well  as
cataract procedures using IOLs, at any time. Since the enactment of the Patient Protection and Affordable Care Act, as amended by the Health Care and Education
Reconciliation Act, or collectively, the Health Care Reform Law, there have been an increasing number of legislative initiatives in the United States to contain
health  care  coverage  and  reimbursement  by  governmental  and  other  payers.  These  laws,  as  well  as  future  laws  that  may  be  enacted,  may  result  in  additional
reductions in Medicare and other health care funding, which could have a material adverse effect on our customers.

In international markets, reimbursement and healthcare payment systems vary significantly by country, and many countries have instituted cost containment
initiatives similar to those in the United States. There can be no assurance that third-party coverage and reimbursement will be available or adequate, or that such
policies or any future legislation or regulation will not adversely affect the demand for our IOLs or our ability to sell these products at prices we consider adequate.

Research and Development  

We  focus  on  furthering  technological  advancements  in  the  ophthalmic  products  industry  through  the  development  of  innovative  premium  ophthalmic
products  (lenses  and  companion  delivery  systems),  materials  and  designs.  We  maintain  active  internal  research  and  development  programs.  To  achieve  our
business objectives, we will continue our investment in research and development.

During 2021, we intend to continue our focus on research and development in the following areas:

•

•

•

Development of presbyopia-correcting ophthalmic medical devices, including models that correct cylinder (i.e., astigmatism), including clinical trials of
the same;

Development of preloaded injector systems for ophthalmic medical devices; and

Development of a new generation of ophthalmic medical devices and materials.

Environmental Matters

We are subject to federal, state, local and foreign environmental laws, and regulations. We believe that our operations comply in all material respects with
applicable environmental laws and regulations in each country where we do business. We do not expect compliance with these laws to affect materially our capital
expenditures, earnings,

13

 
 
 
or competitive position. We have no plans to invest in material capital expenditures for environmental control facilities for the remainder of our current fiscal year
or  for  the  next  fiscal  year.  We  are  not  aware  of  any  pending  actions,  litigation  or  significant  financial  obligations  arising  from  current  or  past  environmental
practices that are likely to have a material adverse impact on our financial position. However, environmental problems relating to our properties could develop in
the future, and such problems could require significant expenditures. In addition, we cannot predict changes in environmental legislation or regulations that may be
adopted or enacted in the future and that may adversely affect us.

Human Capital

Our goal is to develop, manufacture and sell ophthalmic products throughout the world as primary and premium solutions for patients seeking visual freedom
from wearing eyeglasses or contact lenses while achieving excellent visual acuity through refractive vision correction. To achieve our goal, we continually seek to
attract, develop and retain talented people. We strive to make STAAR a diverse, inclusive, safe workplace, with opportunities for employees to grow and develop
their careers. We offer competitive compensation and benefits.

As of  January  1, 2021, we had approximately  575 full-time  equivalent  employees,  of which  225 were employed  outside  the  U.S. In fiscal  year  2020, we
added approximately 70 employees to help keep pace with the growth of our business. Our U.S. overall turnover rate in fiscal year 2020 was approximately 7%,
below  the  overall  turnover  rate  of  approximately  17%  in  the  medical  device  industry.  We  seek  employees  who  reflect  the  communities  where  we  conduct
operations. In the U.S., currently approximately 50% of our employees are female and approximately 50% are male. The gender ratio for our employees globally is
approximately 48% female and 52% male. In the U.S., currently approximately 60% of our employees are from underrepresented populations. Among our Board
of  Directors,  currently  three  directors  are  female  and  five  directors  are  male,  and  one  male  director  has  chosen  to  retire  from  the  Board  of  Directors  when  his
current  term  expires,  effective  at  STAAR’s  2021  Annual  Shareholders  Meeting.  Two  of  the  directors  on  our  Board  of  Directors  self-identify  as  members  of
underrepresented populations.  

The health and safety of our employees is a top priority We created and follow various safety policies and procedures. Also, we offer health insurance and
wellness programs. In response to the COVID-19 pandemic, we implemented numerous changes that we determined were in the best interest of our employees and
other  stakeholders,  and  which  followed  guidelines  and  regulations  of  the  applicable  health  authorities.  For example,  the  majority  of  our  employees  continue  to
work  from  home.  We  implemented  additional  safety  measures  for  employees  who  continue  critical  on-site  work  such  as  health  screening,  implemented  social
distancing and personal protective equipment requirements, enhanced cleaning and sanitation procedures, and modified workspaces and break areas to reduce the
potential for disease transmission. Two examples demonstrating our commitment to our employees during the pandemic are the following: (1) we did not furlough
any employees, even when we paused manufacturing operations from March 17, 2020 to April 27, 2020; and (2) we continued to fully compensate our employees
globally even when customers ceased purchasing our products.

We  invest  in  our  employees  by  offering  numerous  training  opportunities,  such  as  to  teach  new  skills,  provide  career  development  opportunities  and
communicate expectations regarding business conduct and ethics. In addition to salaries, we provide additional compensation and benefits programs (which vary
by country) such as cash bonuses, stock awards, a 401(k) plan, health insurance benefits, health savings and flexible spending accounts, paid time off, family leave,
and employee assistance programs, among others.

Code of Ethics

STAAR has adopted a revised Code of Business Conduct and Ethics that applies to all its directors, officers, and employees. The Code of Business Conduct

and Ethics is posted on our website, www.staar.com — Investor Information: Corporate Governance.

Additional Information

We make available free of charge through our website, www.staar.com, our Annual Report on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports
on Form 8-K and amendments to any reports filed or furnished pursuant to Section 13(a) of the Securities Exchange Act of 1934, as soon as reasonably practicable,
after those reports are filed with or furnished to the Securities and Exchange Commission (“SEC”).

The SEC maintains an Internet site that contains reports, proxy and information statements, and other information regarding STAAR and other issuers that

file electronically with the SEC at http://www.sec.gov.

14

Glossary

The following glossary is intended to help the reader understand some of the terms used in this Report.

acrylic – a broadly used family of plastics. Acrylic materials used in IOLs have been both water repelling (hydrophobic) and water-absorbing (hydrophilic).

The most popular IOLs in the U.S., Europe and Japan are made of a flexible, water-repellent acrylic material.

aspheric –  aspheric  lenses  are  lenses  that  are  designed  in  a  shape  that  creates  a  more  clearly  focused  image  than  traditional  spheric lenses.  By  reducing

spherical aberrations, IOLs that feature aspheric optics generally deliver better night vision and contrast sensitivity than spheric IOLs.

collagen copolymer - compounds formed by joining molecules of collagen derived from biological sources with synthetic monomer molecules. STAAR’s

Collamer® is a collagen copolymer engineered specifically for use in implantable lenses.

contrast sensitivity - the ability to visually distinguish an object from its background.

crystalline lens – the natural lens that is present in the eye at birth, which is a clear structure, located behind the iris that changes shape to focus light onto the

retina.

excimer laser – a specialized ultraviolet laser used in ophthalmology to cut or shape eye tissue. The excimer laser is used during LASIK and PRK surgery.

foldable IOL – an intraocular lens made of flexible material, which can be inserted with an injector system through a small incision in minimally invasive

cataract surgery.

haptic – the part of an IOL that contacts the structures of the eye and holds the IOL in place. IOLs in which the haptic is also a part of the optic material is

called a single-piece IOL, while IOLs in which the haptics are attached to the optic is called a three-piece IOL.

hyperopia –  the  refractive  disorder  commonly  known  as  farsightedness,  which  occurs  when  the  eye’s  lens  focuses  images  behind  the  plane  of  the  retina
rather than on the retinal surface. An adult with moderate to high hyperopia cannot see close objects without eyeglasses or contact lenses. Because presbyopia often
results in the need for reading glasses, it is sometimes confused with farsightedness.

intraocular – within the eye.

injector  or  injector  system –  a  device  in  the  form  of  a  syringe  that  is  used  to  deliver  a  foldable  IOL  into  the  eye  through  a  slender  nozzle  in  minimally

invasive cataract surgery.

iridotomy – a small hole created in the iris, usually made with a YAG laser. Prior to implantation of some ICL models a YAG peripheral iridotomy is made
in an unobtrusive area at the periphery of the iris to ensure continued fluid flow in the eye after implantation. The ICL with CentraFLOW technology, marketed
with the brand names EVO and EVO+, have a central port for fluid flow, which eliminates the need for an iridotomy or iridectomy.

LASIK –  an  acronym  for  laser-assisted  in-situ  keratomileusis,  a  surgical  operation  that  reshapes  the  cornea  to  correct  nearsightedness,  farsightedness,  or
astigmatism. LASIK involves first the cutting of a hinged flap to separate the surface layer of the cornea, using a microkeratome (a special blade) or a laser. An
excimer laser is then used to ablate tissue and reshape the inner cornea, after which the flap is returned to position.

myopia – the refractive disorder also known as nearsightedness, which occurs when the eye’s lens focuses images in front of the retina rather than on the

retinal surface. A person with myopia cannot clearly see distant objects without eyeglasses or contact lenses.

ophthalmologist – a surgeon who specializes in the diseases and disorders of the eye and the related visual pathway.

ophthalmic – of or related to the eye.

optic – the central part of an IOL or ICL, the part that functions as a lens and focuses images on the retina.

PRK – an acronym for photorefractive keratectomy, the first type of laser surgical operation to correct nearsightedness, farsightedness, or astigmatism.

15

preloaded injector -  an  IOL  packaged  and  shipped  in  a  pre-sterilized,  disposable  injector.  This  differs  from  the  conventional  method  of  packaging  IOLs,

which requires the surgeon or an assistant to manually load each lens into an injector before surgery.

presbyopia – an age-related condition in which the crystalline lens loses its ability to focus on both near and far objects. People who have had normal vision

will typically begin to need eyeglasses for reading or other close tasks at some point after age 40 due to presbyopia.

QSR - the FDA’s Quality System Regulation, or current Good Manufacturing Practice (cGMP) regulation, includes requirements related to the methods used
in, and the facilities and controls used for, designing, manufacturing, packaging, labeling, storing, installing, and servicing of medical devices intended for human
use.  The  regulation  sets  forth  the  framework  for  medical  device  manufacturers  to  follow  in  achieving  quality  requirements,  including  requirements  related  to
complaint handling and control of purchased or supplied services, components, and materials bearing on the quality of medical devices.

RLE – refractive lens exchange, a refractive surgical procedure in which the natural crystalline lens is removed and replaced with an IOL (essentially the

same as cataract surgery but performed primarily to address refractive issues not to remove a cataract).

refractive market –  as  used  in  this  report  “refractive  market”  means  the  overall  market  volume  for  refractive  surgical  procedures  of  all  kinds,  including
LASIK, PRK, RLE, the ICL product family and other phakic IOLs. As used in this report, the term does not include sales of non-surgical products like eyeglasses
and contact lenses.

silicone – a type of plastic often used in implantable devices that is inert, generally flexible and water-repelling.

single-piece IOL – in a single piece IOL the haptics and the optic are fashioned from a single piece of lens material.

spheric lenses – a spheric lens has surfaces that are shaped like sections of a sphere.

three-piece IOL – a three-piece IOL has a central, disk-shaped optic and two spring-like haptics attached at either side. The haptics are positioned against

structures of the eye to hold the IOL in place.

toric – refers to the shape of a lens designed to correct astigmatism, which has greater refractive power in some sections of the lens than others.

YAG – an acronym for yttrium-aluminum-garnet, a mineral crystal. Lasers using neodymium-doped yttrium aluminum garnet crystals (Nd:YAG) generate a

high-energy beam that can be used in a number of ophthalmic procedures, including creating iridotomies before implantation of some models of the ICL.

ITEM 1A.

Risk Factors

Investment in our securities involves a high degree of risk. Investors should carefully  consider the following risk factors, in addition to other information
contained in this report before making a decision to invest in our common stock. These risks are not the only ones we face. These risks and uncertainties, as well as
other  risks  that  we  cannot  foresee  at  this  time,  have  the  potential  to  affect  our  business,  financial  condition,  results  of  operations,  cash  flows,  strategies  and
prospects in a material and adverse manner. The trading price of our common stock could decline due to any of these risks, and investors may lose all or part of
their investment. This Annual Report on Form 10-K contains forward-looking statements that involve risks and uncertainties. Actual results could differ materially
from those anticipated or implied in these forward-looking statements because of factors beyond our control, including the risks faced by us described below.

We may not be able to continue our growth and profitability trajectory.

Risks Related to Our Business

In 2020 our revenue grew by 9% and we achieved $0.12 diluted earnings per share.  While we plan to continue sales growth and remain profitable, there can
be no guarantee that we will achieve our growth and profitability plans in 2021.  While we achieved profitability in the past three years, we reported losses in three
of the past six years. Our profitability is challenged by the competitive nature of our industry and the other risks to our business detailed herein.

16

Compliance issues may adversely impact our operations.

Quality system and other deficiencies observed by the FDA at certain of our facilities in the past resulted in delays in product approvals.  We plan to remain
in  compliance  with  regulatory  requirements  established  by  applicable  global  regulatory  agencies,  however,  there  can  be  no  guaranty  that  we  will  do  so.  If  we
cannot maintain compliance with a particular jurisdiction’s regulatory requirements, it could adversely impact our financial performance/have a material adverse
effect on our ongoing business and operations.  We expect to continue to devote resources and attention to our quality systems and compliance and other regulatory
requirements as part of the ordinary course of business. We cannot ensure that our efforts will be successful and failure to achieve or maintain compliance may
materially and adversely impact our business and operations.

We rely and depend on independent distributors in international markets.

Except for Japan, Germany, Spain, the U.S., Canada, the U.K. and Singapore, we sell our products through independent distributors who generally control
the importation and marketing of our product within their territories. We generally grant exclusive rights to these distributors and rely on them to understand local
market  conditions,  to  diligently  sell  our  products  and  to  comply  with  local  laws  and  regulations.  Our  agreements  with  distributors  and  local  laws  can  make  it
difficult for us to quickly change from a distributor who we feel is underperforming. If we do terminate an independent distributor, we may lose customers who
have been dealing with that distributor, and may be required to compensate the distributor for termination. Because these distributors are independent, it may be
difficult for us to detect failures in our distributors’ performance or compliance. Actions by independent distributors could result in declining sales in that territory,
harm to the reputation of our company or our products, or legal liability. For example, if Shanghai Lansheng, which accounted for approximately 44% of our fiscal
2020  consolidated  net  sales,  ceased  to  serve  as  our  distributor,  or  significantly  underperformed  our  expectations,  we  may  experience  a  substantial  reduction  in
sales.

Unfavorable economic conditions or negative publicity concerning complications of laser eye surgery, or medical devices in general, could hurt sales of

our refractive products.

Approximately  eighty-seven  percent  (87%)  of  our  revenue  was  derived  from  ICL  lenses  used  in  refractive  procedures.  Refractive  surgery  is  an  elective
procedure generally not covered by health insurance. Patients must pay for the procedure, frequently through installment financing arrangements with third parties.
They can defer the choice to have refractive surgery if they lack the disposable income to pay for it or do not feel their income is secure. Economic stagnation, lack
of consumer confidence or a recession in any of our larger markets could slow ICL sales growth or, if severe, cause declines in sales. Because the ICL is our best
selling and highest gross margin product, restricted growth or a decline in its sales could materially harm our business.

We believe that negative publicity in the past regarding the potential complications of refractive surgery and potential patient dissatisfaction, in particular
because  of  LASIK  and  other  corneal  laser-based  procedures,  decreased  patient  interest  in  LASIK  as  well  as  all  other  refractive  procedures.  Depending  on  the
nature  and  severity  of  any  future  negative  publicity  about  refractive  surgery,  the  growth  of  ICL  sales  could  be  limited  or  sales  could  decline  due  to  decreased
patient interest in all refractive surgery, including our ICL.  

Disruptions in our supply chain or failure to adequately forecast product demand could result in significant delays or lost sales.

The loss of a material  supplier  could significantly  disrupt our business. In some cases, we obtain components used in certain  of our products from single
sources. If we experience difficulties acquiring sufficient quantities of required materials or products from our existing suppliers, or if our suppliers are found to be
non-compliant  with  the  FDA’s  QSR,  other  applicable  laws,  or  STAAR’s  requirements,  then  qualifying  and  obtaining  the  required  regulatory  approvals  to  use
alternative suppliers may be a lengthy and uncertain process during which production could be delayed and we could lose sales.

Our sources of supply for raw materials may be threatened by shortages and other market forces, by natural disasters or public health crises, by the supplier’s
failure to maintain adequate quality or a recall initiated by the supplier. Even when substitute suppliers are available, the need to verify the substitute supplier’s
regulatory compliance and the quality standards of the replacement material could significantly delay production and materially reduce our sales.

In particular,  we manufacture  the proprietary collagen-containing  raw material  used in our ICLs internally. If the supply of these collagen-containing  raw

materials is disrupted, it could result in our inability to manufacture

17

those products and would have a material adverse effect on STAAR. The loss of our external supply source for silicone material, polymer for injectors or acrylic
lenses could also cause us material harm.

Further, any failure by us to forecast demand for or to maintain an adequate supply of, raw material and finished product could result in an interruption in the
supply of certain products and a decline in the sales of that product. For example, in 2020 our ICL sales grew 9%. If our suppliers or we are unable or our suppliers
are unwilling to meet our increased manufacturing requirements, we may not be able to produce enough materials or products in a timely manner, which could
cause a decline in our sales.

Because our business is global our sales and profits may fluctuate or decline in response to changes in foreign currency exchange rates and/or other

international risks (including tariffs).

Activities outside the U.S. accounted for approximately 96% of our total sales during 2020. Foreign currency fluctuations could result in volatility of our
revenue. The results of operations and the financial position of our Japanese subsidiary are reported in Japanese yen and then translated into U.S. dollars at the
applicable  exchange  rates  for  inclusion  in  our  consolidated  financial  statements,  exposing  us  to  translation  risk.  In  addition,  we  are  exposed  to  transaction  risk
because we incur some of our sales and expenses in currencies other than the U.S. dollar. Our most significant currency exposures are to the Japanese yen, the
euro, and the Swiss franc, and the exchange rates between these currencies and the U.S. dollar may fluctuate substantially. We do not actively hedge our exposure
to currency rate fluctuations. The strengthening of the U.S. dollar would likely negatively impact our results. We price some of our products in U.S. dollars, and
thus changes in exchange rates can make our products more expensive in some offshore markets and reduce our sales. Inflation in emerging markets could also
make our products more expensive and increase the credit risks to which we are exposed.  Future foreign currency fluctuations could favorably or unfavorably
impact and increase the volatility of our revenue, profitability, and stock price.

Economic, social, and political conditions, laws, practices, and local customs vary widely among the countries in which we sell our products. Our operations
outside of the U.S. face a number of risks and potential costs, including, enjoying less stringent protection of intellectual property, and facing economic, political,
and social uncertainty in some countries, especially in emerging markets. For example, sales in certain Asian and developing markets may result in lower margins
and higher exposure to intellectual property infringement or counterfeits. Also, if China, which accounted for approximately 44% of our fiscal 2020 consolidated
net sales, experienced a significant economic downturn, we may experience a significant reduction in sales. Further, trade disputes between the United States and
its significant trading partners may adversely affect our sales, including as a result of the imposition of tariffs or other barriers or restrictions on trade, or increase
our costs.  The institution of trade tariffs both globally and between the U.S. and China specifically could negatively impact the overall economic condition in our
markets,  including  China,  which could  have  a  negative  effect  on our  sales.  Also,  we  are  exposed  to  credit  and  collectability  risk  on  our  trade  receivables  with
customers in certain international markets. There can be no assurance we can effectively limit our credit risk and avoid losses and our ability to transfer foreign
earnings to the U.S. may be subject to taxes or restricted or result in incurring substantial costs.  Our continued success as a global company depends, in part, on
our  ability  to  develop  and  implement  policies  and  strategies  that  are  effective  in  anticipating  and  managing  these  and  other  risks  in  the  countries  where  we do
business. These and other risks may have a material adverse effect on our operations in any particular country and on our business, financial condition and results
of operations as a whole.

We may not be able to fully use our recorded tax loss carryforwards.

We have accumulated approximately $152.9 million of U.S. federal tax net operating loss carryforwards as of January 1, 2021, which can be used to offset
taxable income in future years if our U.S. operations become profitable. If unused, the pre-2018 tax loss carryforwards will begin to expire between 2021 and 2037.
Recently enacted legislation commonly known as the Tax Cuts and Jobs Act of 2017, or the Tax Act, subjects a U.S. shareholder to tax on Global Intangible Low
Tax Income (GILTI) earned by certain foreign subsidiaries.  At this time, our U.S. operations are not profitable, however, recognizing GILTI may offset federal net
operating  loss  carryforwards,  as  it  did  for  fiscal  years  2019  and  2018.    Our  ability  to  utilize  any  future  net  operating  losses  may  also  be  limited  by  the  Tax
Act.  Under the Tax Act, the amount of post-2017 net operating losses we are permitted to deduct in any taxable year is limited to 80% of our taxable income in
such year. The unused net operating losses, pre-2018 tax year can still offset 100% of taxable income.  In addition, the Tax Act generally eliminates the ability to
carry  back  any  net  operating  loss  to  prior  taxable  years,  while  allowing  post-2017  unused  net  operating  losses  to  be  carried  forward  indefinitely.  Due  to  these
changes  under  the  Tax  Act,  we  may  not  be  able  to  realize  a  tax  benefit  from  the  use  of  our  net  operating  losses,  whether  or  not  we  generate  profits  in  future
years.  Moreover, if we were to experience a

18

significant change in ownership, Internal Revenue Code Section 382 may restrict the future utilization of our tax loss carryforwards even if our U.S. operations
generate significant profits.

We are vulnerable to any loss of use of our principal manufacturing facility.

We manufacture most of our products at a single facility in Monrovia, California. All or a portion of the Monrovia facility could suffer catastrophic loss due
to fire, flood, earthquake, terrorism or other natural or man-made disasters, including manufacturing challenges such as equipment failure.  Developing additional
manufacturing sites may require significant expense for personnel and equipment and a long period to obtain regulatory approvals.  Our California and Japanese
facilities are in areas where earthquakes could cause catastrophic loss.

In our major markets, regulatory approval to manufacture materials and sell our products is generally limited to the current manufacturing site, and changing
the site requires applications to and approval from regulatory bodies prior to commercialization. To satisfy our own quality standards as well as regulations, we
must follow strict protocols to confirm that products and materials made at a new site are equivalent to those made at the currently approved site. For example, we
have commenced activities to resume manufacturing ICLs at our Swiss facility, and to commence manufacturing EVO Viva at our Lake Forest facility, but there
can be no guaranty whether or when these facilities will be prepared and approved by regulators for manufacturing. Even minor changes in equipment, supplies or
processes require validation. Unanticipated delays with a transferred process or difficulties in manufacturing a transferred material could interrupt our supply of
products. Any sustained interruption in supply could cause us to lose market share and harm our business, financial condition and results of operations.

If  any  or  a  portion  of  our  facilities  were  to  experience  a  catastrophic  loss,  or  if  one  of  our  facilities  is  found  not  to  be  in  compliance  with  regulatory
requirements, it could disrupt our operations, delay production and shipments, delay or reduce sales and revenue and result in large expenses to repair or replace
the facility, as well as lost customers or sales. Our insurance for property damage and business interruption may not cover any particular loss, or, if covered, be
sufficient. We do not carry insurance or reserve funds for interruptions or potential losses arising from earthquakes or terrorism.

Public health crises, political crises, and other catastrophic events or other events outside of our control may impact our business.

In 2020, we generated approximately 96% of our total sales outside the U.S. A natural disaster (such as tsunami, power shortage, or flood), public health
crisis (such as a pandemic or epidemic), political crisis (such as terrorism, war, political instability or other conflict), or other events outside of our control that may
occur anywhere around the world, may adversely impact our business and operating results. Moreover, these types of events could negatively impact surgeon or
patient spending in the impacted region(s) or depending upon the severity, globally, which could adversely impact our operating results. For example, in December
2019, COVID-19 was reported in Wuhan, China, resulting in temporary hospital and clinic closures and a decrease in consumer traffic in China, our largest single
market. Thereafter, COVID-19 spread globally becoming a pandemic, resulting in governmental authorities and other third parties implementing or recommending
a number of measures to contain the spread of COVID-19, including travel restrictions, shelter-in-place orders and business limitations and shutdowns.  The impact
of  COVID-19  and  these  measures  implemented  or  recommended  by  governmental  authorities  and  other  third  parties  have  had  a  significant  impact  on  many
businesses,  including  ours.  We  suspended  most  of  our  production  on  March  17,  2020  with  the  exception  of  continuation  of  critical  late-staged
processes.  Moreover, our revenues have been adversely impacted, as customers in China and elsewhere were not able to carry out procedures and we experienced
a substantial slowdown in sales beginning March 20, 2020 in global geographies characterized as “hot spots” for the COVID-19 virus, including parts of Europe
and North America.  In certain of these markets, sales paused as elective surgeries were discouraged to support COVID-19 related needs.  We expect this decrease
in sales in certain geographies, such as parts of Europe and North America, to continue through the first half of 2020 and possibly beyond as different geographies
resume  pre-pandemic  levels  of  business  activities  on  differing  timelines.    We  cannot  predict  when  different  governments  will  permit  businesses  in  their
jurisdictions to return to pre-pandemic levels of business or when consumers will resume scheduling procedures. We also cannot predict COVID-19’s impact on
the  overall  economy  of  various  markets,  including  the  existence  or  extent  of  a  possible  recession.  Thus,  at  this  point,  the  extent  to  which  the  coronavirus  may
impact delayed medical procedures and delayed lens orders, and the related impact on our full year 2021 results is uncertain; however, it could have a material
adverse  impact  on  our  results  of  operations,  cash  flows  and  financial  condition.  We  monitor  such  events  and  take  actions  that  we  deem  reasonable  given  the
circumstances. In the future other types of crises, may create an environment of business uncertainty around the world, which may hinder sales and/or supplies of
our products nationally and internationally.

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The extent to which the pandemic impacts our business, operations, and financial results, including the duration and magnitude of such effects, will depend
on numerous evolving factors that are uncertain and cannot be predicted, including the following: the duration and scope of the pandemic; the impact it has on
global and regional economies and economic activity, including the duration and magnitude of its impact on consumer spending; how quickly and to what extent
more customary economic and operating conditions can resume; its impact on our customers’ facilities; levels of consumer confidence; whether our COVID-19
preventative measures such as remote working arrangements, changes to manufacturing work areas, such as adherence to social distancing guidelines, and other
workforce changes will impact operational efficiency or inventory levels; our ability to obtain supplies from vendors or transport products to customers; the impact
on regulatory agencies, including the review and approval process; the impact on clinical studies; the ability of our customers to successfully navigate the impacts
of the pandemic  such as resuming  activities  and growing patient  interest  in our lenses; actions governments,  businesses and individuals  take in response  to the
pandemic; and potential employee illness and its impact on our operations.

We depend on key employees.

We depend on the continued service of our senior management and other key employees. The loss of a key employee could hurt our business. It could be
particularly detrimental if any key employee or employees went to work for a competitor. Also, our future success depends on our ability to identify, attract, train,
motivate and retain other highly skilled personnel. Failure to do so may adversely affect our results. We do not maintain insurance policies to cover the cost of
replacing the services of any of our key employees who may unexpectedly die or become disabled.

We compete with much larger companies and low-cost Asian manufacturers.

Our primary competitors, including Alcon (formally Novartis), Johnson & Johnson (formerly Abbott Medical Optics, or AMO), Bausch Health Companies
(formerly  Valeant  or  Bausch  &  Lomb),  and  Carl  Zeiss  Meditec  have  much  greater  financial,  technical,  marketing  and  distribution  resources  and  brand  name
recognition than we do and some of them have large international markets for a full suite of ophthalmic products. Their greater resources for research, development
and marketing, and their greater capacity to offer comprehensive products and equipment to providers, makes for intense competition. Over the past several years,
we have lost market share in IOL sales to some of our competitors. In addition, competitors from Asia are beginning to appear in some markets with their low-cost
version of an implantable contact lens, which competes with our ICL.  With our increased commercial success with the ICL, additional companies may seek to
enter the refractive phakic intraocular lens market.

Non-compliance with anti-corruption laws could lead to penalties or harm our reputation.

We  are  subject  to  anti-corruption  laws in  the  jurisdictions  in which  we  operate,  including  the  U.S. Foreign  Corrupt Practices  Act  (FCPA). Any failure  to
comply  with  these  laws,  even  if  inadvertent,  could  result  in  significant  penalties  or  otherwise  harm  our  reputation,  business,  financial  condition  and  results  of
operations. Our reliance on foreign subsidiaries and independent distributors requires vigilance in maintaining our policy against participation in corrupt activity.
In  many  of  our  markets  outside  the  U.S.,  doctors  and  hospital  administrators  may  be  deemed  government  officials.  Despite  precautions  we  may  take,  non-
compliance  may  occur  that  could  harm  our  reputation  and  financial  results.    Other  U.S.  companies  in  the  medical  device  and  pharmaceutical  field  have  faced
criminal penalties under the FCPA for allowing their agents to deviate from appropriate practices in doing business with such individuals.

We could experience losses due to product liability claims.

We have been subject  to product liability  claims in the past and may experience such claims in the future. Product liability claims against us may not be
covered, may exceed the coverage limits of our insurance policies or cause us to record a loss in excess of our deductible. A product liability claim that exceeds our
insurance coverage could materially harm our business, financial condition, and results of operations. Even if an insurance policy covers a product liability loss, we
must generally pay for losses until they reach the level of the policy’s stated deductible or retention amount after which the insurer begins paying. The payment of
retentions or deductibles for a significant number of claims could have a material adverse effect on our business, financial condition, and results of operations.

Any product liability claim would divert managerial and financial resources and could harm our reputation with customers. We cannot assure investors that

we will not have product liability claims in the future or that such claims would not have a material adverse effect on our business.

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Our defined benefit pension plans are currently underfunded and we may be subject to significant increases in pension benefit obligations under those

pension plans.

We sponsor two defined benefit pension plans through our wholly owned Swiss and Japanese subsidiaries, which we refer to as the “Swiss Plan” and the

“Japan Plan”, respectively. Both plans are underfunded and may require significant cash payments.

We determine our pension benefit obligations and funding status using many assumptions. If the investment performance does not meet our expectations, or
if other actuarial assumptions are modified, or not realized, we may be required to contribute more than we currently expect and increase our future pension benefit
obligations to be funded from our operations.

Our pension plans taken together are underfunded by approximately $11.9 million ($2.0 million for the Japan Plan and $9.9 million for the Swiss Plan) as of

January 1, 2021.

If our cash flow from operations is insufficient to fund our worldwide pension obligations, as well as other cash requirements, we may be materially  and

adversely harmed and have to seek additional capital.

Our activities involve hazardous materials, emissions, and use of an irradiator and may subject us to environmental liability.

Our manufacturing, research and development activities  involve the use of hazardous materials and equipment and use of an irradiator. Federal, state and
local laws and regulations govern the use, manufacturing, storage, handling and disposal of these materials and certain waste products in the places where we have
operations. We cannot eliminate the risk of accidental contamination or injury from these materials and equipment. Remedial environmental actions could require
us to incur substantial unexpected costs, which could materially and adversely affect our financial condition and results of operations. If we were involved in an
environmental accident or found to be in substantial non-compliance with applicable environmental laws, it could harm our reputation, and we could be held liable
for damages or penalized with fines.

Data corruption, cyber-based attacks or network security breaches and/or noncompliance with data protection regulations could negatively impact our

operations.

We depend on information technology networks and our information technology infrastructure for electronic communications among our locations around
the world and between our personnel and our subsidiaries, customers, and suppliers. The integrity and protection of our customer, vendor, supplier, employee, and
other Company data, is an important part of our business. Addressing applicable security and privacy regulations may increase our operating costs or adversely
affect our business operations.

Unauthorized parties may also gain access to our systems or facilities, and may, among other things, prevent access to our systems. Security breaches could
disrupt our operations, and result in lost or misappropriated information. Despite the security measures we have in place, our facilities and systems, and those of
our suppliers, distributors and customers with whom we do business, may be vulnerable to security breaches, cyber-attacks, or other similar events. Any security
breach of Company information could have a material adverse effect on our business, results of operations and financial condition. Also, certain of our information
technology systems are not redundant, and our disaster recovery planning is not sufficient for every eventuality. Despite any precautions we may take, such events
could harm our reputation and financial results.  For example, while we maintain cyber insurance, it may be insufficient to address any potential loss incurred.

We are subject to various data protection regulations in different jurisdictions, including the General Data Protection Regulation (Regulation (EU) 2016/679)
(GDPR) and the California Consumer Privacy Act. We have made and continue to engage in compliance efforts to satisfy these regulations, however, we may be
unsuccessful  in  complying  with  applicable  requirements,  and  may  be  at  risk  of  enforcement  actions  and/or  subject  to  fines,  including  those  imposed  by  a  data
protection  authority.  As  a  result,  we  may  incur  substantial  expense  in  complying  with  data  protection  regulations,  exposure  resulting  from  a  data  breach,
ransomware or non-compliance and may be distracted from other aspects of our business.

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The increased use of social media platforms and mobile technologies presents additional risks and challenges.

New technologies are increasingly used to communicate about our products and the health conditions they are intended to treat. The use of these media poses
risks to our business and requires specific attention and monitoring. For example, patients, competitors, or others may use these channels to comment on the safety
or effectiveness of a product and to report an alleged adverse event. Negative posts or comments about us or our business on any social networking web site could
harm our reputation. In addition, our employees may use social media tools and mobile technologies inappropriately, which may give rise to liability, or which
could lead to the exposure of sensitive information. In either case, such uses of social media and mobile technologies could have a material adverse effect on our
business, financial condition, and results of operations.

Acquisitions of technologies, products, and businesses could disrupt our operations, involve increased expenses and present risks not contemplated at the

time of the transactions.

We  may  consider  and,  as  appropriate,  make  acquisitions  of  technologies,  products,  and  businesses  that  we  believe  are  complementary  to  our  business.
Acquisitions typically entail many risks and could result in difficulties in integrating the operations, personnel, technologies, and products acquired, and mitigating
the risk of unknown liabilities some of which may result in significant payments or charges to earnings.

If we are unable to successfully integrate our acquisitions with our existing business, we may not obtain the advantages that the acquisitions were intended to
create, which may materially adversely affect our business, and our ability to develop and introduce new products. Actual costs and sales synergies, if achieved at
all, may be lower than we expect and may take longer to achieve than we anticipate. Acquisitions may also divert management’s attention from our core business.
Furthermore, the products of companies we acquire may overlap with our products or those of our customers, creating conflicts with existing relationships or with
other commitments that are detrimental to the integrated businesses.

If we are not able to manage growth successfully, this could adversely affect our business, financial condition, and results of operations.

If we continue to experience rapid growth, this places a significant strain on financial, operational, and managerial resources. We must continue to implement
and  enhance  our  managerial,  operational  and  financial  systems,  expand  our  operations,  and  continue  to  recruit  and  train  qualified  personnel.  There  can  be  no
assurance that our strategic and operational  planning will allow us to adequately manage anticipated growth. In addition, the expense associated with increased
manufacturing  and  sales/marketing  to  meet  increased  demand  may  exceed  our  expectations.  Any  inability  to  successfully  manage  growth  could  materially  and
adversely affect our business, financial condition, and results of operation.

Risks Related to the Ophthalmic Products Industry

Unless we keep pace with advances in our industry and persuade physicians to adopt our new products, our sales will not grow and may decline.

Our  future  growth  depends,  in  part,  on  our  ability  to  timely  develop  products  to  treat  diseases  and  disorders  of  the  eye  that  are  more  effective,  safer,  or
incorporate emerging technologies better than our competitors’ products, and are accepted by physicians and patients. Sales of our existing products may decline
rapidly  if  one  of  our  competitors  introduces  a  superior  product,  or  if  we  announce  a  new  product  of  our  own.  If  we  focus  on  research  and  development  or
technologies that do not lead to better products, more effective or advanced products could surpass our current and planned products. In addition, such product
development efforts could require a significant investment of resources.  If we are able to develop new products, we must manufacture these products economically
and market them successfully by demonstrating to enough eye-care professionals the overall benefits of using them.  If we do not timely develop new products that
meet market demand or if there is insufficient demand for our new products, our sales and results of operations could be harmed.  For example, it is uncertain
whether  physicians  in  countries  that  recognize  the  CE  Mark  will  adopt  the  EVO  Viva lens  for  use  in  presbyopic  eyes,  which  our  Notified  Body  approved  for
marketing and sale in July 2020.

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Resources devoted to research and development may not yield new products that achieve regulatory approval or commercial success.

Development  of  new  implantable  technology,  from  discovery  through  testing  and  registration  to  initial  product  launch,  is  expensive  and  time-consuming.
Because of the complexities and uncertainties of ophthalmic research and development, products we are developing, including those currently in development, may
not complete the development process or obtain the regulatory approvals required for us to successfully market the products. Our new products, including those
currently under development, may fail to become commercially successful.

We may be required to conduct extensive clinical trials to demonstrate safety and efficacy of new or enhanced products, such clinical trials are expensive,

complex, can take years to complete, and have highly uncertain outcomes.

In  order  to  further  advance  the  development  of,  and  ultimately  receive  regulatory  approval  to  manufacture  and  sell,  our  new  products  or  product
enhancements,  we  may  be  required  to  conduct  extensive  clinical  trials  to  demonstrate  their  safety  and  efficacy  to  the  satisfaction  of  the  FDA  or  regulatory
authorities in other countries. Clinical trials are expensive, complex, can take many years to complete, and have highly uncertain outcomes. Delays, setbacks, or
failures can occur at any time, or in any phase of the clinical trials, and can result from concerns about safety, a lack of demonstrated efficacy, or poor study or trial
design.  For example, we cannot ensure that our on-going clinical trial of the EVO Visian ICL in the U.S. will succeed in obtaining approval for correcting myopia
or astigmatism by the FDA.  The commencement and completion of clinical trials may be delayed or prevented by many factors, including, but not limited to:

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an inability to reach agreement with regulatory authorities regarding the scope or extent of a proposed clinical trial;

an inability to timely identify and reach agreement on acceptable terms with prospective clinical trial sites and entities involved in the conduct of our
clinical trials;

failure by third-party clinical trial managers to comply with applicable regulations or protocols;

flaws in the design of the clinical trials;

slower than expected rates of patient recruitment and enrollment;

periodic amendments to clinical trial protocols to address certain variables which arise during the course of a trial;

lack of effectiveness of our products; or

unforeseen safety issues.

We are subject to extensive government regulation worldwide, which increases our costs and could prevent us from selling our products.

We are regulated by regional, national, state and local agencies in the U.S. as well as governmental authorities in those international countries in which we
manufacture  or  distribute  products,  such  as  in  Europe  and  Asia.  These  regulations  may  govern  the  research,  development,  manufacturing,  and  commercial
activities relating to medical devices, including their design, pre-clinical and clinical testing, clearance or approval, production, labeling, sale, distribution, import,
export,  post-market  surveillance,  advertising,  dissemination  of  information  and  promotion.    Failure  to  receive  necessary  approvals  in  foreign  jurisdictions  on  a
timely basis, or at all, could harm our business and operating results. In addition, regulations and requirements for approvals can vary in each international country,
which can significantly increase the costs to sell our products in these international countries.

Complying with government regulation substantially increases the cost of developing, manufacturing and selling our products.

Competing in the ophthalmic products industry requires us to introduce new or improved products and processes continuously, and to submit these to the
FDA and other regulatory bodies for clearance  or approval. Obtaining clearance or approval can be a long and expensive process, and clearance  or approval is
never certain. For example, the FDA or another country’s regulatory agency, could require us to conduct an additional clinical trial prior to granting clearance or
approval of a product and such clinical trial could take a long time and have substantial expense. Furthermore, there is no assurance that clearance or approval will
be granted.

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If a regulatory authority delays or does not grant approval of a potentially significant product, the potential sales of the product and its value to us can be
substantially  reduced.  Even  if  the  FDA  or  another  regulatory  agency  clears  or  approves  a  product,  the  clearance  or  approval  may  limit  the  indicated  patient
populations or uses of the product, or may otherwise limit our ability to promote, sell and distribute the product, or may require expensive post-marketing studies
or surveillance. If we cannot obtain timely regulatory clearance or approval of our new products, or if the clearance or approval is too narrow, we will not be able
to successfully market these products, which would eliminate or reduce our potential sales and earnings.

In  addition,  the  FDA  and  other  regulatory  authorities  may  change  their  clearance  and  approval  policies,  adopt  additional  regulations,  or  revise  existing
regulations,  or  take  other  actions  which  may  prevent  or  delay  approval  or  clearance  of  our  products  under  development,  cause  the  loss  of  previously  received
approvals or clearances or impact our ability to modify our currently cleared products on a timely basis.  Also, we expect to incur additional costs complying with
the European Union’s new Medical Device Regulation (MDR).

We depend on proprietary technology but our intellectual property protections may be limited.

While  we  rely  on  various  intellectual  property  laws,  contractual  provisions  and  confidentiality  procedures  and  copyright  laws  to  protect  the  proprietary
aspects of our technology, we rely more on trade secrets and know-how, which may not prevent third parties from using publicly available information to access
our technology.   With respect  to our patents,  any of them  may be challenged,  invalidated,  circumvented  or rendered  unenforceable.  Any of our pending patent
applications  may  fail  to  result  in  an  issued  patent  or  fail  to  provide  meaningful  protection  against  competitors  or  competitive  technology.  Litigation  may  be
necessary to enforce our intellectual property rights, and to protect or determine the validity and scope of our proprietary rights. We also challenge others’ patents
or patent applications from time to time.  Any litigation could result in substantial expense, may reduce our profits, and may not adequately protect our intellectual
property rights. In addition, we may be exposed to future litigation by third parties based on claims that our products infringe their intellectual property rights. This
risk is exacerbated by the fact that the validity and breadth of claims covered by patents in our industry may involve complex legal issues that are open to dispute.
Any litigation or claims against or instituted by us, whether or not successful, could result in substantial costs, divert resources and the efforts of our personnel
away  from  daily  operations,  harm  our  reputation,  result  in  the  impairment  of  our  intellectual  property  rights,  limit  our  ability  to  pursue  future  products  and/or
otherwise materially adversely impact our business.

We may not successfully replace our existing products, including those that lose or have lost patent protection.

As  our  existing  patents  expire,  many  of  which  already  expired  over  the  past  several  years,  our  competitors  may  introduce  products  using  the  same
technology. Because of this possible increase in competition, we may lose sales and/or may need to reduce our prices to maintain sales of our products, which
would make them less profitable. If we fail to develop and successfully launch new products and/or obtain new patents, our sales and profits with respect to our
products could decline significantly. We may not be able to develop and successfully launch more advanced replacement products.

While  we  will  continue  developing  intellectual  property  protections  for  our  future  products,  third  parties  may  pursue  blocking  patents  that  limit  our

ability to manufacture such products.

We plan to continue relying on our intellectual  property rights to protect products and technology that we may develop or employ in the future, but third
parties may develop and obtain patents covering such products or technology. In such event, we may need to obtain licenses for such patents. However, we may
not be able to obtain licenses on reasonable terms, if at all, which could limit our ability to manufacture our future products and operate our business.

Laws pertaining to healthcare fraud and abuse could materially adversely affect our business, financial condition, and results of operations.

We are subject to various federal, state, local and international laws targeting fraud and abuse in the healthcare industry, including anti-kickback and false
claims laws. Violations of these laws are punishable by criminal or civil sanctions, including substantial fines, imprisonment, and exclusion from participation in
healthcare programs such as Medicare and Medicaid, and health programs outside the United States. These laws and regulations are wide ranging and subject to
changing  interpretation  and  application,  which  could  restrict  our  sales  or  marketing  practices.  Furthermore,  because  many  of  our  customers,  particularly  IOL
customers, rely on reimbursement from Medicare, Medicaid, and other governmental programs to cover a substantial portion of their expenditures, our exclusion
from

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such programs because of a violation of these laws could adversely impact our business, results of operations, financial condition, and cash flow.

If we recall a product, the cost and damage to our reputation could harm our business.

We  have  voluntarily  recalled  our  products  in  the  past  and  recalls  could  take  place  again.  We  may  also  be  subject  to  recalls  initiated  by manufacturers  of
products we distribute. We cannot eliminate the risk of a material recall in the future. Recalls can result in lost sales of the recalled products themselves, and can
result in further lost sales while replacement products are manufactured, especially if the replacements must be redesigned or approved by regulatory authorities
prior to distribution. If recalled products have already been implanted, we may bear some or all of the cost of corrective surgery. Recalls may also damage our
professional reputation and the reputation of our products. The inconvenience caused by recalls and related interruptions in supply, the underlying causal issues,
and the damage to our reputation, could cause professionals to discontinue using our products.

Companies are required to maintain certain records of actions, even if they determine such actions are not reportable to the FDA or other regulatory bodies. If
we determine that certain actions do not require notification of the FDA or others, the FDA or other regulatory bodies may disagree with our determinations and
require us to report those actions as recalls. In addition, the FDA or other regulatory bodies could take enforcement action for failing to report the recalls when they
were  conducted  or  failing  to  timely  report  or  initiate  a  reportable  product  action.  Moreover,  depending  on  the  corrective  action  we  take  to  redress  a  product’s
deficiencies or defects, the FDA or other regulatory bodies may require, or we may decide, that we will need to obtain new approvals or clearances for the device
before we may market or distribute the corrected device. Seeking such approvals or clearances may delay our ability to replace the recalled devices in a timely
manner.

Changes in FDA or international regulations related to product approval, including those that apply retroactively, could make us less competitive and

harm our business.

FDA and foreign regulations depend heavily on administrative interpretation, and we cannot assure investors that future interpretations made by the FDA or
other regulatory bodies, with possible retroactive effect, will not adversely affect us. Additionally, any changes, whether in interpretation or substance, in existing
regulations  or  policies,  or  any  future  adoption  of  new  regulations  or  policies  by  relevant  regulatory  bodies,  could  rescind,  prevent  or  delay  approval  of  our
products, which could materially impact our competitive position, business, and financial results. Further, we or our distributors have obtained regulatory approvals
outside the United States for many of our products. We or our distributors may be unable to maintain regulatory qualifications, clearances or approvals in these
countries  or  obtain  qualifications,  clearances,  or approvals  in  other  countries.  If  we are  not  successful  in doing  so, our business  and financial  condition  will be
harmed.

If  our  products,  or  malfunction  of  our  products,  cause  or  contribute  to  a  death  or  a  serious  injury,  we  will  be  subject  to  medical  device  reporting

regulations, which can result in voluntary corrective actions, agency enforcement actions and harm to our results.

Under the FDA regulations, we are required to report to the FDA any incident in which our product may have caused or contributed to a death or serious
injury  or in which our product  malfunctioned  and, if  the malfunction  were to recur,  would likely  cause or contribute  to death  or serious injury.  In addition,  all
manufacturers placing medical devices in international markets, such as European Union and Asian markets, are legally bound to report any serious or potentially
serious  incidents  involving  devices  they  produce  or  sell  to  the  relevant  authority  in  whose  jurisdiction  the  incident  occurred.  In  the  future,  we  may  experience
events that would require reporting to the FDA pursuant to the Medical Device Reporting (MDR) regulations or to other regulatory bodies pursuant to international
regulations.  Any  adverse  event  involving  our  products  could  result  in  future  voluntary  corrective  actions,  such  as  product  actions  or  customer  notifications,  or
agency actions, such as inspection, mandatory recall, or other enforcement action. Any corrective action, whether voluntary or involuntary, as well as defending
ourselves  in  a  lawsuit,  will  require  the  dedication  of  our  time  and  capital,  distract  management  from  operating  our  business,  and  may  harm  our  reputation  and
financial results.

The decision to file an MDR involves a judgment by us as the manufacturer. We have made decisions that certain types of events are not reportable under the
MDR and similar regulations; however, there can be no assurance that the FDA or other regulatory bodies will agree with our decisions. If we fail to report MDRs
to  the  FDA  or  other  regulatory  bodies  within  the  required  timeframes,  or  at  all,  or  if  the  FDA  or  others  disagree  with  any  of  our  determinations  regarding  the
reportability of certain events, the FDA or other regulatory bodies could take enforcement actions against us, which could have an adverse impact on our reputation
and financial results.

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If we modify our products, we may have to obtain new marketing clearances or approvals, or may have to cease marketing or recall the modified products

until clearances or approvals are obtained.

Any  modification  to  a  510(k)  cleared  device  that  could  significantly  affect  its  safety  or  effectiveness,  including  any  significant  change  in  design  or
manufacture, or that would constitute a major change in its intended use, requires a new 510(k) clearance or, possibly, approval of a PMA. The FDA requires every
manufacturer to make this determination in the first instance, but the FDA may review any manufacturer’s decision. The FDA may not agree with our decisions
regarding whether new clearances or approvals are necessary. We have modified some of our 510(k) cleared and PMA approved products, and have determined
based on our review of the applicable FDA guidance that in certain instances new 510(k) clearances or premarket approvals are not required. If the FDA disagrees
with  our  determination  and  requires  us  to  submit  new  510(k)  notifications  or  PMAs  for  modifications  to  our  previously  cleared  products  for  which  we  have
concluded that new clearances or approvals are unnecessary, we may be required to cease marketing and/or to recall the modified product until we obtain clearance
or approval, and we may be subject to significant regulatory fines or penalties.

Regulatory agencies in other countries similarly require approval or clearance prior to our marketing or selling products in those countries. We rely on our
distributors to obtain regulatory clearances or approvals of our products in certain countries outside of the United States. If we or our distributors are unable to
obtain additional clearances or approvals needed to market existing or new products in the United States or elsewhere or obtain these clearances or approvals in a
timely fashion or at all, or if our existing clearances or approvals are revoked or restricted, our revenues and profitability may decline.

Investigations and allegations, whether or not they lead to enforcement action or litigation, can materially harm our business and our reputation.

Our failure to comply with the requirements of the FDA or other regulators can result in civil and criminal fines, the recall of products, the total or partial
suspension of manufacturing or distribution, seizure of products, injunctions, lawsuits, failure to obtain approval of pending product applications, withdrawal of
existing product approvals, exclusion from participation in government healthcare programs and other sanctions. Any threatened or actual government enforcement
action  can  also  generate  adverse  publicity  and  require  us  to  divert  substantial  resources  from  more  productive  uses  in  our  business.  Enforcement  actions  could
affect our ability to distribute our products commercially and could materially harm our business.

In  addition,  negative  publicity  about  investigations  or  allegations  of  misconduct,  even  without  a  finding  of  misconduct,  could  harm  our  reputation  with
healthcare professionals and also with the market for our common stock. Responding to investigations or conducting internal investigations can be costly, time-
consuming, and disruptive to our business.

The market price of our common stock is likely to be volatile.

Risks Related to Ownership of Our Common Stock

The market price for our common stock has fluctuated widely. The closing price of our common stock ranged from $25.01 to $82.78 per share during the
year  ended  January  1,  2021.  Our  stock  price  could  continue  to  experience  significant  fluctuations  in  response  to  factors  such  as  market  perceptions,  quarterly
variations in operating results, operating results that vary from the expectations of securities analysts and investors, changes in financial estimates, changes in the
business and market valuations of competitors, announcements by us or our competitors of a material nature, additions or departures of key personnel, future sales
of our common stock and stock volume fluctuations. Also, general political and economic conditions such as a recession or interest rate fluctuations, and public
health crises, may adversely affect the market price of our common stock.

Because we do not intend to pay dividends, stockholders will benefit from an investment in our common stock only if it appreciates in value.

We have not paid any cash dividends on our common stock since our inception. We currently expect to retain any earnings for use to further develop our
business, and do not expect to declare cash dividends on our common stock in the foreseeable future. The declaration and payment of any such dividends in the
future depends upon our earnings, financial condition, capital needs, and other factors deemed relevant by our Board of Directors, and may be restricted by future
agreements with lenders. As a result, the success of an investment in our common stock will depend entirely upon any future appreciation. There is no guarantee
that our common stock will appreciate in value or even maintain the price at which stockholders purchase their shares.

26

Our Certificate of Incorporation and Bylaws, anti-takeover provisions of Delaware law, and contractual provisions could delay or prevent an acquisition

or sale of our company.

Our Certificate of Incorporation empowers our Board of Directors to issue one or more series of preferred stock, and to determine the rights of each such
series as provided in our Certificate of Incorporation. These provisions give our Board of Directors the ability to deter, discourage or make more difficult a change
in control of our company, even if such a change in control could be deemed in the interest of our stockholders or if such a change in control would provide our
stockholders with a substantial premium for their shares over the then-prevailing market price for our common stock. Our Certificate of Incorporation and Bylaws
contain other provisions that could have an anti-takeover effect, including the following:

•

•

•

•

stockholders cannot act by consent;

stockholders cannot fill vacancies on our Board of Directors;

certain  provisions,  including  those  related  to  changing  the  number  of  directors,  limiting  our  stockholders’  ability  to  fill  vacancies  on  our  Board  of
Directors,  prohibiting  stockholder  action  by  written  consent,  and  amending  such  provisions,  cannot  be  altered,  amended  or  repealed,  and  provisions
inconsistent therewith  cannot be adopted, without the affirmative  vote of holders of at least two-thirds in voting power of our outstanding shares of
common stock entitled to vote thereon; and

stockholders must give advance notice to nominate directors or propose other business.

In  addition,  we  are  generally  subject  to  the  anti-takeover  provisions  of  Section  203  of  the  Delaware  General  Corporation  Law,  which  regulates  corporate
acquisitions. These provisions could discourage potential acquisition proposals and could delay or prevent a change in control transaction. They could also have the
effect of discouraging tender offers for our common stock or prevent changes in our management.

Ownership of our common stock is concentrated among a few investors, which may affect the ability of a third party to acquire control of us. Substantial

sales by such investors could cause our common stock price to decline.

Our largest investor beneficially owns over 20% of our outstanding common stock, and our largest five investors beneficially own approximately 50% of our
outstanding common stock. Two of our current eight directors were recommended by our investors. The sale of a substantial number of shares of our common
stock by any or all of our largest investors or our other stockholders within a short period of time could cause our common stock price to decline, make it more
difficult for us to raise funds through future offerings of our common stock or acquire other businesses using our common stock as consideration.

In addition, having such a concentration of ownership may have the effect of making it more difficult for a third party to acquire, or of discouraging a third

party from seeking to acquire, a majority of our outstanding common stock or control of our Board of Directors, including through a proxy solicitation. 

Future sales of our common stock could reduce our stock price.

We could issue additional shares of common or preferred stock to raise additional capital or for other corporate purposes without stockholder approval. In
addition, we could designate and sell a class of preferred stock with preferential rights over our common stock with respect to dividends or other distributions.
Also, we have filed a universal shelf registration statement with the Securities and Exchange Commission.  The shelf registration statement is available to cover the
future public offering and sale of up to approximately $200,000,000 in equity or debt securities or any combination of such securities. Sales of our common or
preferred stock under the shelf registration or in other transactions could dilute the interest of existing stockholders and reduce the market price of our common
stock. Even in the absence of such sales, the perception among investors that additional sales of equity securities may take place could reduce the market price of
our common stock.

ITEM 1B.

Unresolved Staff Comments

None.

27

 
 
 
 
ITEM 2.

Properties

Our  operations  are  conducted  in  leased  facilities  throughout  the  world.  Our  global  administrative  offices,  principal  manufacturing,  warehouse  and
distribution, are in Monrovia, California. STAAR Surgical AG maintains administrative offices, manufacturing capabilities, warehouse and distribution facilities in
Nidau and Brügg, Switzerland. Our facility in Lake Forest, California serves as our corporate headquarters and is expected to handle manufacturing of the EVO
Viva to correct or reduce presbyopia after the facility’s approval.  The Company leases a research and development facility in Tustin, California and a facility in
Aliso Viejo, California for raw material production and research and development activities. STAAR Japan maintains executive offices in Shin-Urayasu, Japan and
a final packaging and inspection and distribution facility in Ichikawa City, Japan. We believe our operating facilities in the U.S., Switzerland and Japan are suitable
and adequate for our current requirements. The Company could increase capacity as needed.

ITEM 3.

Legal Proceedings

Certain of the legal proceedings in which we are involved are discussed under “Litigation and Claims” in Note 13, “Commitments and Contingencies,” to our

Consolidated Financial Statements in this Annual Report on Form 10-K, and are hereby incorporated by reference.  

ITEM 4.

Mine Safety Disclosures

None.

ITEM 5.

Market for Registrant’s Common Equity, Related Stockholder Matters, and Issuer Purchases of Equity Securities

PART II

Market Information

Our common stock is traded on the Nasdaq Global Market (NASDAQ) under the symbol “STAA.”

Holders

As of February 19, 2021, there were approximately 296 record holders of our Common Stock.

Dividends

We have not paid any cash dividends on our Common Stock since our inception. We currently expect to retain any earnings for use to further develop our
business  and  not  to  declare  cash  dividends  on  our  Common  Stock  in  the  foreseeable  future.  The  declaration  and  payment  of  any  such  dividends  in  the  future
depends upon the Company’s earnings, financial condition, capital needs, and other factors deemed relevant by the Board of Directors and may be restricted by
future agreements with lenders.

Stock Performance Graph

This performance graph shall not be deemed “filed” for purposes of Section 18 of the Securities Exchange Act of 1934, as amended (the Exchange Act), or
incorporated  by  reference  into  any  filing  of  STAAR  Surgical  Company  under  the  Securities  Act  of  1933,  as  amended,  or  the  Exchange  Act,  except  as  shall  be
expressly set forth by specific reference in such filing.

The following graph shows a comparison from January 1, 2016 to January 1, 2021 of the total performance of the following:

•

•

STAAR Surgical Company;

the Nasdaq Stock Market;

28

 
 
•

a peer group we have selected based on data and advice provided by the Radford Group, consisting of the following 16 companies:

Angio Dynamics (ANGO)
Anika Therapeutics (ANIK)
AtriCure (ATRC)
Atrion (ATRI)
AxoGen (AXGN)
Cardiovascular Systems (CSII)
CryoLife (CRY)
Glaukos (GKOS)

Inogen (INGN)
LeMaitre Vascular (LMAT)
Merit Medical Systems (MMSI)
Nevro (NVRO)
Penumbra (PEN)
Surmodics (SRDX)
Tactile Systems Technology (TCMD)
Tandem Diabetes Care (TNDM)

Returns in the graph below reflect historical results; we do not intend to suggest they predict future performance. The data assumes $100 was invested on
January 1, 2016 in STAAR common stock and in each of the composite indices, and that dividends (if any) were reinvested. We have never paid dividends on our
common stock and have no present plans to do so.

Prepared by Zacks Investment Research, Inc. Used with Permission. All rights reserved.

Total Returns Index for Fiscal Years:
STAAR Surgical Company
The Nasdaq Stock Market (US and
   Foreign Companies)
Peer Group

2015

2016

2017

2018

2019

100.00     

151.96     

217.09     

437.82     

481.52     

2020
1,109.55 

100.00     
100.00     

108.81     
126.39     

140.76     
162.50     

135.57     
189.32     

186.47     
220.15     

266.23 
267.88

Notes:

A.

B.

C.

D.

The lines represent monthly index levels derived from compounded daily returns that include all dividends.

These indexes are reweighted daily, using the market capitalization from the previous trading day.

If the monthly interval, based on the fiscal year-end, is not a trading day, the preceding trading day is used.

The index level for all series was set to $100.00 on January 1, 2016.

29

 
 
 
 
 
 
   
   
   
   
   
 
   
   
   
 
 
 
 
 
 
ITEM 6.

Selected Financial Data

The following table sets forth selected consolidated financial data with respect to the five most recent fiscal years ended January 1, 2021, January 3, 2020,
December 28, 2018, December 29, 2017 and December 30, 2016. The selected Consolidated Statement of Operations data set forth below for each of the three
most  recent  fiscal  years,  and  the  selected  Consolidated  Balance  Sheet  data  set  forth  below  at  January  1,  2021  and  January  3,  2020  are  derived  from  our
Consolidated Financial Statements, which have been audited by BDO USA, LLP, our independent registered public accounting firm, as indicated in their report
included  in  this  Annual  Report.  The  selected  Consolidated  Statement  of  Operations  data  set  forth  below  for  each  of  the  two  fiscal  years  in  the  periods  ended
December 29, 2017 and December 30, 2016 and the Consolidated Balance Sheet data set forth below at December 28, 2018, December 29, 2017 and December 30,
2016 are derived from audited  Consolidated  Financial Statements  of the Company not included in this Annual Report. The selected  consolidated financial  data
should be read in conjunction with the Consolidated Financial Statements of the Company, and the Notes thereto, included in this Annual Report, and “Item 7.
Management’s Discussion and Analysis of Financial Condition and Results of Operations.”

January 1,
2021

January 3,
2020(2)

December 28,
2018(1)
(In thousands except per share data)

December 29,
2017(1)

December 30,
2016(1)

Statement of Operations
Net sales
Cost of sales
Gross profit
General and administrative
Selling and marketing
Research and development
Operating income (loss)
Total other income, net
Income (loss) before income taxes
Income tax provision (benefit)
Net income (loss)

Net income (loss) per share:

Basic

Diluted

Weighted average shares outstanding:

Basic
Diluted

Balance Sheet Data
Working capital
Total assets
Long-term obligations
Stockholders’ equity

  $

  $

  $

  $

  $

163,460    $
45,098     
118,362     
33,911     
45,764     
31,918     
6,769     
1,498     
8,267     
2,354     
5,913    $

150,185    $
38,231     
111,954     
29,313     
45,491     
25,298     
11,852     
1,174     
13,026     
(1,022)    
14,048    $

123,954    $
32,444     
91,510     
24,287     
38,600     
22,028     
6,595     
44     
6,639     
1,671     
4,968    $

90,611    $
26,331     
64,280     
19,465     
28,402     
20,044     
(3,631)    
1,335     
(2,296)    
(157)    
(2,139)   $

0.13    $

0.12    $

0.32    $

0.30    $

0.12    $

0.11    $

(0.05)   $

(0.05)   $

45,605     
47,953     

44,493     
46,895     

42,587     
45,257     

41,004     
41,004     

175,182    $
257,416     
18,958     
197,222     

140,188    $
207,523     
13,161     
159,884     

123,844    $
167,253     
7,099     
132,426     

34,802    $
67,973     
5,949     
42,936     

82,432 
24,063 
58,369 
21,671 
28,685 
20,668 
(12,655)
211 
(12,444)
(315)
(12,129)

(0.30)

(0.30)

40,329 
40,329 

28,450 
65,036 
6,064 
37,905

(1)

(2)

The Company adopted ASU 2014-09, “Revenue from Contracts with Customers (Topic 606)” in fiscal 2018 using the modified retrospective  method. As
such, fiscal 2016 through 2017 are presented under the previous revenue recognition standard, i.e. ASC 605.
The Company adopted ASU 2016-02, “Leases (Topic 842)” in fiscal 2019 using the modified retrospective method.  As such fiscal 2016 through 2018 are
presented under the previous lease accounting standard, i.e. ASC 840.

30

 
 
 
 
 
   
   
   
   
 
 
 
 
   
      
      
      
      
  
   
   
   
   
   
   
   
   
   
   
      
      
      
      
  
   
      
      
      
      
  
   
   
   
      
      
      
      
  
   
   
   
 
 
ITEM 7.

Management’s Discussion and Analysis of Financial Condition and Results of Operations

The matters addressed in this Item 7 that are not historical information constitute “forward-looking statements” within the meaning of Section 27A of the
Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. Readers can recognize forward-looking statements by
the use of words like “anticipate,” “estimate,” “expect,” “intend,” “plan,” “believe,” “will,” “should,” “forecast” and similar expressions in connection with
any  discussion  of  future  operating  or  financial  performance.  In  particular,  these  include  statements  about  any  of  the  following:  any  guidance  as  to  earnings,
revenue, sales, profit margins, expense rate, cash, effective tax rate, capital expense or any other financial items; the expected impact of the COVID-19 pandemic
and related public health measures (including but not limited to their impact on sales, operations or clinical trials globally), the plans, strategies, and objectives of
management for future operations or prospects for achieving such plans; statements regarding new, existing, or improved products, including but not limited to,
expectations  for  success  of  new,  existing,  and  improved  products  in  the  U.S.  or  international  markets  or  government  approval  of  a  new  or  improved  products
(including the EVO family of lenses in the U.S. and the EVO Viva family of lenses for presbyopia internationally); commercialization of new or improved products;
future  economic  conditions  or  size  of  market  opportunities;  expected  costs  of  operations;  statements  of  belief,  including  as  to  achieving  2021  business  plans;
expected regulatory activities and approvals, product launches, and any statements of assumptions underlying any of the foregoing.

Although we believe that the expectations reflected in these forward-looking statements are reasonable, such statements are inherently subject to risks and
we  can  give  no  assurance  that  our  expectations  will  prove  to  be  correct.  Actual  results  could  differ  from  those  described  in  this  report  because  of  numerous
factors, many of which are beyond our control. These factors include, without limitation, those described in this Annual Report in “Item 1A. Risk Factors.” We
undertake  no  obligation  to  update  these  forward-looking  statements  after  the  date  of  this  report  to  reflect  future  events  or  circumstances  or  to  reflect  actual
outcomes.

The following discussion should be read in conjunction with the audited consolidated financial statements of STAAR, including the related notes, provided in

this report.

Overview

STAAR Surgical  Company designs, develops, manufactures,  and sells implantable  lenses for the eye and companion delivery  systems used to deliver  the
lenses into the eye. We are the world’s leading manufacturer of intraocular lenses for patients seeking lens-based refractive vision correction, and we also make
lenses for use in surgery to treat cataracts. All the lenses we make are foldable, which allows the surgeon to insert them into the eye through a small incision during
minimally invasive surgery. Refractive surgery is performed to treat the type of visual disorders that have traditionally been corrected using eyeglasses or contact
lenses. We refer to our lenses used in refractive surgery as “implantable Collamer® lenses” or “ICLs.” The field of refractive surgery includes both lens-based
procedures,  using  products  like  our  ICL  family  of  products,  and  laser-based  procedures  like  LASIK.  Successful  refractive  surgery  can  correct  common  vision
disorders such as myopia, hyperopia, and astigmatism. Cataract surgery is a common outpatient procedure where the eye’s natural lens that has become cloudy
with  age  is  removed  and  replaced  with  an  artificial  lens  called  an  intraocular  lens  (IOL)  to  restore  the  patient’s  vision.  STAAR  employs  a  commercialization
strategy that strives for increased share of the refractive market and sustainable profitable growth. Our goal is to position our refractive lenses throughout the world
as primary and premium solutions for patients seeking visual freedom from wearing eyeglasses or contact lenses while achieving excellent visual acuity through
refractive vision correction. We position our IOL lenses used in surgery that treats cataracts based on quality and value.

See Item 1.  “Business,” for a discussion of:

•

•

•

•

•

•

Operations

Principal Products

Distribution and Customers

Competition

Regulatory Matters

Research and Development

31

 
 
 
 
 
 
Strategic Priorities for 2021

For 2021 we intend to continue achieving and strengthening our 2020 strategic priorities, which are as follows:

•

•

•

•

•

•

Position EVO Implantable Lenses as a Special and Transformational Pathway to Visual Freedom;

Execute Go-to-Market Strategy to Significantly Expand Market Share Globally;

Innovate and Develop a Pipeline of Next Generation Premium Collamer-Based Intraocular Lenses;

Support the Transformation of the Refractive Surgery Paradigm to Lens-Based through Clinical Validation and Medical Affairs Excellence;

Continue our Focus on and Commitment to STAAR’s Culture of Quality; and

Deliver Shareholder Value.

To realize these priorities, we are planning to:

•

•

•

•

Continue  to  invest  in  manufacturing  and  facilities  expansion  that  include,  among  other  things:  (i)  increasing  manufacturing  capacity  at  our
Monrovia, California facility for our myopia ICLs; (ii) reopening and expanding our manufacturing and distribution facilities in Switzerland; and
(iii) preparing for the validation of our Lake Forest, California facility for the manufacturing of our EVO Viva for presbyopia lenses;

Continue market share gains in all global markets, including China.  We will continue to focus on increasing consideration and usage of low and
mid-diopter ICLs;

Continue to increase investment in Direct-to-Consumer marketing and patient education in targeted markets; and

Continue to strengthen existing and finalize new strategic agreements and alliances with global partners.

Finally, we will continue to evaluate opportunities to acquire new product lines, technologies, and companies.

We continue to assess and manage through the potential impact of COVID-19, which remains uncertain at this time and may adversely affect our financial

results. For example, we continue to monitor the commercial and operational impact of new variants of COVID-19 in our markets.

Results of Operations

The following table sets forth the percentage of total sales represented by certain items reflected in the Company’s Consolidated Statement of Income for the

period indicated.  

Net sales
Cost of sales
Gross profit
General and administrative
Selling and marketing
Research and development
Total selling, general and administrative
Operating income
Total other income, net
Income before income taxes
Provision (benefit) for income taxes
Net income

2020

Percentage of Net Sales
2019

2018

100.0% 
27.6% 
72.4% 
20.7% 
28.0% 
19.6% 
68.3% 
4.1% 
0.9% 
5.0% 
1.4% 
3.6% 

100.0%  
25.5%  
74.5%  
19.5%  
30.3%  
16.8%  
66.6%  
7.9%  
0.8%  
8.7%  
(0.7)%  
9.4%  

100.0%
26.2%
73.8%
19.6%
31.1%
17.8%
68.5%
5.3%
0.0%
5.3%
1.3%
4.0%

32

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net Sales  

The following table presents our net sales, by product for the fiscal years presented (dollars in thousands):

ICLs
Other product sales

IOLs
Other surgical products

Total other product sales

Net sales

2020

2019

2018

% of
Total

86.5%  $

Sales
141,407     

% of
Total

86.1%  $

Sales
129,322     

% of
Total

81.5%  $

Sales
101,082 

8.3%   
5.2%   
13.5%   
100.0%  $

13,574     
8,479     
22,053     
163,460     

10.5%   
3.4%   
13.9%   
100.0%  $

15,689     
5,174     
20,863     
150,185     

13.1%   
5.4%   
18.5%   
100.0%  $

16,193 
6,679 
22,872 
123,954

Net sales for 2020 were $163.5 million, a 9% increase from $150.2 million reported in fiscal 2019. The increase in net sales was due to increased ICL sales

of $12.1 million and in other product sales of $1.2 million. Changes in foreign currency favorably impacted net sales by $1.5 million.

Net sales for 2019 were $150.2 million, a 21% increase over the $124.0 million reported in fiscal 2018. The increase in net sales was due to increased ICL
sales of $28.2 million, partially offset by a decrease in other product sales of $2.0 million. Changes in foreign currency unfavorably impacted net sales by $1.3
million.

Total ICL sales for 2020 were $141.4 million, a 9% increase from $129.3 million reported for fiscal 2019, with unit growth up 11%. The sales increase was
driven by the APAC region, which grew 15% with unit growth of 17%, primarily due to sales growth in Japan up 56%, other APAC Distributors up 38%, Korea up
17% and China up 11%.  The Europe, Middle East, Africa and Latin America region sales decreased 3% and units decreased 11%, as a result of decreased sales in
the  Middle  East  down  35%,  Latin  America  down  13%  and  Spain  down  4%,  partially  offset  by  sales  growth  in  Germany  up  15%,  the  U.K.  up  8%  and  Other
Distributors up 4%.  The North America region sales decreased 14% and units decreased 12%, mainly due to decreased sales in the U.S. down 17%, slightly offset
by sales growth in Canada up 2%.  The decreases in these various regions were impacted by the COVID-19 pandemic in the first half of 2020; most markets started
to reopen in mid-May/early June, with India and the Middle East being the two markets that remained the most challenged by COVID-19 during the second half of
2020.  Changes in foreign currency favorably impacted ICL sales by $1.0 million.  ICL sales represented 86.5% of our total sales for fiscal year 2020.

Total ICL sales for 2019 were $129.3 million, a 28% increase from $101.1 million reported for fiscal 2018, with unit growth up 33%. The sales increase was
driven by the APAC region, which grew 40% with unit growth of 44%, primarily due to sales growth in Japan up 67%, China up 41%, Korea up 26%, other APAC
Distributors up 16% and India up 12%.  The Europe, Middle East, Africa and Latin America region, grew 2% with unit growth of 7%, primarily due to increased
sales in UK up 19%, Germany up 9% and Spain up 7%, partially offset by decreased sales in the Middle East of 9% and Latin America of 8%.  The North America
region grew 18%, with unit growth of 4%, primarily due to growth in the U.S., as a result of sales of the Toric ICL in 2019, partially offset by decreased sales in
Canada.  Changes in foreign currency unfavorably impacted ICL sales by $1.3 million.  ICL sales represented 86.1% of our total sales for fiscal year 2019.

Other  product  sales,  including  IOLs  were  $22.1  million  for  fiscal  2020,  an  increase  of  6%  from  $20.9  million  reported  in  fiscal  2019,  due  to  increased
preloaded  injector  part  sales  to  a  third-party  manufacturer  for  product  they  sell  to  their  customers,  partially  offset  by  decreased  IOL  sales.  Changes  in  foreign
currency favorably impacted other product sales by $0.5 million. Other product sales represented 13.5% of our total sales for fiscal year 2020.

Other  product  sales,  including  IOLs  were  $20.9  million  for  fiscal  2019,  a  decrease  of  9%  from  $22.9  million  reported  in  fiscal  2018,  due  to  decreased
preloaded injector part sales to a third-party manufacturer for product they sell to their customers and in IOL sales.  Other product sales represented 13.9% of our
total sales for fiscal year 2019.

33

 
 
 
 
   
   
 
 
 
 
 
   
 
 
   
 
 
 
   
   
  
   
      
  
   
      
  
   
  
   
   
   
   
 
 
Gross Profit  

The following table presents our gross profit and gross profit margin for the fiscal years presented (dollars in thousands):

Gross profit
Gross margin

2020

2019

2018

  2020 vs. 2019  

  2019 vs. 2018  

  $

118,362 

  $
72.4%   

111,954 

  $
74.5%   

91,510 

73.8%   

5.7%   

22.3%

Percentage Change

Gross profit for 2020 was $118.4 million, a 5.7% increase compared to the $112.0 million reported for 2019.  Gross profit margin decreased to 72.4% of
revenue for 2020 compared to 74.5% of revenue for 2019, due to geographic sales mix, $1.2 million in expenses related to the COVID-19 manufacturing pause
from March 17 through April 27, 2020, period costs associated with the manufacturing expansion projects and increased mix of injector part sales which carry a
lower margin, partially offset by increased ICL volume.

Gross profit for 2019 was $112.0 million, a 22.3% increase compared to the $91.5 million reported for 2018.  Gross profit margin increased to 74.5% of
revenue for 2019 compared to 73.8% of revenue for 2018, due to favorable product mix resulting from increased sales of ICLs, partially offset by period costs
associated with the project to resume manufacturing in Switzerland.  The gross margin impact of lower average selling prices was more than offset by the favorable
impact of improved product mix.

General and Administrative Expense  

The following table presents our general and administrative expense for the fiscal years presented (dollars in thousands):

General and administrative expense
Percentage of sales

2020

2019

2018

  2020 vs. 2019  

  2019 vs. 2018  

  $

33,911 

  $
20.7%   

29,313 

  $
19.5%   

24,287 

19.6%   

15.7%   

20.7%

Percentage Change

General  and  administrative  expenses  for  2020  were  $33.9  million,  an  increase  of  15.7%  when  compared  with  $29.3  million  reported  for  2019,  due  to

increased salary-related expenses, tax consulting, variable compensation, corporate insurance and facility costs, slightly offset by decreased travel expenses.

General  and  administrative  expenses  for  2019  were  $29.3  million,  an  increase  of  20.7%  when  compared  with  $24.3  million  reported  for  2018,  due  to

increased headcount and salary-related expenses including stock-based compensation, facility costs and professional fees.

Selling and Marketing Expense  

The following table presents our marketing and selling expense for the fiscal years presented (dollars in thousands):

Selling and marketing expenses
Percentage of sales

2020

2019

2018

  2020 vs. 2019  

  2019 vs. 2018  

  $

45,764 

  $
28.0%   

45,491 

  $
30.3%   

38,600 

31.1%   

0.6%   

17.9%

Percentage Change

Selling and marketing expenses for 2020 were $45.8 million, an increase of 0.6% when compared with $45.5 million for 2019, due to increased advertising

and promotional activities, salary-related expenses and variable compensation, offset by decreased trade shows and travel expenses.

Selling and marketing expenses for 2019 were $45.5 million, an increase of 17.9% when compared with $38.6 million for 2018, due to increased headcount
and  salary-related  expenses  including  stock-based  compensation  and  continued  investments  in  digital,  consumer,  and  strategic  marketing,  and  increased  travel
expenses.

34

 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
 
 
 
   
   
  
   
 
 
 
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
 
 
 
   
   
  
   
 
 
 
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
 
 
 
   
   
  
   
 
 
 
Research and Development Expense  

The following table presents our research and development expense for the fiscal years presented (dollars in thousands):

Research and development expense
Percentage of sales

2020

2019

2018

  2020 vs. 2019  

  2019 vs. 2018  

  $

31,918 

  $
19.6%   

25,298 

  $
16.8%   

22,028 

17.8%   

26.2%   

14.8%

Percentage Change

Research  and  development  expenses  for  2020  were  $31.9  million,  an  increase  of  26.2%  compared  to  $25.3  million  for  2019  primarily  due  to  increased
clinical expenses associated with our EVO clinical trial in the U.S., and increased salary-related expenses and variable compensation, partially offset by decreased
travel expenses.

Research and development expenses for 2019 were $25.3 million, an increase of 14.8% compared to $22.0 million for 2018, due to increased headcount and
salary-related expenses including stock-based compensation, and clinical expenses associated with our EDOF clinical trial in Europe and EVO clinical trial in the
U.S.

Research and development expense consist primarily of compensation and related costs for personnel responsible for the research and development of new
and existing products, the regulatory and clinical activities required to acquire and maintain product approvals globally and medical affairs expenses. These costs
are expensed as incurred.

Other Income, Net  

The following table presents our other income, net for the fiscal years presented (dollars in thousands):

Percentage Change

Other income, net
Percentage of sales

*

Denotes change is greater than +100%.

  $

1,498 

 $
0.9%   

1,174 

  $
0.8%   

44 
0.0%   

2020

2019

2018

  2020 vs. 2019  

  2019 vs. 2018  
—* 

27.6%   

Other income for 2020, 2019 and 2018 was $1.5 million, $1.2 million and $0.0 million, respectively. The increase for 2020 is mainly due to increased foreign
exchange  gains  (primarily  euro),  partially  offset  by  decreased  net  interest  income,  as  a  result  of  lower  interest  rates.    The  increase  in  2019  is  mainly  due  to
increased interest income earned on cash and cash equivalents and decreased foreign exchange losses (primarily euro).

Other income, net generally relates to interest income earned on cash and cash equivalents, interest expense on notes payable and finance lease obligations,

gains or losses on foreign currency transactions, and royalty income. The table below summarizes the year over year changes in other income, net (in thousands).

Interest income (expense), net
Foreign exchange
Royalty income
Other

Net change in other income, net

Provision (Benefit) for Income Taxes  

Favorable (Unfavorable)

2020 vs. 2019

2019 vs. 2018

  $

  $

(750)   $
1,381   
(111)  
(196)  
324    $

823 
319 
(82)
70 
1,130

The following table presents our provision (benefit) for income taxes for the fiscal years presented (in thousands):

2020

2019

2018

Provision (benefit) for income taxes

  $

2,354    $

(1,022)   $

*

Denotes change is greater than +100%.

35

Percentage Change
    2020 vs. 2019     2019 vs. 2018  
—*
—*     

1,671     

 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
 
 
 
   
   
  
   
 
 
 
 
 
   
 
 
   
 
 
   
 
 
 
 
 
 
 
 
 
 
 
  
   
  
  
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
     
 
     
 
   
 
 
 
   
   
 
 
We recorded income taxes of $2.4 million for 2020 due to pre-tax income generated in certain foreign jurisdictions, which included a release of $0.5 million
of our U.S. valuation allowance, as a result of increases in foreign income and changes in the usage and release of our deferred tax assets. We recorded an income
tax benefit for 2019 due to a release of the federal and certain state valuation allowances, offset by the income tax expense from profits generated in our Swiss and
Japan operations.  We recorded income taxes for 2018 as a result of income tax expense generated primarily from profits in our Swiss and Japan operations and
U.S. withholding taxes on those profits.  During 2020, 2019 and 2018, there are no unrecognized tax benefits related to uncertain tax positions taken by us. 

All earnings from our subsidiaries are not considered to be permanently reinvested.  Accordingly, we provided withholding and U.S. taxes on all unremitted
foreign  earnings  through  2018.    Beginning  2019,  we  no  longer  need  to  accrue  withholding  taxes  on  foreign  earnings  (Note  10  to  the  Consolidated  Financial
Statements).  During 2020, 2019 and 2018 there were no withholding taxes paid to foreign jurisdictions.

On December 22, 2017, the United States enacted major tax reform legislation, the 2017 Tax Act, which enacted a broad range of changes to the federal tax
code. Key provisions that could have an impact on our Consolidated Financial Statements are the deemed repatriation of foreign earnings, the re-measurement of
certain net deferred assets and other liabilities for the change in the U.S. corporate tax rate from 35 percent to 21 percent, and the elimination of the AMT.  

We applied the guidance in SAB 118 when accounting for the enactment-date effects of the 2017 Tax Act and throughout 2018. At that time, for 2017, we
made reasonable estimates of the impact and included $5.7 million in foreign earnings, which were fully offset by the deemed foreign tax credit. This inclusion
amount was later finalized at $7.5 million. At December 28, 2018, we completed our accounting for all the enactment-date income tax effects of the 2017 Tax Act.

Beginning  in  2018,  the  2017  Tax  Act  subjects  a  U.S.  shareholder  to  tax  on  Global  Intangible  Low  Tax  Income  (GILTI)  earned  by  certain  foreign
subsidiaries.  In January 2018, the FASB released guidance (Staff Q&A Topic 740, No. 5) on the accounting for tax on the GILTI provisions of the 2017 Tax
Act.    In  general,  GILTI  is  the  excess  of  a  U.S.  shareholder’s  total  net  foreign  income  over  a  deemed  return  on  tangible  assets.  The  provision  further  allows  a
deduction of 50 percent of GILTI, however this deduction is limited by our net operating loss carryforwards.  For 2020, 2019 and 2018, we included GILTI of
$21.3 million, $15.1 million and $7.7 million, respectively, in U.S. gross income, which was fully offset with net operating loss carryforwards.  

ASC  740  requires  that  a  valuation  allowance  be  established  when  it  is  more  likely  than  not  that  all  or  a  portion  of  a  deferred  tax  asset  may  not  be
realizable.    The  ultimate  realization  of  deferred  tax  assets  is  dependent  upon  future  generation  of  income  during  the  periods  in  which  temporary  differences
representing net future deductible amounts become deductible. We considered the projected future income, tax planning strategies and all other available evidence
in  making  this  assessment.    Since  January  3,  2020,  we  had  at  least  three  years  of  accumulated  profits  for  federal  income  tax  purposes  as  a  result  of
GILTI.  Therefore, based upon our findings that the positive evidence outweighed the negative evidence, sufficient for us to realize the benefit of our deferred tax
assets due to our projected future profits, we reduced the valuation allowance.

Since 2019, we have made a policy election to apply the incremental cash tax savings approach when analyzing the impact GILTI could have on our U.S.
valuation allowance. As a result of future expected GILTI inclusions, and because of the Tax Act’s ordering rules, U.S. companies may now expect to utilize tax
attribute carryforwards (e.g. net operating losses and deferred tax assets) for which a valuation allowance has historically been recorded (this is referred to as the
“tax law ordering approach”). However, due to the mechanics of the GILTI rules, companies that have a GILTI inclusion may realize a reduced (or no) cash tax
savings from utilizing such tax attribute carryforwards (this view is referred to as the “incremental cash tax savings approach”). Applying the incremental cash tax
savings approach, resulted in the valuation allowance release of $3.0 million and $0.4 million for Federal and state purposes, respectively, during 2019.  As a result
of our fiscal 2020 operating results, revising our global forecasts for fiscal 2021 and beyond as a result of COVID-19 in the first quarter of 2020 and changes in the
usage and release of certain deferred tax assets, we recorded a valuation allowance release of $0.6 million against our federal deferred tax assets, and a valuation
allowance release reversal of $0.1 million against certain states deferred tax assets during 2020. The remaining valuation allowance was $34.7 million and $7.4
million for federal and state purposes, respectively, as of January 1, 2021.

36

 
See Critical Accounting Policies included later in this Item 7 for additional information about our provision for income taxes.

A reconciliation of the federal statutory income tax rate to our effective tax rate is set forth in Note 10 of Notes to the Consolidated Financial Statements

included in Item 8 of this Annual Report on Form 10-K.

Liquidity and Capital Resources  

We believe that current cash, cash equivalents and future cash flow from operating activities will be sufficient to meet our anticipated cash needs, including
working capital needs, capital expenditures and contractual obligations for at least 12 months from the issuance date of the financial statements included in this
Annual Report.  Although we have experienced some delays in payments on accounts receivable as a result of the COVID-19 pandemic in the first half of 2020,
this  improved  during  the  second  half  of  2020  as  our  customers  resumed  elective  refractive  surgery.    At  this  time  we  are  unaware  of  any  impairment  of  assets
resulting from the COVID-19 pandemic.  We did not apply for or require financing available under the Coronavirus Aid, Relief, and Economic Security “CARES”
Act and do not expect to do so.  Our financial condition at January 1, 2021, January 3, 2020 and December 28, 2018 included the following (in millions):

Cash and cash equivalents

Current assets
Current liabilities
Working capital

  $

  $

  $

152.5    $

216.4    $
41.2     
175.2    $

120.0    $

174.7    $
34.5     
140.2    $

2020

2019

2018

    2020 vs. 2019     2019 vs. 2018  
16.1 
32.5    $

103.9    $

151.6    $
27.7     
123.9    $

41.7    $
6.7     
35.0    $

23.1 
6.8 
16.3

We invest our net proceeds in short-term interest-bearing obligations, investment-grade instruments, certificates of deposit or direct or guaranteed obligations
of the U.S. government.  Additionally, at January 1, 2021, we have a line of credit with a Japanese lender, in the amount of $1.4 million, with $3.5 million of
availability and a line of credit with a Swiss lender, in the amount of $1.1 million, which is fully available for borrowing.

Overview of changes in cash and cash equivalents and other working capital accounts.  

Net  cash  provided  by  operating  activities  was  $21.0  million,  $25.8  million  and  $12.8  million  for  2020,  2019  and  2018,  respectively.    For  2020,  net  cash
provided  by  operating  activities  consisted  of  $17.8  million  in  non-cash  items  and  $5.9  million  in  net  income,  offset  by  $2.7  million  in  working-capital
changes.  For 2019, net cash provided by operating activities consisted of $14.0 million in net income and $13.0 million in non-cash items, offset by $1.2 million in
working-capital changes.  For 2018, net cash provided by operating activities consisted of $12.3 million in non-cash items and $5.0 million in net income, offset by
$4.5 million in working-capital changes.

Net  cash  used  in  investing  activities  was  $8.4  million,  $10.2  million  and  $2.2  million  for  2020,  2019  and  2018  respectively,  and  relate  primarily  to  the
acquisition of property, plant, and equipment.  The decrease in investment in property, plant and equipment during 2020, relative to 2019, is primarily due to a
slight decrease in investments in manufacturing facilities.  The increase in investment in property, plant and equipment during 2019, relative to 2018, is primarily
due to continued increased investments in manufacturing intending to satisfy growing demand for our products.  

Net  cash  provided  by  financing  activities  was  $19.6  million,  $0.1  million  and  74.6  million  for  2020,  2019  and  2018,  respectively.    For  2020,  net  cash
provided by financing activities consisted of $20.6 million of proceeds from the exercise of stock options, partially offset by $0.6 million repayment of finance
lease obligations and $0.5 million repayment on the Japan line of credit.  For 2019, net cash provided by financing activities consisted of $3.5 million of proceeds
from the exercise of stock options, offset by a $2.0 million repayment on the Japan line of credit and $1.3 million repayment of finance lease obligations.  For
2018, net cash provided by financing activities resulting primarily from the proceeds of $72.2 million from the equity offering (refer to Note 12 to the Consolidated
Financial Statements).  In addition, the increase also consisted of $5.2 million of proceeds from the exercise of stock options, offset by $1.9 million repayment of
finance lease obligations and $0.7 million repayment on the Japan line of credit.  

Accounts receivable, net was $35.2 million and $31.0 million at January 1, 2021 and January 3, 2020, respectively.  Days’ Sales Outstanding (DSO) was 70

and 78 days in 2020 and 2019. The decrease in DSO was mainly due to increased customer collections of receivables in the fourth quarter of 2020.

37

 
 
 
   
   
   
 
 
Inventories, net was $18.1 million and $17.1 million at January 1, 2021 and January 3, 2020, respectively. Days’ Inventory on Hand (DOH) was 114 and 159
days  in  2020 and  2019,  respectively, for  finished  goods,  including  consignment  inventory.    The  decrease  in  DOH  is  due  to  increased  sales  of  ICL  products
resulting in more frequent inventory turnover.

Shelf Registration

On May 6, 2020, STAAR filed a universal shelf registration statement with the SEC covering the future public offering and sale of up to $200 million in
equity  or  debt  securities  or  any  combination  of  such  securities.  The  shelf  registration  statement  became  effective  on  February  22,  2021  and  expires  on
February  22,  2024.    Among  the  purposes  for  which  STAAR  could  use  the  proceeds  of  securities  sold  in  the  future  under  the  shelf  registration  statement  are
working  capital,  capital  expenditures,  expansion  of  sales  and  marketing,  and  continuing  research  and  development.  STAAR could  also  use  a  portion  of  the  net
proceeds to acquire or invest in businesses, assets, products, and technologies that are complementary to our own, although we are not currently contemplating or
negotiating any such acquisitions or investments. The availability  of financing in the public capital markets through the shelf registration statement depends on
several factors in place at the time of financing, including the strength of STAAR’s business performance, general economic conditions and investment climate,
and investor perceptions of those factors. If STAAR seeks financing under the shelf registration statement in the future, we cannot assure that such financing will
be available on favorable terms, if at all.

Credit Facilities, Lease Line of Credit, Contractual Obligations, and Commitments

Credit Facilities

We have credit facilities with different lenders to support operations as detailed below.

Lines of Credit

Since  1998,  our  wholly  owned  Japanese  subsidiary,  STAAR  Japan,  has  had  an  agreement  with  Mizuho  Bank  which  provides  for  borrowings  of  up  to
500,000,000 Yen, at an interest rate equal to the uncollateralized overnight call rate (approximately 0.07% as of January 1, 2021) plus a 0.50% spread, and may be
renewed  quarterly  (the  current  line  expires  on  February  21,  2021).    The  credit  facility  is  not  collateralized.    We  had  142,500,000  Yen  and  197,500,000  Yen
outstanding on the line of credit as of January 1, 2021 and January 3, 2020, respectively, (approximately $1,379,000 and $1,827,000 based on the foreign exchange
rates on January 1, 2021 and January 3, 2020, respectively), which approximates fair value due to the short-term maturity and market interest rates of the line of
credit.  In case of default, the interest rate will be increased to 14% per annum. There was 357,500,000 Yen and 302,500,000 Yen available for borrowing as of
January  1,  2021  and  January  3,  2020,  respectively  (approximately  $3,459,000  and  $2,798,000  based  on  the  foreign  exchange  rate  on  January  1,  2021  and
January 3, 2020, respectively).  At maturity on February 21, 2021, this line of credit was renewed until May 21, 2021, with similar terms.

In September 2013, our wholly owned Swiss subsidiary, STAAR Surgical AG, entered into a framework agreement for loans (“framework agreement”) with
Credit Suisse (the “Bank”). The framework agreement provides for borrowings of up to 1,000,000 CHF (Swiss Francs) (approximately $1,100,000 and $1,000,000
million  at  the  rate  of  exchange  on  January  1,  2021  and  January  3,  2020,  respectively),  to  be  used  for  working  capital  purposes.  Accrued  interest  and  0.25%
commissions  on average  outstanding  borrowings  is payable  quarterly  and  the interest  rate  will  be determined  by the  Bank based  on the  then prevailing  market
conditions at the time of borrowing. The framework agreement is automatically renewed on an annual basis based on the same terms assuming there is no default.
The framework agreement may be terminated by either party at any time in accordance with its general terms and conditions. The framework agreement is not
collateralized and contains certain conditions such as providing the Bank with audited financial statements annually and notice of significant events or conditions,
as defined in the framework  agreement.  The Bank may  also declare  all amounts  outstanding  to be immediately  due and payable upon a change of control or a
“material qualification” in STAAR Surgical independent auditors’ report, as defined. There were no borrowings outstanding as of January 1, 2021 and January 3,
2020.

Covenant Compliance

We are in compliance with the covenants of our credit facilities and lines of credit as of January 1, 2021.

38

Lease Line of Credit (Finance Leases)

During 2019, we converted the lease line of credit schedule 011 with Farnam Street Financial, Inc. into a finance lease liability of approximately $500,000.

Contractual Obligations  

The following table represents the Company’s known contractual obligations as of January 1, 2021 (in thousands):

Contractual Obligations
Line of credit (Note 8)*
Finance lease obligations (Note 9)*
Operating lease obligations (Note 9)*
Pension benefit payments (Note 11)*
Asset retirement obligation (Note 13)*
Open purchase orders (Note 13)*
Total

Total

1 Year

Payments Due by Period
2 – 3
Years

4 – 5
Years

More than
5 Years

  $

  $

1,379    $
405     
9,462     
11,940     
221     
8,446     
31,853    $

1,379    $
366     
2,682     
176     
221     
8,154     
12,978    $

—    $
35     
4,023     
485     
—     
280     
4,823    $

—    $
4     
1,432     
637     
—     
12     
2,085    $

— 
— 
1,325 
10,642 
— 
— 
11,967

*

Refer to the Notes to the Consolidated Financial Statements in this Annual Report on Form 10-K

Critical Accounting Policies  

The preparation of financial statements in accordance with accounting principles generally accepted in the United States of America requires management to
make significant estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of
the financial statements and the reported amounts of sales and expenses during the reporting period. On an on-going basis, we evaluate our estimates, including
those related to revenue recognition, allowances for doubtful accounts and sales returns, inventory reserves and income taxes, among others.  Our estimates are
based on historical experiences, market trends and financial forecasts and projections, and on various other assumptions that management believes are reasonable
under  the  circumstances  and  at  that  certain  point  in  time.  Actual  results  may  differ,  significantly  at  times,  from  these  if  actual  conditions  differ  from  our
assumptions.

We believe the following represent our critical accounting policies.

Revenue Recognition

We  recognize  revenue  when  our  contractual  performance  obligations  with  customers  are  satisfied.    Our  performance  obligations  are  generally  limited  to
single sales orders with product shipping to the customer within a month of receipt of the sales order.  Substantially all of our revenues are recognized at a point-in-
time when control of our products transfers to the customer, which is typically upon shipment (as discussed below).  We present sales tax and similar taxes we
collect from our customers on a net basis (excluded from revenues).

We sell certain injector parts to an unrelated customer and supplier (collectively referred to as “supplier”) whereby these injector part sales are either made as
a final sale to the supplier or, are sold to be combined with an acrylic IOL by the supplier into finished goods inventory (a preloaded acrylic IOL).  These finished
goods are then sold back to us at an agreed upon, contractual price.  We make a profit margin on either type of sale with the supplier and each type of sale is made
under separate purchase and sales orders between the two parties resulting in cash settlement for the orders sold or repurchased.  For parts that are sold as a final
sale, we recognize a sale and those sales are classified as other product sales in total net sales.  For the injector parts that are sold to be combined with an acrylic
IOL into finished goods, we record the transaction at its carrying value deferring any profit margin as contra-inventory, until the finished goods inventory is sold to
an end-customer (not the supplier) at which point we recognize revenues.

For  all  sales,  we  are  considered  the  principal  in  the  transaction  as  we  are  the  party  providing  specified  goods  under  our  control  prior  to  when  control  is
transferred to the customer.  Cost of sales includes cost of production, freight and distribution, and inventory provisions, net of any purchase discounts.  Shipping
and handling activities that occur after the customer obtains control of the goods are recognized as fulfillment costs.

39

 
 
 
 
 
   
   
   
   
 
   
   
   
   
   
 
 
Non-consignment sales  

We recognize revenue from non-consignment product sales at a point-in-time when control has been transferred, which is typically at shipping point, except
for  certain  customers  and  for  our  STAAR  Japan  subsidiary,  which  is  typically  recognized  when  the  customer  receives  the  product.    We  generally  do  not  have
significant deferred revenue as delivery to the customer is generally made within the same or the next day of shipment.

We  also  enter  into  certain  strategic  cooperation  agreements  with  customers  in  which,  as  consideration  for  certain  commitments  made  by  the  customer,
including minimum purchase commitments, we agree, among other things, to pay for marketing, educational training and general support of our products.  The
provisions  in  these  arrangements  allow  for  these  payments  to  be  made  directly  to  the  customer  or  payments  can  be  made  directly  to  a  third  party  for  distinct
marketing, educational training and general support services provided to or on behalf of the customer by the third party.  For payments we make to another party,
or reimburse the customer for distinct marketing and support services, we recognize these payments as sales and marketing expense as incurred.  These strategic
cooperation  agreements  are  generally  for  periods  of  12  months  or  more  with  quarterly  minimum  purchase  commitments.    We  recognize  sales  and  marketing
expenses in the period in which it expects the customer will achieve its minimum purchase commitment, generally quarterly, and any unpaid amounts are recorded
in Other Current Liabilities in “Other” on the Consolidated Balance Sheets, see Note 7 to the Consolidated Financial Statements.  Reimbursements made directly to
the  customer  for  general  marketing  incentives  are  treated  as  a  reduction  in  revenues.    Our  performance  obligations  generally  occur  in  the  same  quarter  as  the
shipment of product.  

Since the payments for distinct or non-distinct services occur within the quarter corresponding with the purchases made by the customer and our shipments to

that customer, there is no remaining performance obligation.  Accordingly, there are no deferred revenues associated with these types of arrangements.  

Consignment Sales

Our products are marketed to ophthalmic surgeons, hospitals, ambulatory surgery centers or vision centers, and distributors. IOLs and ICLs may be offered to
surgeons and hospitals on a consignment basis.  We maintain title and risk of loss on consigned inventory and recognize revenue for consignment inventory at a
point-in-time when we are notified that the lenses have been implanted, thus completing the performance obligation.

Sales Return Reserves

Generally, we may permit returns of product if the product, upon issuance of a Returned Goods Authorization, is returned within the time allowed by our
return policies, and in good condition. We provide allowances for sales returns such that returns are matched against the sales from which they originated. While
such allowances have historically been within our expectations, we cannot guarantee that we will continue to experience the same return rates that we have in the
past.  Measurement of such returns, is based on an expected loss model which requires consideration of, among other factors, historical returns experience and
current/anticipated trends, including the need to adjust for current conditions and product lines, the entry of a competitor, and judgments about the probable effects
of  relevant  observable  data.  We  consider  all  available  information  in  our  quarterly  assessments  of  the  adequacy  of  the  allowance  for  sales  returns.    Sales  are
reported net of estimated returns.  If the actual sales returns are higher or lower than estimated by management, additional reduction or increase in sales may occur.

Allowance for Doubtful Accounts

We maintain provisions for uncollectible accounts based on estimated losses resulting from the inability of our customers to remit payments. If the financial
condition of customers were to deteriorate, thereby resulting in an inability to make payments, additional allowances could be required. We perform ongoing credit
evaluations  of  our  customers  and  adjust  credit  limits  based  upon  customer  payment  history  and  current  creditworthiness,  as  determined  by  our  review  of  our
customers’ current credit information. We continuously monitor collections and payments from our customers and maintain a provision for estimated credit losses
based upon our historical experience and any specific customer collection issues that have been identified. We write off amounts determined to be uncollectible
against  the  allowance  for  doubtful  accounts.  While  such  credit  losses  have  historically  been  within  our  expectations  and  the  provisions  established,  we  cannot
guarantee that we will continue to experience the same credit loss rates that we have in the past. Measurement of such losses, is based on an expected loss model
which requires consideration of historical loss experience, including the need to adjust for current conditions, and judgments about the probable effects of relevant
observable data, including present economic conditions such as delinquency rates and financial health of specific customers. We consider all available information
in our assessments of the adequacy of the reserves for uncollectible accounts.

40

Stock-Based Compensation

We account for the issuance of stock options to employees and directors by estimating the fair value of options issued using the Black-Scholes pricing model.
This  model’s  calculations  include  the  exercise  price,  the  market  price  of  shares  on  grant  date,  risk-free  interest  rates,  expected  term  of  the  option,  expected
volatility of our stock and expected dividend yield.  The amounts recorded in the financial statements for share-based compensation could vary significantly if we
were to use different assumptions.  We also issue restricted stock units (“RSUs”) and performance stock units (“PSUs”) which contain a service condition such that
they vest if the grantee is still employed with us on a range of measurement dates, which are typically three years after the grant date.  On occasion, we also issue
RSUs and PSUs to certain employees  which contain a performance  condition such that they vest if the internally established  target  is met or exceeded and the
grantee is still employed with us on the measurement date, which is typically one year after the grant date.  We recognize compensation cost for the RSUs and
PSUs when it is probable that the performance condition will be achieved, net of an estimate of pre-vesting forfeitures, over the requisite service period based on
the  grant-date  fair  value  of  the  stock.    We  reassess  the  probability  of  vesting  at  each  reporting  period  and  adjust  compensation  cost  based  on  our  probability
assessment.

Income Taxes

We  account  for  income  taxes,  on  a  jurisdiction-by-jurisdiction  basis,  under  the  asset  and  liability  method,  whereby  deferred  tax  assets  and  liabilities  are
recognized for the future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their
respective tax bases. Deferred tax assets and liabilities are measured using enacted tax rates expected to apply in the years in which those temporary differences are
expected to be recovered or settled in the jurisdictions in which they arise. The effect on deferred tax assets and liabilities of a change in tax rates is recognized in
income  in  the  period  that  includes  the  enactment  date.  We  evaluate  the  need  to  establish  a  valuation  allowance  for  deferred  tax  assets  based  on  the  amount  of
existing  temporary  differences,  the  period  in  which  they  are  expected  to  be  recovered  and  expected  levels  of  taxable  income.  A  valuation  allowance  to  reduce
deferred tax assets is established when it is more likely than not that some or all the deferred tax assets will not be realized.  We have made a policy election to
apply the incremental cash tax savings approach when analyzing the impact GILTI could have on our U.S. valuation allowance assessment.

In many countries, including the U.S., we are subject to transfer pricing and other tax regulations designed to ensure that appropriate levels of income are
reported as earned by our U.S. and foreign entities and are taxed accordingly.  In the normal course of business, we are audited by federal, state and foreign tax
authorities, and subject to inquiries from those tax authorities regarding the amount of taxes due. These inquiries may relate to the timing and amount of deductions
and the allocation of income among various tax jurisdictions. We believe that our tax positions comply with applicable tax law and intend to defend our positions,
if necessary.

Inventories

We provide estimated inventory allowances for excess, slow moving, expiring and obsolete inventory as well as inventory whose carrying value is more than
net  realizable  value.  These  reserves  are  based  on  current  assessments  about  future  demands,  market  conditions  and  related  management  initiatives.  If  market
conditions and actual demands are less favorable than those projected by management, additional inventory write-downs may be required. We value our inventory
at the lower of cost or net realizable market values. We regularly review inventory quantities on hand and record a provision for excess and obsolete inventory
based primarily on the expiration of products with a shelf life of less than four months, estimated forecasts of product demand and production requirements for the
next twelve months. Several factors may influence the realizability of our inventories, including decisions to exit a product line, technological change, and new
product development. These factors could result in an increase in the amount of obsolete inventory quantities on hand. Additionally, estimates of future product
demand may prove to be inaccurate, in which case the provision required for excess and obsolete inventory may be understated or overstated. If in the future, we
determine  that  our  inventory  was overvalued,  we  would  be  required  to  recognize  such  costs  in  cost  of sales  at  the  time  of  such determination.  Likewise,  if  we
determine that our inventory was undervalued, cost of sales in previous periods could have been overstated and we would be required to recognize such additional
operating  income  at  the  time  of  sale.  While  such  inventory  losses  have  historically  been  within  our  expectations  and  the  provisions  established,  we  cannot
guarantee that we will continue  to experience the same loss rates that we have in the past. Therefore, although we make every effort  to ensure the accuracy of
forecasts  of future product demand, including  the impact  of planned future product launches, any significant  unanticipated  changes in demand or technological
developments could have a significant impact on the value of our inventory and our reported operating results.

41

Lease Accounting

We recognize right-of-use (“ROU”) assets and lease liabilities for leases with terms greater than twelve months.  Leases are classified as either finance or
operating,  with  classification  affecting  the  pattern  of  expense  recognition.    Certain  leases  may  have  non-lease  components  such  as  common  area  maintenance
expense  for  building  leases  and  maintenance  expenses  for  automobile  leases.    In  general,  we  separate  common  area  maintenance  expense  component  from  the
value of the ROU asset and lease liability when evaluating rental properties, whereas, we include the maintenance and service components in the value of the ROU
asset  and  lease  liability  while  evaluating  automobile  leases.  We  review  ROU  assets,  for  impairment  whenever  events  or  changes  in  circumstances  indicate  the
carrying amount of an asset may not be recoverable. We measure recoverability of these assets by comparing the carrying value of such assets to the estimated
undiscounted  future  cash  flows  the  assets  are  expected  to  generate.  When  the  estimated  undiscounted  future  cash  flows  are  less  than  their  carrying  amount,  an
impairment loss is recognized equal to the difference between the assets’ fair value and their carrying value.  

Impairment of Long-Lived Assets

Intangible and other long lived-assets are reviewed for impairment whenever events such as product discontinuance, plant closures, product dispositions or
other changes in circumstances indicate that the carrying amount may not be recoverable. Certain factors which may occur and indicate that an impairment exists
include, but are not limited to, the following: significant underperformance relative to expected historical or projected future operating results; significant changes
in the manner of use of the underlying assets; and significant adverse industry or market economic trends. In reviewing for impairment, we compare the carrying
value of such assets to the estimated undiscounted future net cash flows expected from the use of the assets and their eventual disposition. If the carrying value of
assets is determined to be unrecoverable, we would estimate the fair value of the assets and record an impairment charge for the excess of the carrying value over
the fair value. The estimate  of fair value requires  management  to make several  assumptions and projections,  which could include, but would not be limited  to,
future revenues, earnings and the probability of certain outcomes and scenarios. Our policy is consistent with current accounting guidance as prescribed by ASC
360-10-35, “Accounting for the Impairment or Disposal of Long-Lived Assets.”

Goodwill

Goodwill, which has an indefinite life, is not amortized, but instead is subject to periodic testing for impairment. Goodwill is tested for impairment on an
annual basis or between annual tests if an event occurs or circumstances change that would reduce the fair value of a reporting unit below its carrying amount.
Certain factors which may occur and indicate that impairment exists include, but are not limited to the following: significant underperformance relative to expected
historical or projected future operating results; significant changes in the manner of our use of the underlying assets; and significant adverse industry or market
economic trends. If the carrying value of assets is determined to be unrecoverable, we would estimate the fair value of the reporting unit and record an impairment
charge for the excess of the carrying value over the fair value. The estimate of fair value requires management to make several assumptions and projections, which
could include, but would not be limited to, future revenues, earnings and the probability of certain outcomes and scenarios, including the use of experts.  

Definite-Lived Intangible Assets

We also have other intangible assets mainly consisting of patents and licenses, certain acquired rights, developed technologies, and customer relationships.
We capitalize the cost of acquiring patents and licenses.   Amortization is computed on the straight-line basis over the estimated useful lives of the assets, which is
our best estimate of the pattern of the economic benefits, which are based on legal, contractual, and other provisions, and range from 3 to 20 years for patents,
certain acquired rights and licenses, 10 years for customer relationships and 3 to 10 years for developed technology.   We review intangible assets for impairment
in the assessment discussed above regarding Impairment of Long-Lived Assets.

Employee Defined Benefit Plans - Pension

We have maintained a passive pension plan (the “Swiss Plan”) covering employees of our Swiss subsidiary.  We determined that the features of the Swiss
Plan conform to the features of a defined benefit plan.  As a result, we adopted the recognition and disclosure requirements of ASC 715, “Employers’ Accounting
for Defined Benefit Pension and Other Postretirement Plans.”

STAAR Japan has a noncontributory defined benefit pension plan (the “Japan Plan”) substantially covering employees of our Japan subsidiary.  The Japan

Plan has also adopted the recognition and disclosure requirements of

42

ASC 715. STAAR Japan is not required, and we do not intend to provide any future contributions to this pension plan to meet benefit obligations and will therefore
not have any plan assets.  Benefit payments are made to beneficiaries from operating cash flows as they become due.

We recognize the funded status, or difference between the fair value of plan assets and the projected benefit obligations of the pension plan on the statement
of financial position with a corresponding adjustment to accumulated other comprehensive income or loss. If the projected benefit obligation exceeds the fair value
of  plan  assets,  then  that  difference  or  unfunded  status  represents  the  pension  liability.  We  record  a  net  periodic  pension  cost  in  the  consolidated  statement  of
operations. The liabilities and annual income or expense of both plans are determined using methodologies that involve several actuarial assumptions, the most
significant of which are the discount rate, and the expected long-term rate of asset return. Assumptions of expected asset returns and market-related values of plan
assets  are  applicable  to  the  Swiss  Plan  only.    The  fair  values  of  plan  assets  are  determined  based  on  prevailing  market  prices.    The  amounts  recorded  in  the
financial statements pertaining to our employee defined benefit plans could vary significantly if we were to use different assumptions.

Foreign Exchange

Management does not believe that the fluctuation in the value of the dollar in relation to the currencies of its suppliers or customers in the last three fiscal
years has adversely affected our ability to purchase or sell products at agreed upon prices. No assurance can be given, however, that adverse currency exchange
rate fluctuations will not occur in the future, which could significantly affect our operating results. We do not currently hedge transactions to offset changes in
foreign currency.

Inflation

Management believes inflation has not had a significant impact on our net sales and revenues and on income from continuing operations during the past three

years.

Off Balance Sheet Arrangements

We do not have any off-balance sheet arrangements.

Recent Accounting Pronouncements

See “Part II. Item 8. “Financial Statements and Supplementary Data – Note 1 – Organization and Description of Business and Accounting Policies – Recent

Accounting Pronouncements and Recent Accounting Pronouncements Not Yet Adopted” of this Annual Report on Form 10-K.

ITEM 7A.

Quantitative and Qualitative Disclosures About Market Risk

In the normal course of business, our operations are exposed to risks associated with fluctuations in interest rates and foreign currency exchange rates. The
Company manages its risks based on management’s judgment of the appropriate trade-off between risks, opportunity, and costs and does not generally enter into
interest rate or foreign exchange rate hedge instruments.

Interest rate risk

As  of  January  1,  2021,  we  had  $1.4  million  of  foreign  debt.  Our  $1.4  million  of  foreign  debt  bears  an  interest  rate  that  is  equal  to  the  uncollateralized
overnight call rate in Japan (approximately 0.07%) plus a 0.50% spread. Thus, our interest expense would fluctuate with any change in the base interest rate. If the
uncollateralized  overnight  call  rate  were  to  increase  or  decrease  by  1%  for  the  year,  our  annual  interest  expense  would  increase  or  decrease  by  approximately
$14,000.

Foreign currency risk

Fluctuations  in  the  rate  of  exchange  between  the  U.S.  dollar  and  foreign  currencies  in  which  we  transact  business  could  adversely  affect  our  financial

results.  

Our international subsidiaries operate in and are net recipients of currencies other than the U.S. dollar and, as a result, our sales benefit from a weaker dollar
and are reduced by a stronger dollar relative to major currencies worldwide (primarily, the euro and the Japanese yen).  Accordingly, changes in exchange rates,
and particularly the strengthening of the U.S. dollar, may negatively affect our consolidated sales and gross profit as expressed in U.S. dollars.  Fluctuations during
any given reporting period result in the re-measurement of our foreign currency denominated cash, receivables, and payables, generating currency transaction gains
or losses and are reported in total other income (expense), net in our Consolidated Statements of Income.   In the normal course of business, we also face risks that
are either non-financial or non-quantifiable. Such risks include those set forth in “Item 1A. Risk Factors.”

43

ITEM 8.

Financial Statements and Supplementary Data

Financial Statements and the Report of Independent Registered Public Accounting Firm are filed with this Annual Report on Form 10-K in a separate section

following Part IV, as shown on the index under Item 15 of this Annual Report.

ITEM 9.

Changes in and Disagreements with Accountants on Accounting and Financial Disclosure

None.

ITEM 9A.

Controls and Procedures

Attached as exhibits to this Annual Report on Form 10-K are certifications of STAAR’s Chief Executive Officer (CEO) and Chief Financial Officer (CFO),
which  are  required  in  accordance  with  Rule  13a-14  of  the  Securities  Exchange  Act  of  1934,  as  amended  (the  Exchange  Act).  This  “Controls  and  Procedures”
section  includes  information  concerning  the  controls  and  controls  evaluation  referred  to  in  the  certifications.  The  report  of  BDO  USA,  LLP,  our  independent
registered  public  accounting  firm,  regarding  its  audit  of  STAAR’s  internal  control  over  financial  reporting  follows  below.  This  section  should  be  read  in
conjunction with the certifications and the BDO USA, LLP report for a more complete understanding of the topics presented.

Evaluation of Disclosure Controls and Procedures

As  of  the  end  of  the  period  covered  by  this  report,  we  carried  out  an  evaluation,  under  the  supervision  and  with  the  participation  of  our  management,
including our CEO and CFO, of the effectiveness of the design and operation of the disclosure controls and procedures of the Company.  Based on that evaluation,
our CEO and CFO concluded, as of the end of the period covered by our Form 10-K for the fiscal year ended January 1, 2021, that our disclosure controls and
procedures were effective.  For purposes of this statement, the term “disclosure controls and procedures” means controls and other procedures of the Company that
are designed to ensure that information required to be disclosed by the Company in the reports that it files or submits under the Securities Exchange Act (15 U.S.C.
78a  et  seq)  is  recorded,  processed,  summarized,  and  reported,  within  the  time  periods  specified  in  the  Commission’s  rules  and  forms.  Disclosure  controls  and
procedures include, without limitation, controls and procedures designed to ensure that information required to be disclosed by the issuer in the reports that it files
or  submits  under  the  Act  is  accumulated  and  communicated  to  the  issuer’s  management,  including  its  principal  executive  and  principal  financial  officers,  or
persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.

Changes in Internal Control over Financial Reporting

There was no change during the fiscal quarter ended January 1, 2021 that has materially affected, or is reasonably likely to materially affect, our internal

control over financial reporting.

Management’s Annual Report on Internal Control over Financial Reporting

The Company’s management, including our CEO and CFO, is responsible for establishing and maintaining adequate internal control over financial reporting
(as  such  term  is  defined  in  Exchange  Act  Rule  13a-15(f)  and  15d-15(f))  for  the  Company.  The  Company’s  internal  control  system  was  designed  to  provide
reasonable  assurance  to the  Company’s management  and Board of Directors  regarding  the preparation  and fair presentation  of published  consolidated  financial
statements in accordance with accounting principles generally accepted in the United States of America.

Because of its inherent limitations, a system of internal control over financial reporting can provide only reasonable assurance and may not prevent or detect
misstatements. Further, because of changing conditions, effectiveness of internal control over financial reporting may vary over time. The Company’s processes
contain self-monitoring mechanisms, and actions are taken to correct deficiencies as they are identified.

Management  has  assessed  the  effectiveness  of  the  Company’s  internal  control  over  financial  reporting  as  of  January  1,  2021,  based  on  the  criteria  for
effective internal control described in Internal Control — Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway
Commission. Based on its assessment, management concluded that the Company’s internal control over financial reporting was effective as of January 1, 2021.

44

Report of Independent Registered Public Accounting Firm

Shareholders and Board of Directors
STAAR Surgical Company
Lake Forest, California

Opinion on Internal Control over Financial Reporting

We have audited STAAR Surgical Company’s (the “Company’s”) internal control over financial reporting as of January 1, 2021, based on criteria established
in Internal Control – Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (the “COSO criteria”). In
our opinion, the Company maintained, in all material respects, effective internal control over financial reporting as of January 1, 2021, based on the COSO criteria.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), the consolidated
balance sheets of the Company as of January 1, 2021 and January 3, 2020, the related consolidated statements of operations, comprehensive income, stockholders’
equity, and cash flows for each of the three years in the period ended January 1, 2021, and the related notes and financial statement schedule and our report dated
February 24, 2021 expressed an unqualified opinion thereon.

Basis for Opinion

The Company’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of
internal  control  over  financial  reporting,  included  in  the  accompanying  Item  9A,  Management’s  Report  on  Internal  Control  over  Financial  Reporting.  Our
responsibility is to express an opinion on the Company’s internal control over financial reporting based on our audit. We are a public accounting firm registered
with the PCAOB and are  required  to be independent  with respect  to the Company in accordance  with U.S. federal  securities  laws and the applicable  rules  and
regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit of internal control over financial reporting in accordance with the standards of the PCAOB. Those standards require that we plan and
perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. Our audit
included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, and testing and evaluating the
design  and  operating  effectiveness  of  internal  control  based  on  the  assessed  risk.  Our  audit  also  included  performing  such  other  procedures  as  we  considered
necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and
the  preparation  of  financial  statements  for  external  purposes  in  accordance  with  generally  accepted  accounting  principles.  A  company’s  internal  control  over
financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the
transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of
financial  statements  in  accordance  with  generally  accepted  accounting  principles,  and  that  receipts  and  expenditures  of  the  company  are  being  made  only  in
accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with
the policies or procedures may deteriorate.

/s/ BDO USA, LLP

Los Angeles, California
February 24, 2021

45

ITEM 9B.

Other Information

The Board of Directors has scheduled the 2021 Annual Shareholders Meeting for June 24, 2021.

ITEM 10.

Directors, Executive Officers and Corporate Governance

PART III

The information required by this item is incorporated herein by reference to the section entitled “Election of Directors” contained in the proxy statement for
the 2021 annual meeting of stockholders (the “Proxy Statement”) to be filed with the Securities and Exchange Commission within 120 days of the close of the
fiscal year ended January 1, 2021.

ITEM 11.

Executive Compensation

The information required by this item is incorporated herein by reference to the section entitled “Executive Compensation” contained in the Proxy Statement.

ITEM 12.

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters

The  information  required  by  this  item  is  incorporated  herein  by  reference  to  the  section  entitled  “Security  Ownership  of  Principal  Shareholders  and

Management” and “Election of Directors” contained in the Proxy Statement.

ITEM 13.

Certain Relationships and Related Transactions, and Director Independence

The information required by this item is incorporated herein by reference to the section entitled “Election of Directors” contained in the Proxy Statement.

ITEM 14.

Principal Accounting Fees and Services

The information required by this item is incorporated herein by reference to the section entitled “Ratification of Independent Registered Public Accounting

Firm” contained in the Proxy Statement.

ITEM 15.

Exhibits and Financial Statement Schedules

We have filed the following documents as part of this Annual Report on Form 10-K:

PART IV

(1)

  Consolidated Financial Statements

  Report of Independent Registered Public Accounting Firm

  Consolidated Balance Sheets

  Consolidated Statements of Income

  Consolidated Statements of Comprehensive Income (Loss)

  Consolidated Statements of Stockholders’ Equity

  Consolidated Statements of Cash Flows

  Notes to Consolidated Financial Statements

(2)

  Schedules required by Regulation S-X are filed as an exhibit to this report

II. Schedule II — Valuation and Qualifying Accounts and Reserves

All other schedules have been omitted because they are not required, not applicable, or the required information is otherwise included.

46

  Page

F-2

F-4

F-5

F-6

F-7

F-8

F-9

F-44

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(3)

  Exhibits

    3.1

  Amended and Restated Certificate of Incorporation.(1)

    3.2

    4.1

  †4.2

  Amended and Restated Bylaws.(2)

  Form of Certificate for Common Stock, par value $0.01 per share.(3)

  Amended and Restated Omnibus Equity Incentive Plan.(4)

  4.3

  Description of the Registrant’s Securities.(23)

  10.1

†10.2

†10.3

  10.4

   10.5

Amendment No. 1 to Standard Industrial/Commercial Multi-Tenant Lease dated January 3, 2003, by and between the Company and California
Rosen LLC.(5)

  Form of Indemnification Agreement between the Company and certain officers and directors.(6)

  Employment Agreement, dated December 16, 2004 by and between the Company and Hans Blickensdoerfer.(7)

  Credit Agreement between STAAR Japan Inc. and Mizuho Bank Inc., dated October 31, 2007.(8)

Basic Agreement on Unsterilized Intraocular Lens Sales Transactions between Canon Staar Co., Inc. and Nidek Co., Ltd., dated May 23, 2005.
(10)

   10.6

  Basic Agreement on Injector Product Sales Transactions between Canon Staar Co., Inc. and Nidek Co., Ltd., dated May 23, 2005.(10)

   10.7

Memorandum  of  Understanding  Concerning  Basic  Agreements  for  Purchase  and  Sale  between  STAAR  Japan  Inc.  and  Nidek  Co.,  Ltd.,  dated
December 25, 2008.(10)

   10.8

  Acrylic Preset Supply Warranty Agreement between STAAR Japan Inc. and Nidek Co., Ltd., dated December 25, 2008.(10)

   10.9

  Framework Agreement for Loans between Credit Suisse and STAAR Surgical AG, dated September 2013.(11)

  †10.10

  Form of Executive Severance Agreement.(12)

  †10.11

  Form of Executive Change in Control Agreement.(12)

   10.12

Standard Industrial/Commercial Single – Tenant Lease – Net dated August 17, 2012, by and between the Company and Pacific Equity Partners,
LLC.(13)

  †10.13

  Letter of the Company dated March 27, 2012 to Samuel Gesten, Vice President and General Counsel, regarding compensation.(9)

  †10.14

  Letter of the Company dated July 27, 2015 to Keith Holliday, Vice President of Research and Development, regarding compensation.(14)

  †10.15

  Employment Agreement effective March 1, 2015 by and between the Company and Caren Mason, dated March 1, 2015.(15)

   10.16

  Form of Option Grant and Stock Option Agreement for employees.(16)

   10.17

  Form of Option Grant and Stock Option Agreement for Non-Employee Directors.(16)

   10.18

  Form of Restricted Stock Unit Grant and Agreement.(16)

   10.19

  Form of Restricted Stock Award Grant and Restricted Stock Award Agreement.(16)

   10.20

  Form of Amendment to Credit Agreement between STAAR Japan Inc. and Mizuho Bank Ltd.(11)

   10.21

  Master Lease Agreement dated May 30, 2006 by and between the Company and Farnam Street Financial, Inc.(16)

   10.22

Lease Schedule No. 011 and Purchase Option dated March 8, 2018 of Lease Agreement dated May 30, 2006, by and between the Company and
Farnam Street Financial, Inc.(20)

47

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   10.23

  Lease dated August 10, 2017 by and between the Company and 2000 Gold L.P.(17)

   10.24

  Lease Agreement commencing May 1, 2018 between Bukewihge Properties, LLC and STAAR Surgical Company.(18)

   10.25

  Form of Distributorship Agreement.(6)

   10.26

  Lease Agreement dated January 29, 2019 between GZK Real Estate Ltd. and STAAR Surgical Ltd.(21)

   10.27

  Lease Agreement dated June 13, 2019 between Einfache Gesellschaft Calderari & Schwab. and STAAR Surgical AG.(22)

  †10.28

  Letter of the Company dated August 10, 2012 to James Francese, Vice President, Global Marketing, regarding compensation.(9)

  †10.29

  Letter of the Company dated June 15, 2015 to Jon K. Hayashida, Vice President Global Clinical Affairs, regarding compensation.(14)

  †10.30

  Employment Agreement effective October 1, 2017 by and between the Company and Scott Barnes, dated September 11 2011.(23)

  †10.31

  Letter of the Company dated December 15, 2015 to Graydon Hansen, Vice President of Operations, regarding compensation.(23)

  †10.32

  Letter of the Company dated June 30, 2020 to Patrick Williams, Chief Financial Officer, regarding compensation.(4)

   10.33

  Lease agreement entered into on September 14, 2020 between STAAR Surgical Company and Calderari & Schwab.(24)

   10.34

  First Amendment to Lease Agreement dated October 1, 2020 between STAAR Surgical Company and Pacific Equity Partners, LLC.(25)

   10.35

  First Amendment to Lease Agreement dated October 30, 2020 between STAAR Surgical Company and 2000 Gold L.P.(26)

   14.1

  Code of Business Conduct and Ethics.(19)

   21.1

  List of Subsidiaries.*

   23.1

  Consent of BDO USA, LLP.*

   31.1

   31.2

Certification Pursuant to Rule 13a-14(a) of the Securities Exchange Act of 1934, Adopted Pursuant to Section 302 of the Sarbanes-Oxley Act of
2002.*

Certification Pursuant to Rule 13a-14(a) of the Securities Exchange Act of 1934, Adopted Pursuant to Section 302 of the Sarbanes-Oxley Act of
2002.*

   32.1

  Certification Pursuant to 18 U.S.C. Section 1350, Adopted Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002.**

    101

The  following  materials  from  the  Company’s  Annual  Report  on  Form  10-K  for  the  year  ended  January  1,  2021  formatted  inline  Extensible
Business Reporting Language (iXBRL): (i) the Consolidated  Balance Sheets, (ii) the Consolidated Statements  of Income, (iii) the Consolidated
Statements of Comprehensive Income (Loss), (iv) the Consolidated Statements of Stockholders’ Equity, (v) the Consolidated Statements of Cash
Flows, and (vi) related notes.

    104

The cover page from the Company’s Annual Report on Form 10-K for the fiscal year ended January 1, 2021, has been formatted in Inline XBRL
with applicable taxonomy extension information contained in Exhibit 101.

*
**
†
(1)
(2)

  Filed herewith.
  Furnished herewith.
  Management contract or compensatory plan.
  Incorporated by reference to Appendix 2 of the Company’s Proxy Statement on Form DEF 14A as filed with the Commission on April 13, 2018.
  Incorporated by reference to Appendix 3 of the Company’s Proxy Statement on Form DEF 14A as filed with the Commission on April 13, 2018.

48

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(3)

(4)

(5)

(6)

(7)
(8)

(9)

(10)

(11)

(12)

(13)
(14)

(15)
(16)

(17)

(18)

(19)

(20)

(21)

(22)

(23)

(24)
(25)
(26)

Incorporated  by  reference  to  Exhibit  4.1  to  Amendment  No.  1  to  the  Company’s  Registration  Statement  on  Form  8‑A/A  as  filed  with  the
Commission on April 18, 2003.
Incorporated by reference to the Company’s Quarterly Report on Form 10-Q, for the period ended July 3, 2020, as filed with the Commission on
August 5, 2020.
Incorporated by reference to the Company’s Annual Report on Form 10-K, for the year ended January 2, 2004, as filed with the Commission on
March 17, 2004.
Incorporated by reference from the Company’s Quarterly Report on Form 10-Q, for the period ended June 29, 2018, as filed with the Commission
on August 1, 2018.

  Incorporated by reference to the Company’s Current Report on Form 8-K as filed with the Commission on October 1, 2009.

Incorporated by reference to the Company’s Quarterly Report on Form 10-Q, for the period ended October 2, 2009, as filed with the Commission
on November 12, 2009.
Incorporated by reference to the Company’s Annual Report on Form 10-K, for the year ended December 31, 2012, as filed with the commission on
March 12, 2013.
Incorporated by reference to the Company’s Annual Report on Form 10-K, for the year ended January 1, 2010 as filed with the Commission on
April 1, 2010.  
Incorporated by reference to the Company’s Annual Report on Form 10-K, for the year ended December 29, 2017, as filed with the commission on
February 28, 2018.
Incorporated  by  reference  to  the  Company’s  Quarterly  Report  on  Form  10-Q,  for  the  period  ended  September  30,  2011,  as  filed  with  the
Commission on November 2, 2011.

  Incorporated by reference to the Company’s Current Report on Form 8-K as filed with the Commission on August 23, 2012.

Incorporated by reference to the Company’s Quarterly Report on Form 10-Q, for the period ended October 2, 2015, as filed with the Commission
on November 4, 2015.

  Incorporated by reference to the Company’s Current Report on Form 8-K as filed with the Commission on March 3, 2015.

Incorporated by reference to the Company’s Annual Report on Form 10-K, for the year ended December 30, 2016, as filed with the Commission
on March 2, 2017.
Incorporated  by  reference  to  the  Company’s  Quarterly  Report  on  Form  10-Q,  for  the  period  ended  September  29,  2017,  as  filed  with  the
Commission on November 8, 2017.
Incorporated by reference to the Company’s Quarterly Report on Form 10-Q, for the period ended March 30, 2018, as filed with the Commission
on May 2, 2018.
Incorporated by reference to the Company’s Quarterly Report on Form 10-Q/A, for the period ended June 29, 2012, as filed with the Commission
on August 8, 2012.
Incorporated by reference to the Company’s Annual Report on Form 10-K, for the year ended December 28 2018, as filed with the Commission on
February 21, 2019.
Incorporated by reference to the Company’s Quarterly Report on Form 10-Q, for the period ended March 29, 2019, as filed with the Commission
on May 1, 2019.
Incorporated by reference to the Company’s Quarterly Report on Form 10-Q, for the period ended June 28, 2019, as filed with the Commission on
July 31, 2019.
Incorporated by reference to the Company’s Annual Report on Form 10-K, for the year ended January 3, 2020, as filed with the Commission on
February 26, 2020.

  Incorporated by reference to the Company’s Current Report on Form 8-K as filed with the Commission on September 14, 2020.
  Incorporated by reference to the Company’s Current Report on Form 8-K as filed with the Commission on October 8, 2020.

Incorporated by reference to the Company’s Quarterly Report on Form 10-Q, for the period ended October 2, 2020, as filed with the Commission
on November 4, 2020.

ITEM 16.

Form 10-K Summary

None.

49

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Pursuant to the requirements  of Section 13 or 15(d) of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its

behalf by the undersigned, thereunto duly authorized.

SIGNATURES

Date:  February 24, 2021

STAAR SURGICAL COMPANY

By:

 /s/  CAREN MASON
Caren Mason
President and Chief Executive Officer
(principal executive officer)

Pursuant to the requirements of the Securities Exchange Act of 1934, this report has been signed below by the following persons on behalf of the registrant

and in the capacities and on the dates indicated.

Name

Title

/s/  CAREN MASON
Caren Mason

President, Chief Executive Officer and Director
(principal executive officer)

/s/  PATRICK F. WILLIAMS
Patrick F. Williams

  Vice President, Chief Financial Officer

(principal accounting and financial officer)

Date

February 24, 2021

February 24, 2021

/s/  LOUIS E. SILVERMAN
Louis E. Silverman

/s/  STEPHEN C. FARRELL
Stephen C. Farrell

/s/  THOMAS G. FRINZI
Thomas G. Frinzi

/s/  GILBERT H. KLIMAN
Gilbert H. Kliman

/s/  JOHN C. MOORE
John C. Moore

/s/  ELIZABETH YEU
Elizabeth Yeu

/s/  K. PEONY YU
K. Peony Yu

  Chairman of the Board, Director

February 24, 2021

  Director

  Director

  Director

  Director

  Director

  Director

50

February 24, 2021

February 24, 2021

February 24, 2021

February 24, 2021

February 24, 2021

February 24, 2021

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSIDIARIES
CONSOLIDATED FINANCIAL STATEMENTS
Years Ended January 1, 2021, January 3, 2020 and December 28, 2018

TABLE OF CONTENTS

Report of Independent Registered Public Accounting Firm

Consolidated Balance Sheets at January 1, 2021 and January 3, 2020

Consolidated Statements of Income for the years ended January 1, 2021, January 3, 2020 and December 28, 2018

Consolidated Statements of Comprehensive Income (Loss) for the years ended January 1, 2021, January 3, 2020 and December 28,

2018

Consolidated Statements of Stockholders’ Equity for the years ended January 1, 2021, January 3, 2020 and December 28, 2018

Consolidated Statements of Cash Flows for the years ended January 1, 2021, January 3, 2020 and December 28, 2018

Notes to Consolidated Financial Statements

Schedule II Valuation and Qualifying Accounts and Reserves

F-2

F-4

F-5

F-6

F-7

F-8

F-9

F-44

F-1

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Shareholders and Board of Directors
STAAR Surgical Company
Lake Forest, California

Opinion on the Consolidated Financial Statements

We have audited the accompanying consolidated balance sheets of STAAR Surgical Company (the “Company”) as of January 1, 2021 and January 3, 2020,
the related consolidated statements of operations, comprehensive income (loss), stockholders’ equity, and cash flows for each of the three years in the period ended
January  1, 2021, and the related  notes and financial  statement  schedule  (collectively  referred  to as the “consolidated  financial  statements”).  In our opinion, the
consolidated financial statements present fairly, in all material respects, the financial position of the Company at January 1, 2021 and January 3, 2020, and the
results  of  its  operations  and  its  cash  flows  for  each  of  the  three  years  in  the  period  ended  January  1,  2021,  in  conformity  with  accounting  principles  generally
accepted in the United States of America.

We also have audited, in accordance  with the standards  of the Public Company Accounting Oversight Board (United States) (“PCAOB”), the Company's
internal  control  over  financial  reporting  as  of  January  1,  2021,  based  on  criteria  established  in  Internal  Control  –  Integrated  Framework  (2013)  issued  by  the
Committee  of  Sponsoring  Organizations  of  the  Treadway  Commission  (“COSO”)  and  our  report  dated  February  24,  2021  expressed  an  unqualified  opinion
thereon.

Change in Accounting Method Related to Leases

As discussed in Notes 1 and 9 to the consolidated financial statements, the Company has changed its method of accounting for leases during the year ended

January 3, 2020 due to the adoption of the Accounting Standards Codification (“ASC”) 842, “Leases.”

Basis for Opinion

These consolidated financial statements are the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company’s
consolidated financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent with respect
to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the
PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable

assurance about whether the consolidated financial statements are free of material misstatement, whether due to error or fraud.

Our audits included performing procedures to assess the risks of material misstatement of the consolidated financial statements, whether due to error or fraud,
and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the
consolidated financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as
evaluating the overall presentation of the consolidated financial statements. We believe that our audits provide a reasonable basis for our opinion.

Critical Audit Matter

The  critical  audit  matter  communicated  below  is  a  matter  arising  from  the  current  period  audit  of  the  consolidated  financial  statements  that  was
communicated or required to be communicated to the audit committee and that: (1) relate to accounts or disclosures that are material to the consolidated financial
statements and (2) involved our especially challenging, subjective, or complex judgments. The communication of critical audit matter does not alter in any way our
opinion on the consolidated financial statements, taken as a whole, and we are not, by communicating the critical audit matter below, providing separate opinions
on the critical audit matter or on the accounts or disclosures to which they relate.

F-2

Income Tax Provision

As described in Notes 1 and 10 to the Company’s consolidated financial statements, the Company operates in multiple jurisdictions through its wholly-owned
subsidiaries. The Company serves international markets and is subject to income taxes in the U.S. and numerous foreign jurisdictions, which affect the Company’s
provision  for  income  taxes.    The  tax  provision  is  based  on  management’s  understanding  of  current  enacted  tax  laws  and  tax  rates  of  each  tax  jurisdiction,  and
assessing the realizability of the deferred tax assets. In evaluating the Company’s ability to realize the deferred tax assets management considers the positive and
negative  evidence,  including  the  reversals  of  deferred  tax  assets  and  liabilities,  projected  future  taxable  income,  tax-planning  strategies,  and  results  of  recent
operations.

We identified the Company’s calculation of the provision for income taxes, including the judgement and estimation regarding projected taxable income as a
critical  audit  matter.  Management  is required  to apply  significant  judgments  in calculating  the provision for income  taxes related  to the evaluation  of tax laws,
including the methods used to allocate taxable income to various jurisdictions, transfer pricing methods and the development of forecasts and assumptions related
to the projected sales growth, margins, costs and income that are used to assess the realizability of deferred tax assets. These forecasts include various assumptions
including the likelihood of continued growth in certain key markets, projected industry-wide performance, macro and micro economic factors and the development
and approval of new products. Auditing these elements involved especially complex auditor judgment due to the nature of audit evidence and extent of audit effort
required to address these matters, including the need to involve personnel with specialized knowledge and skills.

The primary procedures we performed to address this critical audit matter included:

•

•

•

•

Testing the design and operating  effectiveness  of controls over management’s  calculation  of its provision for income taxes, including controls
over:  (i)  evaluating  allocation  methodologies,  (ii)  reviewing  the  assumptions  and  data  utilized  in  determining  the  allocation  of  income  to
applicable tax jurisdictions, (iii) the development of the projected forecasts, and (iv) projected reversals of deferred tax assets and liabilities in the
valuation allowance assessment.

Assessing  the  reasonableness  of  the  Company’s  projected  forecasts  and  related  assumptions  against  the  Company’s  historical  performance,
industry conditions and outlooks, and evidence obtained in other areas of the audit.

Recalculating income tax expense and agreeing the data used in the calculations to the Company’s underlying books and records.

Utilizing personnel with specialized knowledge and skills in domestic and international tax law to assist in: (i) evaluating the application of tax
laws used in management’s allocation methodologies based on the Company’s structure and operations, (ii) evaluating transfer pricing regulations
to  assist  in  assessing  the  appropriateness  of  intercompany  transactions  and  the  rates  used  to  cross  charge  and  allocate  costs  based  on  transfer
pricing agreements,  (iii) recalculating the income tax expense utilizing enacted tax rates, and (iv) evaluating both positive and negative evidence
and assessing the reasonableness of assumptions used in the Company’s valuation allowance assessment.

/s/ BDO USA, LLP

We have served as the Company's auditor since 1993.

Los Angeles, California
February 24, 2021

F-3

 
 
 
 
STAAR SURGICAL COMPANY AND SUBSIDIARIES

CONSOLIDATED BALANCE SHEETS
January 1, 2021 and January 3, 2020

(In thousands, except par value amounts)

2020

2019

ASSETS

Current assets:

Cash and cash equivalents
Accounts receivable trade, net
Inventories, net
Prepayments, deposits and other current assets

Total current assets
Property, plant and equipment, net
Finance lease right-of-use assets, net
Operating lease right-of-use assets, net
Intangible assets, net
Goodwill
Deferred income taxes
Other assets

Total assets

LIABILITIES AND STOCKHOLDERS’ EQUITY

Current liabilities:
Line of credit
Accounts payable
Obligations under finance leases
Obligations under operating leases
Allowance for sales returns
Other current liabilities

Total current liabilities

Obligations under finance leases
Obligations under operating leases
Deferred income taxes
Asset retirement obligations
Pension liability

Total liabilities

Commitments and contingencies (Note 13)

Stockholders’ equity:
Common stock, $0.01 par value; 60,000 shares authorized: 46,448 and
   44,822 shares issued and outstanding at January 1, 2021 and
   January 3, 2020, respectively
Additional paid-in capital
Accumulated other comprehensive loss
Accumulated deficit

Total stockholders’ equity

Total liabilities and stockholders’ equity

  $

  $

  $

  $

152,453    $
35,229   
18,111   
10,625   
216,418   
24,030   
596   
8,764   
270   
1,786   
4,944   
608   
257,416    $

1,379    $
7,874   
360   
2,485   
4,532   
24,606   
41,236   
38   
6,537   
222   
221   
11,940   
60,194   

464   
338,194   
(5,545)  
(135,891)  
197,222   
257,416    $

119,968 
30,996 
17,142 
6,560 
174,666 
17,065 
1,867 
6,684 
296 
1,786 
4,408 
751 
207,523 

1,827 
8,050 
560 
2,700 
3,644 
17,697 
34,478 
366 
4,086 
658 
211 
7,840 
47,639 

448 
304,288 
(3,048)
(141,804)
159,884 
207,523

The accompanying notes are an integral part of these consolidated financial statements.

F-4

 
 
 
   
 
 
 
    
 
  
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
  
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
  
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF INCOME
Years Ended January 1, 2021, January 3, 2020 and December 28, 2018

(In thousands, except per share amounts)

Net sales
Cost of sales
Gross profit
Selling, general and administrative expenses:

General and administrative
Selling and marketing
Research and development

Total selling, general and administrative expenses
Operating income

Other income (expense), net:
Interest income, net
Gain (loss) on foreign currency transactions
Royalty income
Other income (loss), net

Total other income, net

Income before income taxes
Provision (benefit) for income taxes
Net income

Net income per share:

Basic

Diluted

Weighted average shares outstanding:

Basic
Diluted

2020

2019

2018

  $

163,460    $
45,098   
118,362   

150,185    $
38,231   
111,954   

33,911   
45,764   
31,918   
111,593   
6,769   

238   
864   
440   
(44)  
1,498   
8,267   
2,354   
5,913    $

0.13    $

0.12    $

45,605   
47,953   

29,313   
45,491   
25,298   
100,102   
11,852   

988   
(517)  
551   
152   
1,174   
13,026   
(1,022)  
14,048    $

0.32    $

0.30    $

44,493   
46,895   

  $

  $

  $

123,954 
32,444 
91,510 

24,287 
38,600 
22,028 
84,915 
6,595 

165 
(836)
633 
82 
44 
6,639 
1,671 
4,968 

0.12 

0.11 

42,587 
45,257

The accompanying notes are an integral part of these consolidated financial statements.

F-5

 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF COMPREHENSIVE INCOME (LOSS)
Years Ended January 1, 2021, January 3, 2020 and December 28, 2018

(In thousands)

Net income
Other comprehensive income (loss):

Defined benefit plans:

Net change in plan assets
Reclassification into other income (expense), net

Foreign currency translation gain
Tax effect

Other comprehensive loss, net of tax
Comprehensive income

2020

2019

2018

  $

5,913    $

14,048    $

4,968 

(3,639)  
283   
717   
142   
(2,497)  
3,416    $

(2,265)  
107   
291   
139   
(1,728)  
12,320    $

(498)
101 
242 
(15)
(170)
4,798

  $

The accompanying notes are an integral part of these consolidated financial statements.

F-6

 
 
 
   
   
 
 
 
    
 
    
 
  
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF STOCKHOLDERS’ EQUITY
Years Ended January 1, 2021, January 3, 2020 and December 28, 2018

(In thousands)

Common
Stock
Shares

Common
Stock Par
Value

Additional
Paid-In
Capital

Accumulated
Other
Compre-
hensive
Income
(Loss)

Balance, at December 29, 2017

Net income
Other comprehensive loss
Proceeds from public offering of stock
Common stock issued upon exercise of options
Stock-based compensation
Repurchase of employee common stock for taxes withheld
Unvested restricted stock
Vested restricted stock

Balance, at December 28, 2018

Net income
Impact of the adoption of lease accounting standard
Impact of adoption of nonemployee share-based payment
standard
Other comprehensive loss
Common stock issued upon exercise of options
Stock-based compensation
Unvested restricted stock
Vested restricted stock
Balance, at January 3, 2020

Net income
Other comprehensive loss
Common stock issued upon exercise of options
Stock-based compensation
Unvested restricted stock
Vested restricted stock
Balance, at January 1, 2021

41,383    $
—     
—     
2,000     
595     
—     
—     
11     
206     
44,195     
—     
—     

—     
—     
387     
—     
11     
229     
44,822     
—     
—     
1,507     
—     
11     
108     
46,448    $

414    $
—     
—     
20     
6     
—     
—     
—     
2     
442     
—     
—     

—     
—     
4     
—     
—     
2     
448     
—     
—     
15     
—     
—     
1     
464    $

204,920    $
—     
—     
72,130     
5,189     
7,399     
(54)    
—     
—     
289,584     
—     
—     

(315)    
—     
3,455     
11,564     
—     
—     
304,288     
—     
—     
20,631     
13,275     
—     
—     
338,194    $

Accumulated
Deficit
(161,248)   $
4,968     
—     
—     
—     
—     
—     
—     
—     
(156,280)    
14,048     
113     

(1,150)   $
—     
(170)    
—     
—     
—     
—     
—     
—     
(1,320)    
—     
—     

—     
(1,728)    
—     
—     
—     
—     
(3,048)    
—     
(2,497)    
—     
—     
—     
—     
(5,545)   $

315     
—     
—     
—     
—     
—     
(141,804)    
5,913     
—     
—     
—     
—     
—     
(135,891)   $

Total

42,936 
4,968 
(170)
72,150 
5,195 
7,399 
(54)
— 
2 
132,426 
14,048 
113 

— 
(1,728)
3,459 
11,564 
— 
2 
159,884 
5,913 
(2,497)
20,646 
13,275 
— 
1 
197,222

The accompanying notes are an integral part of these consolidated financial statements.

F-7

 
 
 
 
   
   
   
   
   
 
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
 
 
 
STAAR SURGICAL COMPANY AND SUBSIDIARIES

CONSOLIDATED STATEMENTS OF CASH FLOWS
Years Ended January 1, 2021, January 3, 2020 and December 28, 2018

(In thousands)

Cash flows from operating activities:
Net income
Adjustments to reconcile net income to net cash provided by
   operating activities:

Depreciation of property, plant, and equipment
Amortization of intangibles
Deferred income taxes
Change in net pension liability
Loss on disposal of property and equipment
Stock-based compensation expense
Provision for sales returns and bad debts
Inventory provision
Changes in working capital:
Accounts receivable
Inventories
Prepayments, deposits, and other current assets
Accounts payable
Other current liabilities

Net cash provided by operating activities

Cash flows from investing activities:

Acquisition of property and equipment
Acquisition of patents and licenses

Net cash used in investing activities

Cash flows from financing activities:

Proceeds from public offering of stock
Repayment of finance lease obligations
Repayment on line of credit
Repurchase of employee common stock for taxes withheld
Proceeds from the exercise of stock options
Proceeds from vested restricted stock

Net cash provided by financing activities

Effect of exchange rate changes on cash, cash equivalents and
   restricted cash
Increase in cash, cash equivalents and restricted cash
Cash, cash equivalents and restricted cash, at beginning of year
Cash, cash equivalents and restricted cash, at end of year

2020

2019

2018

  $

5,913    $

14,048    $

4,968 

3,060   
35   
(849)  
656   
213   
12,146   
835   
1,706   

(3,974)  
(1,390)  
(3,753)  
(812)  
7,165   
20,951   

(8,404)  
—   
(8,404)  

—   
(561)  
(515)  
—   
20,646   
1   
19,571   

3,665   
34   
(3,481)  
359   
14   
10,547   
275   
1,580   

(4,502)  
(950)  
(1,313)  
1,084   
4,435   
25,795   

(10,095)  
(83)  
(10,178)  

—   
(1,294)  
(2,018)  
—   
3,459   
2   
149   

2,430 
34 
441 
231 
10 
6,762 
905 
1,473 

(6,040)
(4,194)
(598)
243 
6,102 
12,767 

(2,245)
— 
(2,245)

72,150 
(1,907)
(747)
(54)
5,195 
2 
74,639 

367   
32,485   
119,968   
152,453    $

203   
15,969   
103,999   
119,968    $

197 
85,358 
18,641 
103,999

  $

The accompanying notes are an integral part of these consolidated financial statements.

F-8

 
 
 
 
   
   
 
 
 
    
 
    
 
  
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

Note 1 — Organization and Description of Business and Accounting Policies

Organization and Description of Business

STAAR  Surgical  Company  and  subsidiaries  (the  “Company”),  a  Delaware  corporation,  was  first  incorporated  in  1982  for  the  purpose  of  developing,
producing, and marketing implantable lenses for the eye and delivery systems used to deliver the lenses into the eye.  Principal products are implantable Collamer
lenses  (“ICLs”)  and  intraocular  lenses  (“IOLs”).    ICLs,  consisting  of  the  Company’s  ICL  family  of  products,  including  the  Toric  implantable  Collamer  lenses
(“TICL”)  and  EVO+  Visian  ICL,  are  intraocular  lenses  used  to  correct  refractive  conditions  such  as  myopia  (near-sightedness),  hyperopia  (far-sightedness),
astigmatism,  and  presbyopia.      IOLs  are  prosthetic  intraocular  lenses  used  to  restore  vision  that  has  been  adversely  affected  by  cataracts,  and  include  the
Company’s lines of silicone IOLs and the Preloaded Injector (a silicone or acrylic IOL preloaded into a single-use disposable injector).

As of January 1, 2021, the Company’s significant subsidiaries consisted of:

•

•

STAAR Surgical AG, a wholly owned subsidiary formed in Switzerland that markets and distributes ICLs and Preloaded IOLs.

STAAR Japan, a wholly owned subsidiary that markets and distributes Preloaded IOLs and ICLs.

The Company operates as one operating segment, the ophthalmic surgical market, for financial reporting purposes (see Note 17).

Principles of Consolidation

The accompanying consolidated financial statements include the accounts of STAAR Surgical Company and its wholly-owned subsidiaries and have been
prepared  in  accordance  with  accounting  principles  generally  accepted  in  the  United  States  of  America  (“GAAP”).  All  significant  intercompany  balances  and
transactions have been eliminated.  Certain reclassifications have been made to financial statements of prior years to conform to the current year presentation (see
Note 20).

Fiscal Year and Interim Reporting Periods

The  Company’s  fiscal  year  ends  on  the  Friday  nearest  December  31  and  each  of  the  Company’s  quarterly  reporting  periods  generally  consists  of  13

weeks.  Fiscal years 2020 and 2018 are based on a 52-week period and fiscal year 2019 is based on a 53-week period. 

Foreign Currency

The functional currency of the Company’s Japanese subsidiary, STAAR Japan, Inc., is the Japanese yen. The functional currency of the Company’s Swiss

subsidiary, STAAR Surgical AG, is the U.S. dollar.

Assets and liabilities of the Company’s Japanese subsidiary are translated at rates of exchange in effect at the close of the period. Sales and expenses are

translated at the weighted average of exchange rates in effect during the period. Net foreign translation gain (loss) was as follows (in thousands):

Foreign currency translation gain(1)
Gain (loss) on foreign currency transactions(2)

2020

  $

Years Ended
2019

717    $
864   

291    $
(517)  

2018

242 
(836)

(1)
(2)

Shown as a separate line item on the Consolidated Statements of Comprehensive Income (Loss).
Shown as a separate line item on the Consolidated Statements of Income.

F-9

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Use of Estimates

The  consolidated  financial  statements  have  been  prepared  in  conformity  with  GAAP  and,  as  such,  include  amounts  based  on  significant  estimates  and
judgments  of  management  with  consideration  given  to  materiality.  Significant  estimates  used  include  determining  valuation  allowances  for  uncollectible  trade
receivables, sales returns reserves, obsolete and excess inventory reserves, deferred income taxes, and tax reserves, including valuation allowances for deferred tax
assets, pension liabilities, evaluation of asset impairment, in determining the useful life of depreciable and definite-lived intangible assets, and in the variables and
assumptions  used  to  calculate  and  record  stock-based  compensation.  Actual  results  could  differ  materially  from  those  estimates.  Throughout  the  COVID-19
pandemic the Company offered extended payment terms to assist its surgeon customers and their clinics as they resumed business. During the second half of 2020,
the  Company  experienced  improvements  in  customer  payments  and  is  unaware  of  any  material  impairment  of  customer  receivables.    The  Company’s  sales
representatives  throughout  the  world  remain  engaged  with  customers  conducting  online  training  and  other  educational  courses  which  have  been  very  well
attended.  This activity has given the Company insight into COVID-19’s impact on customers and potential impairment of receivables.

Cash and Cash Equivalents and Restricted Cash

The Company considers all highly liquid investments purchased with a maturity of three months or less to be cash equivalents. The Company maintains cash
deposits  with  major  banks  which  from  time  to  time  may  exceed  federally  insured  limits.  The  Company  periodically  assesses  the  financial  condition  of  the
institutions and believes that the risk of any loss is minimal.  The following table provides a reconciliation of cash, cash equivalents, and restricted cash reported
within the Consolidated Balance Sheets that sum to the total of the same such amounts shown in the Consolidated Statements of Cash Flows at January 1, 2021,
January 3, 2020 and December 28, 2018 (in thousands):

Cash and cash equivalents
Restricted cash(1)

Total cash, cash equivalents and restricted cash

(1)

Included in other assets on the Consolidated Balance Sheets.

2020

2019

2018

  $

  $

152,453    $

119,968    $

—   

—   

152,453    $

119,968    $

103,877 
122 
103,999

The Company had restricted cash set aside as collateral for a standby letter of credit required by the California Department of Public Health for unforeseen
future regulatory costs related to the decommissioning of certain manufacturing equipment.  Since the quarter ended June 28, 2019, the Company was no longer
required to set aside collateral for this standby letter of credit.

Revenue Recognition

On  December  30,  2017  (beginning  of  fiscal  year  2018),  the  Company  adopted  Financial  Accounting  Standards  Board  (“FASB”)  Accounting  Standards
Update (“ASU”) 2014-09, “Revenue from Contracts with Customers (Topic 606)” and its subsequent amendments, using the modified retrospective method, and
determined  that  there  was  no  cumulative  effect  adjustment  on  the  Consolidated  Financial  Statements.  The  Company  determined  that  the  adoption  of  the  new
standard did not materially impact the revenue recognition on its Consolidated Financial Statements.  

The Company recognizes revenue when its contractual performance obligations with customers are satisfied.  The Company’s performance obligations are
generally  limited  to single sales  orders  with product  shipping  to the customer  within a month of receipt  of the sales order.   Substantially  all  of the Company’s
revenues  are  recognized  at  a  point-in-time  when  control  of  its  products  transfers  to  the  customer,  which  is  typically  upon  shipment  (as  discussed  below).    The
Company presents sales tax and similar taxes it collects from its customers on a net basis (excluded from revenues).

F-10

 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Revenue Recognition (Continued)

The Company sells certain injector parts to an unrelated customer and supplier (collectively referred to as “supplier”) whereby these injector part sales are
either  made  as  a  final  sale  to  the  supplier  or,  are  sold  to  be  combined  with  an  acrylic  IOL  by  the  supplier  into  finished  goods  inventory  (a  preloaded  acrylic
IOL).  These finished goods are then sold back to the Company at an agreed upon, contractual price.  The Company makes a profit margin on either type of sale
with the supplier and each type of sale is made under separate purchase and sales orders between the two parties resulting in cash settlement for the orders sold or
repurchased.  For parts that are sold as a final sale, the Company recognizes a sale and those sales are classified as other product sales in total net sales.  For the
injector parts that are sold to be combined with an acrylic IOL into finished goods, the Company records the transaction at its carrying value deferring any profit
margin as contra-inventory, until the finished goods inventory is sold to an end-customer (not the supplier) at which point the Company recognizes revenues.

For all sales, the Company is considered the principal in the transaction as the Company is the party providing specified goods it has control over prior to
when  control  is  transferred  to  the  customer.    Cost  of  sales  includes  cost  of  production,  freight  and  distribution,  and  inventory  provisions,  net  of  any  purchase
discounts.  Shipping and handling activities that occur after the customer obtains control of the goods are recognized as fulfillment costs.

The  Company  also  enters  into  certain  strategic  cooperation  agreements  with  customers  in  which,  as  consideration  for  certain  commitments  made  by  the
customer, including minimum purchase commitments, the Company agrees, among other things, to pay for marketing, educational training and general support of
the Company’s products.  The provisions in these arrangements allow for these payments to be made directly to the customer or payments can be made directly to a
third party for distinct marketing, educational training and general support services provided to or on behalf of the customer by the third party.  For payments the
Company makes to another party, or reimburses the customer for distinct marketing and support services, the Company recognizes these payments as sales and
marketing expense as incurred in accordance with ASC 606-10-32-25.  These strategic cooperation agreements are generally for periods of 12 months or more with
quarterly minimum purchase commitments.  The Company recognizes sales and marketing expenses in the period in which it expects the customer will achieve its
minimum purchase commitment, generally quarterly, and any unpaid amounts are recorded in Other Current Liabilities in “Other” on the Consolidated Balance
Sheets,  see  Note  7.    Reimbursements  made  directly  to  the  customer  for  general  marketing  incentives  are  treated  as  a  reduction  in  revenues.    The  Company’s
performance obligations generally occur in the same quarter as the shipment of product.  Sales and marketing expenses for distinct services were as follows (in
thousands):

Marketing and support services related to strategic cooperation agreements

  $

655    $

485    $

629

Since the payments for distinct or non-distinct services occur within the quarter corresponding with the purchases made by the customer and the shipments
made  by  the  Company  to  that  customer,  there  is  no  remaining  performance  obligation  by  the  Company  to  the  customer.    Accordingly,  there  are  no  deferred
revenues associated with these types of arrangements as of January 1, 2021, January 3, 2020 and December 28, 2018.

2020

Years Ended
2019

2018

F-11

 
 
 
 
 
 
 
 
   
   
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Revenue Recognition (Continued)

The Company disaggregates its revenue into the following categories:  non-consignment sales and consignment sales.

Non-consignment Sales

The Company recognizes revenue from non-consignment product sales at a point-in-time when control has been transferred, which is typically at shipping
point, except for certain customers and for the Company’s STAAR Japan subsidiary, which is typically recognized when the customer receives the product.  The
Company does not have significant deferred revenues as of January 1, 2021, January 3, 2020 and December 28, 2018, as delivery to the customer is generally made
within the same or the next day of shipment.

Consignment Sales

The Company’s products are marketed to ophthalmic surgeons, hospitals, ambulatory surgery centers or vision centers, and distributors. IOLs and ICLs may
be offered to surgeons and hospitals on a consignment basis.  The Company maintains title and risk of loss on consigned inventory and recognizes revenue for
consignment inventory at a point-in-time when the Company is notified that the lenses have been implanted, thus completing the performance obligation.

See Note 17 for additional information on disaggregation of revenues, geographic sales information and product sales.

Allowance for Doubtful Accounts

The Company performs ongoing credit evaluations of its customers and adjusts credit limits based on customer payment history and credit worthiness, as
determined by the Company’s review of its customers’ current credit information.  The Company continuously monitors collections and payments from customers
and maintains a provision for estimated credit losses and uncollectible accounts based upon an expected loss model which considers its historical experience, any
specific customer collection issues that have been identified and other relevant observable data, including current economic conditions.  Amounts determined to be
uncollectible are written off against the allowance for doubtful accounts.

Concentration of Credit Risk and Revenues

Financial instruments that potentially subject the Company to credit risk principally consist of trade receivables. This risk is limited due to the large number
of customers comprising the Company’s customer base, and their geographic dispersion. As of January 1, 2021 and January 3, 2020, there was one customer who
accounted  for  46%  and  43%  of  the  Company’s  consolidated  trade  receivables,  respectively.    Ongoing  credit  evaluations  of  customers’  financial  condition  are
performed and, generally, no collateral is required. The Company maintains reserves for potential credit losses and such losses, taken together, have not exceeded
management’s expectations.

There  was  one  customer  who  accounted  for  44%,  43%  and  37%  of  the  Company’s  consolidated  net  sales  for  the  years  ended  2020,  2019  and  2018,

respectively.

F-12

 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Sales Return Reserve

The Company generally may permit returns of product if the product, upon issuance of a Return Goods Authorization, is returned within the time allowed by
its return policies and records an allowance for estimated returns at the time revenue is recognized. The Company’s allowance for estimated returns is based on an
expected  loss  model  which  considers  historical  and  current/anticipated  trends  and  experience,  the  impact  of  new  product  launches,  the  entry  of  a  competitor,
availability of timely and pertinent information and the various terms and arrangements offered, including sales with extended credit terms.  For estimated returns,
sales  are  reported  net  of  estimated  returns  and  cost  of  sales  are  reported  net  of  estimated  returns  that  can  be  resold.    On  the  Consolidated  Balance  Sheets,  the
balances associated for estimated sales returns were as follows (in thousands):

Estimated returns - inventory(1)
Allowance for sales returns

(1) Recognized in inventories, net on the Consolidated Balance Sheets

Fair Value of Financial Instruments

2020

2019

  $

1,041    $
4,532   

869 
3,644

Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at
the  measurement  date.  To  increase  the  comparability  of  fair  value  measures,  the  following  hierarchy  prioritizes  the  inputs  to  valuation  methodologies  used  to
measure fair value (ASC 820-10-50):

•

•

•

Level 1 – Inputs to the valuation methodology are quoted prices (unadjusted) for identical assets or liabilities in active markets.

Level 2 – Inputs to the valuation methodology include quoted prices for similar assets or liabilities in active markets, and inputs that are observable for
the assets or liability, either directly or indirectly, for substantially the full term of the financial instruments.

Level 3 – Inputs to the valuation methodology are unobservable; that reflect management’s own assumptions about the assumptions market participants
would make and significant to the fair value.

The carrying values reflected on the Consolidated Balance Sheets for cash and cash equivalents, trade accounts receivable, net, prepayments, deposits and

other current assets, accounts payable, other current liabilities and line of credit approximate their fair values because of the short maturity of these instruments.

Inventories, Net

Inventories, net are valued at the lower of cost, determined on a first-in, first-out basis, or net realizable value. Inventories include the costs of raw material,
labor,  and  manufacturing  overhead,  work  in  process  and  finished  goods.  Inventories  also  include  as  a  contra  item,  deferred  margins  for  certain  injector  parts
described under the revenue recognition policy. The Company provides estimated inventory allowances for excess, expiring, slow moving and obsolete inventory
as well as inventory whose carrying value is in excess of net realizable value to properly reflect inventory at the lower of cost or market.

F-13

 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Property, Plant, and Equipment

Property,  plant,  and  equipment  are  recorded  at  cost.  Depreciation  on  property,  plant,  and  equipment  is  computed  using  the  straight-line  method  over  the
estimated useful lives of the assets as noted below. Leasehold improvements are amortized over the lesser of the estimated useful lives of the assets or the related
lease term. Major improvements are capitalized and minor replacements, maintenance and repairs are charged to expense as incurred.

Also included in property, plant and equipment is construction in process.  Construction in process includes the cost of design plans and build out of facilities
and the cost of equipment, as well as the direct costs incurred in the testing and validation of machinery and equipment and facilities before they are ready for
productive use.  Upon placement in service, costs are reclassified into the appropriate asset category and depreciation commences.

The estimated useful lives of assets are as follows:

Machinery and equipment
Computer equipment and software
Furniture and equipment
Leasehold improvements

Goodwill

  5-10 years
  2-5 years
  3-7 years
  The shorter of the useful life of the asset or the term of the associated lease

Goodwill, which has an indefinite life, is not amortized but instead is tested for impairment on an annual basis or between annual tests if an event occurs or
circumstances change that would indicate the carrying amount may be impaired. Impairment testing for goodwill is done at the reporting unit level. Reporting units
can  be  one  level  below  the  operating  segment  level,  and  can  be  combined  when  reporting  units  within  the  same  operating  segment  have  similar  economic
characteristics. The Company has determined that its reporting units have similar economic characteristics, and therefore, can be combined into one reporting unit
for the purposes of goodwill impairment testing.  The Company performed its annual impairment test and determined that its goodwill was not impaired.  As of
January 1, 2021 and January 3, 2020, the carrying value of goodwill was $1,786,000.  

Long-Lived Assets

The  Company  reviews  property,  plant,  and  equipment  and  intangible  assets,  excluding  goodwill,  for  impairment  whenever  events  or  changes  in
circumstances indicate the carrying amount of an asset may not be recoverable. The Company measures recoverability of these assets by comparing the carrying
value of such assets to the estimated undiscounted future cash flows the assets are expected to generate. When the estimated undiscounted future cash flows are
less than their carrying amount, an impairment loss is recognized equal to the difference between the assets’ fair value and their carrying value. A review of long-
lived assets was conducted as of January 1, 2021 and January 3, 2020 and no impairment was identified.

Amortization is computed on the straight-line basis, which is the Company’s best estimate of the economic benefits realized over the estimated useful lives of
the assets which range from 3 to 20 years for patents, certain acquired rights and licenses, 10 years for customer relationships, and 3 to 10 years for developed
technology.

F-14

 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Lease Accounting

On December 29, 2018 (beginning of fiscal year 2019), the Company adopted FASB ASU 2016-02, “Leases (Topic 842)” and its subsequent amendments
affecting  the  Company:  (i)  ASU  2018-10,  “Codification  Improvements  to  Topic  842,  Leases,”  and  (ii)  ASU  2018-11,  “Leases  (Topic  842):    Targeted
improvements,”  using  the  modified  retrospective  method.    Upon  adoption  of  Topic  842,  the  Company  recognized  a  cumulative  adjustment  of  $113,000  which
decreased the accumulated deficit and recognized right-of-use (“ROU”) assets and lease liabilities for operating leases, whereby the Company’s accounting finance
leases remained substantially unchanged.

The Company recognizes ROU assets and lease liabilities for leases with terms greater than twelve months in the Consolidated Balance Sheets.  Leases are

classified as either finance or operating, with classification affecting the pattern of expense recognition in the Consolidated Statement of Income.  

A contract contains a lease if the contract conveys the right to control an identified asset for a period of time in exchange for consideration.  An asset is either
explicitly identified or implicitly identified and must be physically distinct.  In addition, the Company must have both the right to obtain substantially all of the
economic benefits from use of the identified asset and has the right to direct the use of the identified asset.

Certain  leases  may  have  non-lease  components  such  as  common  area  maintenance  expense  for  building  leases  and  maintenance  expenses  for  automobile
leases.  In general, the Company separates common area maintenance  expense component from the value of the ROU asset and lease liability when evaluating
rental properties under Topic 842, whereas, the Company includes the maintenance and service components in the value of the ROU asset and lease liability while
evaluating automobile leases under Topic 842.

When  determining  whether  a  lease  is  a  finance  lease  or  an  operating  lease,  Topic  842  does  not  specifically  define  criteria  to  determine  “major  part  of
remaining  economic  life  of  the  underlying  asset”  and  “substantially  all  of  the  fair  value  of  the  underlying  asset.”    For  lease  classification  determination,  the
Company continues to use (i) greater than or equal to 75% to determine whether the lease term is a major part of the remaining economic life of the underlying
asset  and  (ii)  greater  than  or  equal  to  90%  to  determine  whether  the  present  value  of  the  sum  of  lease  payments  is  substantially  all  of  the  fair  value  of  the
underlying asset.

The Company uses either the rate implicit in the lease or its incremental borrowing rate as the discount rate in lease accounting.

When adopting Topic 842, the Company did not reassess any expired or existing contracts, reassess the lease classification for any expired or existing leases

and reassess initial direct costs for exiting leases.  The Company also elected not to capitalize leases that have terms of twelve months or less.

The  Company  reviews  ROU  assets,  for  impairment  whenever  events  or  changes  in  circumstances  indicate  the  carrying  amount  of  an  asset  may  not  be
recoverable. The Company measures recoverability of these assets by comparing the carrying value of such assets to the estimated undiscounted future cash flows
the assets are expected to generate. When the estimated undiscounted future cash flows are less than their carrying amount, an impairment loss is recognized equal
to the difference between the assets’ fair value and their carrying value.

F-15

 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Vendor Concentration

As  of  January  1,  2021  and  January  3,  2020  there  was  one  vendor  who  accounted  for  over  10%  and  11%,  respectively,  of  the  Company’s  consolidated
accounts payable.  There were no vendors who accounted for over 10% of the Company’s consolidated purchases for the years ended 2020 and 2019, respectively.
There was one vendor who accounted for over 10% of the Company’s consolidated purchases for the year ended 2018.

Research and Development Costs

Expenditures for research activities relating to product development and improvement are charged to expense as incurred.

Advertising Costs

Advertising costs, which are included in marketing and selling expenses, are expensed as incurred, and were as follows (in thousands):

Advertising costs

Income Taxes

2020

Years Ended
2019

2018

  $

9,181    $

10,990 

 $

8,981

On December 22, 2017, the United States enacted major tax reform legislation, the 2017 Tax Act, which enacted a broad range of changes to the federal tax
code.    Key  provisions  that  could  have  an  impact  on  the  Company’s  Consolidated  Financial  Statements  are  the  deemed  repatriation  of  foreign  earnings,  the
remeasurement of certain net deferred assets and other liabilities for the change in the U.S. corporate tax rate from 35 percent to 21 percent, and the elimination of
the alternative minimum tax (“AMT”) which were included in the Company’s 2017 Consolidated Financial Statements.  The Company applied the guidance in
Staff  Accounting  Bulletin  118  when  accounting  for  the  enactment-date  effects  of  the  2017  Tax  Act  in  2017  and  throughout  2018.  At  December  28,  2018,  the
Company has completed its accounting for all the enactment-date income tax effects of the Tax Act.

Beginning  in  2017,  the  2017  Tax  Act  subjects  a  U.S.  shareholder  to  tax  on  Global  Intangible  Low  Tax  Income  (“GILTI”)  earned  by  certain  foreign
subsidiaries.  In January 2018, the FASB released guidance (Staff Q&A Topic 740, No. 5) on the accounting for tax on the GILTI provisions of the 2017 Tax Act.
In general, GILTI is the excess of a U.S. shareholder’s total net foreign income over a deemed return on tangible assets.  The provision further allows a deduction
of 50 percent of GILTI, however this deduction is limited by the Company’s net operating loss carryforwards.  In addition, Staff Q&A Topic 740, No. 5 states that
an entity can make an accounting policy election to either recognize deferred taxes for temporary basis differences expected to reverse as GILTI in future years or
to provide for the tax expense related to GILTI in the year the tax is incurred as a period expense only.  The Company has elected to account for GILTI as a current
period expense when incurred.

The Company recognizes the income tax benefit from an uncertain tax position when it is more likely than not that, based on technical merits, the position
will be sustained upon examination, including resolutions of any related appeals or litigation processes. The amount of tax benefit recorded, if any, is limited to the
extent it is not greater than 50 percent likely to be realized upon settlement with the taxing authority (that has full knowledge of all relevant information). Accrued
interest, if any, related to uncertain tax positions is included as a component of income tax expense, and penalties, if incurred, are recognized as a component of
operating income or loss. The Company does not have any uncertain tax positions as of any of the periods presented.

The Company did not incur significant interest and penalties for any period presented.

F-16

 
 
 
 
 
 
 
 
   
   
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Income Taxes (Continued)

The  Company  recognizes  deferred  tax  assets  and  liabilities  for  temporary  differences  between  the  financial  reporting  basis  and  the  tax  basis  of  the
Company’s assets and liabilities, net operating loss and credit carryforwards, and uncertainty in income taxes, on a jurisdiction-by-jurisdiction basis. In evaluating
the  Company’s  ability  to  recover  the  deferred  tax  assets  within  a  jurisdiction  from  which  they  arise,  management  considers  all  available  positive  and  negative
evidence,  including  scheduled  reversals  of  deferred  tax  liabilities,  projected  future  taxable  income,  tax-planning  strategies,  and  results  of  recent  operations.  In
projecting future taxable income, the Company begins with historical results and incorporates assumptions including overall current and projected business and
industry  conditions,  the  amount  of  future  federal,  state,  and  foreign  pretax  operating  income,  the  reversal  of  temporary  differences  and  the  successful
implementation of feasible and prudent tax-planning strategies. These assumptions require significant judgment about the forecasts of future taxable income and
are  consistent  with  the  plans  and  estimates  the  Company  uses  to  manage  the  underlying  businesses.  In  evaluating  the  objective  evidence  that  historical  results
provide,  the  Company  also  considers  three  years  of  cumulative  operating  results.  Valuation  allowances,  or  reductions  to  deferred  tax  assets,  are  recognized  if,
based on the weight of all the available evidence, it is more likely than not that some portion or all the deferred tax asset may not be realized.  The impact on
deferred taxes of changes in tax rates and laws, if any, are applied to the years during which temporary differences are expected to be settled and reflected in the
financial statements in the period of enactment. 

The  Company  has  made  a  policy  election  to  apply  the  incremental  cash  tax  savings  approach  when  analyzing  the  impact  GILTI  could  have  on  its  U.S.
valuation allowance. As a result of future expected GILTI inclusions, and because of the Tax Act’s ordering rules, U.S. companies may now expect to utilize tax
attribute carryforwards (e.g., net operating losses and deferred tax assets) for which a valuation allowance has historically been recorded (this is referred to as the
“tax law ordering approach”). However, due to the mechanics of the GILTI rules, companies that have a GILTI inclusion may realize a reduced (or no) cash tax
savings from utilizing such tax attribute carryforwards (this view is referred to as the “incremental cash tax savings approach”).

On July 23, 2020 the U.S. Treasury issued final regulations for addressing the treatment of foreign income that is subject to a high rate of foreign tax (the
GILTI  high-tax  exclusion).  The  final  regulations  allow  companies  to  exclude  certain  high-taxed  income  from  their  GILTI  calculation.    The  GILTI  high-tax
exclusion applies if the effective foreign tax rate is 90% or more of the rate that would apply if the income were subject to the maximum US rate of tax specified in
section 11 (currently 18.9%, based on a maximum rate of 21%).  The final regulations also provide that the GILTI high-tax exclusion is an annual election made
each year and is retroactive to years beginning after December 31, 2017.  The Company has made the election to exclude certain high-taxed income from its GILTI
calculation for fiscal years 2020, 2019 and 2018.  The Company will continue to make the election each year to the extent it results in a tax benefit.

On  March  27,  2020,  the  Coronavirus  Aid,  Relief  and  Economic  Security  (“CARES”)  Act  was  enacted  and  signed  into  law.    The  Company  reviewed  the

provisions of the CARES Act, but does not expect it to have a material impact to its tax provision (also see Note 21).

On December 27, 2020 the Consolidated Appropriations Act (“CAA”) was enacted and signed into law. The Company reviewed the provisions of the CAA,

but does not expect it to have a material impact to its tax provision (also see Note 21).

Basic and Diluted Net Income Per Share

The Company has only one class of common stock and no participating securities which would require the two-class method of calculating basic earnings per
share. Basic per share information is calculated by dividing net income by the weighted average number of shares outstanding, net of unvested restricted stock,
unvested restricted stock units (“RSUs”) and unvested performance stock units (“PSUs”), during the period. Diluted per share information is calculated by dividing
net  income  by  the  weighted  average  number  of  shares  outstanding,  adjusted  for  the  effects  of  potentially  dilutive  common  stock,  which  are  comprised  of
outstanding warrants, stock options, unvested restricted stock, RSUs and PSUs, during the period, using the treasury-stock method (See Note 16).

F-17

 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Employee Defined Benefit Plans

The Company maintains a passive pension plan (the “Swiss Plan”) covering employees of its Swiss subsidiary.  The Swiss Plan conforms to the features of a

defined benefit plan.  

The Company also maintains a noncontributory defined benefit pension plan which covers substantially all the employees of STAAR Japan.  

The Company recognizes the funded status, or difference between the fair value of plan assets and the projected benefit obligations of the pension plan on the
Consolidated Balance Sheets, with a corresponding adjustment to accumulated other comprehensive income (loss). If the projected benefit obligation exceeds the
fair  value  of  plan  assets,  then  that  difference  or  unfunded  status  represents  the  pension  liability.  The  Company  records  a  net  periodic  pension  cost  in  the
Consolidated Statements of Income. The liabilities and annual income or expense of both plans are determined using methodologies that involve several actuarial
assumptions,  the  most  significant  of  which  are  the  discount  rate  and  the  expected  long-term  rate  of  asset  return  (asset  returns  and  fair-value  of  plan  assets  are
applicable for the Swiss Plan only). The fair values of plan assets are determined based on prevailing market prices (see Note 11). 

Stock-Based Compensation

Stock-based compensation expense for all stock-based compensation awards granted is based on the grant-date fair value. The Company recognizes these
compensation  costs  on  a  straight-line  basis  over  the  requisite  service  period  of  the  award,  which  is  generally  the  option  vesting  term  of  three  to  four  years  for
executive officers and employees, and one year for members of its Board of Directors (the “Board”) (see Note 12).

The Company also, at times,  issues restricted  stock to its executive  officers,  employees  and the  Board, which are  restricted  and unvested common  shares
issued at fair market value on the date of grant. For the restricted shares issued to the Board, the restricted stock vests over a one-year service period, for executive
officers and employees, it is typically a three-year service period, and are subject to forfeiture (or acceleration, depending upon the circumstances) until vested or
the service period is completed.  Restricted stock compensation expense is recognized on a straight-line basis over the requisite service period of one to three years,
based on the grant-date fair value of the stock. Restricted stock is considered legally issued and outstanding on the grant date (see Notes 12 and 16).

The Company issues RSUs and PSUs (see Note 12), which can have only a service condition or a performance contingent restricted stock award based upon
the Company meeting certain internally established performance conditions that vest only if those conditions are met or exceeded and the grantee is still employed
with  the  Company.  RSU  and  PSU  compensation  expense  is  recognized  on  a  straight-line  basis  over  the  requisite  service  period.  The  Company  recognizes
compensation cost for the performance condition RSUs and PSUs when the Company concludes that it is probable that the performance condition will be achieved,
net  of  an  estimate  of  pre-vesting  forfeitures,  over  the  requisite  service  period  based  on  the  grant-date  fair  value  of  the  stock.  The  Company  reassesses  the
probability of vesting at each reporting period and adjusts compensation cost based on its probability assessment.

Once the RSUs and PSUs are vested, equivalent common shares will be issued or issuable to the grantee and therefore the RSUs and PSUs are not included

in total common shares issued and outstanding until vested (see Notes 12 and 16).

On  December  29,  2018  (beginning  of  fiscal  year  2019),  the  Company  adopted  ASU  2018-07,  “Compensation-Stock  Compensation  (Topic
718):    Improvements  to  Nonemployee  Share-Based  Payment  Accounting,”  aligns  the  accounting  for  share-based  payments  to  nonemployees  similar  to
employees.  Upon the adoption of ASU 2018-07, the Company recognized a cumulative adjustment of $315,000 which decreased the accumulated deficit.  

F-18

 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Comprehensive Income (Loss)

The Company presents comprehensive income (loss) in the Consolidated Balance Sheets and the Consolidated Statements of Comprehensive Income (Loss).
Total comprehensive income (loss) includes, in addition to the net income, changes in equity that are excluded from the Consolidated Statements of Income and are
recorded  directly  into  a  separate  section  of  stockholders’  equity  on  the  Consolidated  Balance  Sheets.  The  following  table  summarizes  the  changes  in  the
accumulated balances for each component of accumulated other comprehensive income (loss) attributable to the Company for the years ended January 1, 2021,
January 3, 2020 and December 28, 2018 (in thousands):  

Balance, at December 29, 2017

Other comprehensive income (loss)
Tax effect

Balance, at December 28, 2018

Other comprehensive income (loss)
Tax effect

Balance, at January 3, 2020

Other comprehensive income (loss)
Tax effect

Balance, at January 1, 2021

Foreign
Currency
Translation    

Defined
Benefit
Pension

Defined
Benefit
Pension
Plan –

Plan – Japan    

Switzerland    

Accumulated
Other Com-
prehensive
Income
(Loss)

  $

  $

278    $
242   
(74)  
446   
291   
(86)  
651   
717   
(217)  
1,151    $

88    $

(107)  
29   
10   
34   
(6)  
38   
(33)  
10   
15    $

(1,516)   $
(290)  
30   
(1,776)  
(2,192)  
231   
(3,737)  
(3,323)  
349   
(6,711)   $

(1,150)
(155)
(15)
(1,320)
(1,867)
139 
(3,048)
(2,639)
142 
(5,545)

Recently Adopted Accounting Pronouncements and Recent Accounting Pronouncements Not Yet Adopted

On January 4, 2020 (beginning of fiscal year 2020), the Company adopted ASU 2016‑13, “Financial Instruments – Credit Losses (Topic 326):  Measurement
of Credit Losses on Financial Instruments,” which (i) significantly changes the impairment model for most financial assets that are measured at amortized cost and
certain other instruments from an incurred loss model to an expected loss model; and (ii) provides for recording credit losses on available-for-sale debt securities
through an allowance account.  ASU 2016-13 also requires certain incremental disclosures.  Subsequently, the FASB issued ASU 2018-19, ASU 2019-04, ASU
2019-05, ASU 2020-02 and ASU 2020-03 to clarify and improve ASU 2016-13.  The adoption of ASU 2016-13 did not have a material impact on the Consolidated
Financial Statements.

On January 4, 2020 (beginning of fiscal year 2020), the Company adopted ASU 2018-13, “Fair Value Measurement (Topic 820):  Disclosure Framework –
Changes  to  the  Disclosure  Requirements  for  Fair  Value  Measurement,”  which  modifies  certain  disclosures  requirements  for  reporting  fair  value
measurements.  The adoption of ASU 2018-13 did not have a material impact on the Consolidated Financial Statements.

On January 4, 2020 (beginning of fiscal year 2020), the Company adopted ASU 2018-14, “Compensation – Retirement Benefits – Defined Benefit Plans –
General (Subtopic 715-20); Disclosure Framework – Changes in the Disclosure Requirement for Defined Benefit Plans,” which modifies disclosure requirements
for  employers  that  sponsor  defined  benefit  pension  or  other  post  retirement  plans.    The  adoption  of  ASU  2018-14  did  not  have  a  material  impact  on  the
Consolidated Financial Statements.

F-19

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 1 — Organization and Description of Business and Accounting Policies (Continued)

Recently Adopted Accounting Pronouncements and Recent Accounting Pronouncements Not Yet Adopted (Continued)

In December 2019, the FASB issued ASU 2019-12, “Income Taxes (Topic 740):  Simplifying the Accounting for Income Taxes.” ASU 2019-12 removes the
following exceptions:  exception to the incremental approach for intraperiod tax allocation; exception to accounting for basis differences when there are ownership
changes in foreign investments; and exception to interim period tax accounting for year to date losses that exceed anticipated losses.  ASU 2019-12 also improves
financial  reporting  for  franchise  taxes  that  are  partially  based  on  income;  transactions  with  a  government  that  result  in  a  step  up  in  the  tax  basis  of  goodwill;
separate financial statements of legal entities that are not subject to tax; and enacted changes in tax laws in interim periods.  ASU 2019-12 is effective for fiscal
years beginning after December 15, 2020 and interim periods within those fiscal years.  Early adoption is permitted.  The Company will adopt this standard as of
January 2, 2021 (beginning of fiscal year 2021) and is not expected to have a material impact on Consolidated Financial Statements.

Note 2 — Accounts Receivable Trade, Net

Accounts receivable trade, net consisted of the following at January 1, 2021 and January 3, 2020 (in thousands):

Domestic
Foreign

Total accounts receivable trade, gross

Less allowance for doubtful accounts

Total accounts receivable trade, net

Note 3 — Inventories, Net

Inventories, net consisted of the following at January 1, 2021 and January 3, 2020 (in thousands):

Raw materials and purchased parts
Work in process
Finished goods

Total inventories, gross

Less inventory reserves
Total inventories, net

  $

  $

  $

  $

2020

2019

828    $

34,460   
35,288   
59   
35,229    $

2020

2019

3,679    $
2,174   
13,717   
19,570   
1,459   
18,111    $

Note 4 — Prepayments, Deposits and Other Current Assets

Prepayments, deposits and other current assets consisted of the following at January 1, 2021 and January 3, 2020 (in thousands):

Prepayments and deposits
Prepaid insurance
Consumption tax receivable
Value added tax (VAT) receivable
Other(1)

Total prepayments, deposits and other current assets

(1) No individual item in “other” exceeds 5% of the total prepayments, deposits and other current assets.

F-20

2020

2019

  $

  $

3,791    $
2,677   
1,409   
2,056   
692   
10,625    $

989 
30,095 
31,084 
88 
30,996

3,334 
1,870 
12,976 
18,180 
1,038 
17,142

3,031 
1,488 
875 
713 
453 
6,560

 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 5 — Property, Plant and Equipment, Net

Property, plant and equipment, net consisted of the following at January 1, 2021 and January 3, 2020 (in thousands):

Machinery and equipment
Computer equipment and software
Furniture and fixtures
Leasehold improvements
Construction in process

Total property, plant and equipment, gross

Less accumulated depreciation

Total property, plant and equipment, net

2020

2019

  $

  $

21,209    $
7,423   
4,676   
11,388   
11,120   
55,816   
31,786   
24,030    $

17,173 
6,244 
4,169 
10,151 
8,477 
46,214 
29,149 
17,065

Depreciation expense and loss on disposal of property, plant and equipment were as follows (in thousands):

Depreciation expense
Loss on disposal of property, plant and equipment

2020

  $

Years Ended
2019

2,801    $
213   

3,081    $
14   

2018

2,430 
10

The loss recognized for the year ended January 1, 2021 consisted primarily of an asset, with a net book value of $208,000, that was no longer in use.

Note 6 — Intangible Assets, Net

Intangible assets, net consisted of the following at January 1, 2021 and January 3, 2020 (in thousands):

Long-lived amortized intangible assets
Patents and licenses

2020

2019

Gross
Carrying
Amount

Accumulated
Amortization    

Net

Gross
Carrying
Amount

Accumulated
Amortization    

Net

  $

9,382    $

(9,112)   $

270    $

9,353    $

(9,057)   $

296

Amortization expense for intangible assets were as follows (in thousands):

Amortization expense

Future amortization of intangible assets is as follows (in thousands):

2020

Years Ended
2019

2018

  $

35    $

34    $

34

Year Ended
2021
2022
2023
2024
2025
Thereafter
Total

Amount

36 
36 
36 
36 
36 
90 
270

$

$

F-21

 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
   
 
 
   
   
   
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 7 — Other Current Liabilities

Other current liabilities consisted of the following at January 1, 2021 and January 3, 2020 (in thousands):

Accrued salaries and wages
Accrued bonuses
Accrued insurance
Income taxes payable
Accrued consumption tax
Marketing obligations
Other(1)

Total other current liabilities

2020

2019

  $

  $

6,061    $
3,000   
2,633   
4,657   
1,743   
1,484   
5,028   
24,606    $

4,400 
4,184 
1,346 
2,710 
1,164 
633 
3,260 
17,697

(1) No individual item in “Other” exceeds 5% of the other current liabilities.

Note 8 — Lines of Credit

Since 1998, the Company’s wholly owned Japanese subsidiary, STAAR Japan, has had an agreement with Mizuho Bank which provides for borrowings of
up to 500,000,000 Yen, at an interest rate equal to the uncollateralized overnight call rate (approximately 0.07% as of January 1, 2021) plus a 0.50% spread, and
may  be  renewed  quarterly  (the  current  line  expires  on  February  21,  2021).    The  credit  facility  is  not  collateralized.    The  Company  had  142,500,000  Yen  and
197,500,000 Yen outstanding on the line of credit as of January 1, 2021 and January 3, 2020, respectively (approximately $1,379,000 and $1,827,000 based on the
foreign exchange rates on January 1, 2021 and January 3, 2020, respectively), which approximates fair value due to the short-term maturity and market interest
rates of the line of credit.  In case of default, the interest rate will be increased to 14% per annum.  There was 357,500,000 Yen and 302,500,000 Yen available for
borrowing as of January 1, 2021 and January 3, 2020, respectively (approximately $3,459,000 and $2,798,000 based on the foreign exchange rates on January 1,
2021 and January 3, 2020, respectively).  At maturity on February 21, 2021, this line of credit was renewed until May 21, 2021, with similar terms.

In  September  2013,  the  Company’s  wholly  owned  Swiss  subsidiary,  STAAR  Surgical  AG,  entered  into  a  framework  agreement  for  loans  (“framework
agreement”)  with  Credit  Suisse  (the  “Bank”).  The  framework  agreement  provides  for  borrowings  of  up  to  1,000,000  CHF  (Swiss  Francs)  (approximately
$1,100,000 and $1,000,000 at the rate of exchange on January 1, 2021 and January 3, 2020, respectively), to be used for working capital purposes. Accrued interest
and 0.25% commissions on average outstanding borrowings is payable quarterly and the interest rate will be determined by the Bank based on the then prevailing
market conditions at the time of borrowing. The framework agreement is automatically renewed on an annual basis based on the same terms assuming there is no
default. The framework agreement may be terminated by either party at any time in accordance with its general terms and conditions. The framework agreement is
not  collateralized  and  contains  certain  conditions  such  as  providing  the  Bank  with  audited  financial  statements  annually  and  notice  of  significant  events  or
conditions,  as  defined  in  the  framework  agreement.  The  Bank  may  also  declare  all  amounts  outstanding  to  be  immediately  due  and  payable  upon  a  change  of
control or a “material qualification” in STAAR Surgical independent auditors’ report, as defined. There were no borrowings outstanding as of January 1, 2021 and
January 3, 2020.

Covenant Compliance

The Company is in compliance with covenants of its credit facilities and lines of credit as of January 1, 2021.

Lease Line of Credit (Finance Leases)

During 2019, the Company converted the lease line of credit schedule 011 with Farnam Street Financial, Inc. into a finance lease liability of approximately

$500,000.

F-22

 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 9 — Leases

Finance Leases

The Company entered into finance leases primarily related to purchases of equipment used for manufacturing or computer-related equipment.  These finance
leases are two to five years in length and have fixed payment amounts for the term of the contract and have options to purchase the assets at the end of the lease
term.  Supplemental balance sheet information related to finance leases consisted of the following at January 1, 2021 and January 3, 2020 (dollars in thousands):

2020

2019

Machinery and equipment
Computer equipment and software
Furniture and fixtures
Leasehold improvements

Finance lease ROU assets, gross

Less accumulated depreciation

Finance lease ROU assets, net

Total finance lease liability

Weighted-average remaining lease term (in years)
Weighted-average discount rate

Supplemental cash flow information related to finance leases consisted of the following (in thousands):

Amortization of finance lease ROU asset
Interest on finance lease liabilities
Cash paid for amounts included in the measurement of finance lease liabilities:

Operating cash flows
Financing cash flows

ROU assets obtained in exchange for new finance lease liabilities

Operating Leases

  $

  $

  $

  $

570 
806 
— 
— 
1,376 
780 
596 

  $

  $

398 

  $

0.9 
3.46% 

Years Ended

2020

2019

259    $
30   

30 
561 
22   

1,885 
912 
102 
27 
2,926 
1,059 
1,867 

926 

1.1 
6.17%

584 
72 

72 
1,294 
679

The  Company  entered  into  operating  leases  primarily  related  to  real  property  (office,  manufacturing  and  warehouse  facilities),  automobiles  and
copiers.  These operating leases are two to ten years in length with options to extend.  The Company did not include any lease extensions in the initial valuation
unless the Company was reasonably certain to extend the lease.  Depending on the lease, there are those with fixed payment amounts for the entire length of the
contract or payments which increase periodically as noted in the contract or increased at an inflation rate indicator.  For operating leases that increase using an
inflation  rate  indicator,  the Company  used  the  inflation  rate  at the  time  the  lease  was  entered  into for  the  length  of  the  lease  term.  Supplemental  balance  sheet
information related to operating leases consisted of the following at January 1, 2021 and January 3, 2020 (dollars in thousands):

F-23

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
    
 
  
 
 
  
 
 
  
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 9 — Leases (Continued)

Operating Leases (Continued)

Machinery and equipment
Computer equipment and software
Real property

Operating lease ROU assets, gross

Less accumulated depreciation

Operating lease ROU assets, net

Total operating lease liability

Weighted-average remaining lease term (in years)
Weighted-average discount rate

Supplemental cash flow information related to operating leases was as follows (in thousands):

Operating lease cost
Cash paid for amounts included in the measurement of operating lease liabilities:

Operating cash flows

ROU assets obtained in exchange for new operating lease liabilities

2020

2019

  $

  $

  $

860 
462 
12,956 
14,278 
5,514 
8,764 

  $

  $

9,022 

  $

5.2 
2.61% 

Years Ended

2020

2019

  $

3,023    $

3,052   
4,938   

765 
462 
11,116 
12,343 
5,659 
6,684 

6,786 

2.3 
1.82%

2,749 

2,774 
3,495

ROU assets related to operating leases of $5,726,000 were recorded upon the adoption of Topic 842 at the beginning of fiscal year 2019.

Future Minimum Lease Commitments

Estimated future minimum lease payments under operating and finance leases having initial or remaining non-cancelable lease terms more than one year as

of January 1, 2021 are as follows (in thousands):

Year Ended
2021
2022
2023
2024
2025
Thereafter

Total minimum lease payments, including interest
Less amounts representing interest
Total minimum lease payments

F-24

  Operating Leases     Finance Leases  
366 
  $
20 
15 
4 
— 
— 
405 
7 
398

2,682    $
2,219   
1,804   
837   
595   
1,325   
9,462    $
440   
9,022    $

  $

  $

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 10 — Income Taxes  

Provision (Benefit) for Income Taxes

Income from continuing operations before provision (benefit) for income taxes was as follows (in thousands):

Domestic
Foreign

Income before income taxes

The provision (benefit) for income taxes consisted of the following (in thousands):

Current tax provision:

U.S. federal
State
Foreign

Total current provision

Deferred tax provision (benefit):

U.S. federal
State
Foreign

Total deferred provision (benefit)

Provision (benefit) for income taxes

F-25

2020

(16,245)   $
24,512   
8,267    $

Years Ended
2019

(5,321)   $
18,347   
13,026    $

2018

(2,629)
9,268 
6,639

2020

Years Ended
2019

2018

2    $
15   
3,186   
3,203   

(573)  
78   
(354)  
(849)  
2,354    $

—    $
13   
2,446   
2,459   

(3,003)  
(373)  
(105)  
(3,481)  
(1,022)   $

— 
10 
1,220 
1,230 

— 
— 
441 
441 
1,671

  $

  $

  $

  $

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 10 — Income Taxes (Continued)

Provision (Benefit) for Income Taxes (Continued)

A reconciliation of the statutory U.S. federal tax rate to the Company’s effective tax rate was as follows (dollars in thousands):

Computed provision for taxes based
   on income at statutory rate
Increase (decrease) in taxes resulting from:

Permanent differences
State taxes, net of federal income
   tax benefit
State tax benefit
Foreign tax differential
Expiration of state net operating tax loss
   carryforwards
Foreign earnings not permanently
   reinvested, net of the participation
   exemption
Foreign dividend withholding
ASC 718 share based payment adjustment
Incentive stock option compensation
Non-qualified stock option and restricted
  stock tax deduction in excess of
  cumulative book deduction
Executive compensation Section 162(m) limitation
GILTI inclusion
Other
Valuation allowance

Effective tax provision (benefit)

2020

Years Ended
2019

2018

Rate

  Amount

Rate

  Amount

Rate

  Amount

21.0%   $

1,736     

21.0%   $

2,735     

21.0%   $

1,394 

0.4%    

29     

0.5%    

60     

0.5%    

34 

0.9%    
(16.9)%    
(27.9)%    

74     
(1,397)    
(2,304)    

(2.2)%    
0.7%    
(11.6)%    

(284)    
93     
(1,514)    

0.1%    
(6.7)%    
(11.0)%    

3.2%    

268     

8.0%    

1,039     

— 

(0.1)%    

— 
5.8%    
(59.4)%    

(5)    
—     
476     
(4,907)    

(0.1)%    

— 
— 

(0.4)%    

(7)    
—     
—     
(55)    

(14.0)%    
4.8%    
(6.5)%    
(12.7)%    

(52.3)%    
43.0%    
54.0%    
(2.5)%    
59.3%    
28.5%   $

(4,324)    
3,552     
4,461     
(204)    
4,899     
2,354     

(12.9)%    
4.4%    
25.9%    
0.9%    
(42.0)%    
(7.8)%   $

(1,679)    
569     
3,372     
121     
(5,472)    
(1,022)    

(12.7)%    
0.9%    
26.8%    
0.5%    
34.2%    
25.2%   $

8 
(447)
(730)

— 

(926)
317 
(434)
(842)

(842)
60 
1,780 
30 
2,269 
1,671

The  Company  recorded  income  taxes  of  $2,354,000  during  the  year  ended  2020  due  to  pre-tax  income  generated  in  certain  foreign  jurisdictions,  which
included a release of $495,000 of the Company’s U.S. valuation allowance, as a result of increases in foreign income and changes in the usage and release of our
deferred tax assets.  The Company recorded an income tax benefit of $1,022,000 during the year ended 2019 due to the income tax benefit from the release of the
U.S. and certain states valuation allowances, offset by income tax expense from profits generated in its foreign operations. The Company recorded an income tax
provision of $1,671,000 during the year ended 2018, due to profits generated in its foreign operations.  

For  the  years  ended  2020  and  2019,  there  was  a  decrease  in  foreign  deferred  liabilities  of  $213,000  and  $46,000,  respectively.  Included  in  the  foreign

deferred tax provision is an increase of $36,000 in foreign deferred liabilities for the year ended 2018  

F-26

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
   
 
   
 
 
   
   
  
   
      
  
   
      
  
   
  
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 10 — Income Taxes (Continued)

Provision (Benefit) for Income Taxes (Continued)

All earnings from the Company’s subsidiaries are not considered to be permanently reinvested.  Accordingly, the Company provided withholding and U.S.
taxes on all unremitted foreign earnings through 2018 (see STAAR Surgical UK discussion below).  During 2020, 2019 and 2018 there were no withholding taxes
paid to foreign jurisdictions.  

As discussed in Note 1, on December 22, 2017, the United States enacted major tax reform legislation, the 2017 Tax Act, which enacted a broad range of
changes to the federal tax code.  Most of the changes from the new law are effective for years beginning after December 31, 2017, with the noted exception of the
deemed repatriation of the offshore earnings.  

For 2020, 2019 and 2018, in accordance with the 2017 Tax Act, the Company included GILTI of $21,300,000, $15,100,000 and $7,700,000, respectively, in
U.S. gross income, which was fully offset with net operating loss carryforwards.  The Company utilized the high-tax exception to exclude income from foreign
jurisdictions with foreign taxes at an effective rate that is higher than 90 percent of the applicable highest U.S. corporate tax rate.  The Company was not able to
utilize the deduction of 50 percent of GILTI, as this deduction is limited by the Company’s pre-GILTI U.S. tax income.

Deferred Tax Assets and Liabilities

Deferred  income  taxes  reflect  the  net  tax  effects  of  temporary  differences  between  the  carrying  amounts  of  assets  and  liabilities  for  financial  reporting
purposes  and  the  amounts  used  for  income  tax  purposes.      Significant  components  of  the  Company’s  deferred  tax  assets  (liabilities)  at  January  1,  2021  and
January 3, 2020 were as follows (in thousands):

2020

2019

Deferred tax assets:

Allowance for doubtful accounts and sales returns
Inventories
Accrued vacation
Accrued other expenses
Stock-based compensation
Pensions
Depreciation and amortization
Net operating loss carryforwards
Business, foreign, AMT and R&D credit carryforwards
Prepaid expenses
Capitalized R&D
Operating lease liability
Other
Valuation allowance

Total deferred tax assets

Deferred tax liabilities:

Foreign tax withholding
Operating lease ROU assets
Depreciation and amortization
Amortization of R&D
Net foreign earnings not permanently reinvested

Total deferred tax liabilities
Total net deferred tax assets

F-27

  $

  $

  $

  $

357    $
691   
599   
786   
3,277   
1,679   
—   
38,642   
3,051   
280   
1,000   
1,687   
19   
(42,502)  

9,566    $

(1,295)   $
(1,662)  
(424)  
(846)  
(617)  
(4,844)  
4,722    $

233 
703 
428 
1,036 
2,859 
1,159 
162 
32,251 
3,164 
272 
986 
1,309 
5 
(37,007)
7,560 

(1,295)
(1,309)
— 
(805)
(401)
(3,810)
3,750

 
 
 
 
 
   
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 10 — Income Taxes (Continued)

Deferred Tax Assets and Liabilities (Continued)

As of January 1, 2021, the Company had combined federal and state net deferred tax assets of $3,871,000, net deferred tax assets in Japan of $1,073,000, and
net deferred tax liabilities in Switzerland of $222,000 (which included $1,295,000 of withholding taxes on unremitted foreign earnings) included in the Company’s
components  of  deferred  income  tax  assets  and  liabilities  table.   As of  January  3, 2020, the  Company had  combined  federal  and  state  net  deferred  tax  assets  of
$3,512,000, net deferred tax assets in Japan of $896,000, and net deferred tax liabilities in Switzerland of $658,000 (which included $1,295,000 of withholding
taxes on unremitted foreign earnings) included in the Company’s components of deferred income tax assets and liabilities table.  

The Company had accrued net income taxes payable of $4,650,000 and $2,572,000 at January 1, 2021 and January 3, 2020, respectively, primarily due to

taxes owed in foreign jurisdictions.

U.S. Jurisdiction

The ultimate realization of deferred tax assets is dependent upon future generation of income during the periods in which temporary differences representing
net future deductible amounts become deductible. Management considers the projected future income and tax planning strategies in making this assessment. Since
January 3, 2020, the Company has at least three years of accumulated profits for federal income tax purposes as a result of GILTI.  However, the three-year income
position  is  not  solely  determinative  and,  accordingly,  management  considers  all  other  available  positive  and  negative  evidence  in  its  analysis.  This  includes
existing  profits  in  foreign  jurisdiction  as  well  as  projected  future  profits.  After  consideration  of  all  the  information  available,  the  Company  determined  that  a
release of the federal valuation and certain states valuation were appropriate.

As a result of the Company’s 2020 operating results, revising its global forecasts for fiscal 2021 and beyond as a result of COVID-19 in the first quarter of
2020  and  changes  in  the  usage  and  release  of  certain  deferred  tax  assets,  under  the  incremental  cash  tax  savings  approach,  the  Company  recorded  a  valuation
allowance  release  of  $573,000  against  the  federal  deferred  tax  assets,  and  a  valuation  allowance  release  reversal  of  $78,000  against  certain  states  deferred  tax
assets,  during  2020.    Under  this  method,  valuation  allowances  of  $34,681,000  and  $7,399,000  for  federal  and  state,  respectively,  remain  as  the  usage  of  the
remaining net operating losses and deferred tax assets will not result in cash tax savings and therefore provide no additional benefit at January 1, 2021.

Under the incremental cash tax savings approach, the Company recorded a valuation allowance release of $3,003,000 and $373,000 again federal and certain
states deferred tax assets, respectively, during 2019, and valuation allowances of $30,308,000 and $6,174,000 for federal and state, respectively, remained as the
usage of the remaining net operating losses and deferred tax assets will not result in cash tax savings and therefore provide no additional benefit at January 3, 2020.

Further included in the federal deferred tax asset balance is $2,013,000 in foreign tax credits that are unlikely to be realized in the future under the new tax

act and the mechanics of GILTI.

As of January 1, 2021, the Company had net deferred tax assets in the U.S. of $3,576,000, which consisted of the cumulative federal valuation allowance

release and had state net deferred tax assets of $294,000, which consisted of the cumulative release of certain state valuation allowances.

As  of  January  1,  2021,  the  Company  had  federal  net  operating  loss  carryforwards  of  $152,863,000  available  to  reduce  future  income  taxes  of  its  U.S.
operations. The pre-2019 federal net operating loss carryforwards expire in varying amounts between 2021 and 2037.  In California, the main state from which the
Company conducts its domestic operations, the Company has state net operating losses of $27,275,000 available to reduce future California income taxes. In 2020,
California  enacted  Assembly Bill 85 which imposed limits  on the usability  of California  state  net operating  losses and research  and development  credits  in tax
years beginning after 2019 and before 2023. The California net operating loss carryforwards expire in varying amounts between 2028 and 2039.

Further, pursuant to the provisions of Internal Revenue Code Section 382, significant changes in ownership may restrict the future utilization of these tax loss

carry forwards.  For 2020 the Company does not have a change in ownership.

F-28

 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 10 — Income Taxes (Continued)

Foreign Jurisdictions

STAAR Surgical UK

On  October  9,  2019  STAAR  US  formed  STAAR  Surgical  UK  Limited  (“STAAR  UK”)  as  a  holding  company  in  the  United  Kingdom  for  their  foreign
subsidiaries.  On December 30, 2019, STAAR US transferred their shares in STAAR Surgical AG to STAAR UK.  STAAR UK will act as the main foreign group
holding  company  (“STAAR  Group”).    The  STAAR  Group  intends  to  consolidate  the  group’s  global  operations  to  create  a  centralized  hub  to  hold  all  future
subsidiaries of the group, as well as expand into the United Kingdom market.  STAAR UK’s activity will include the training and promotion of the entire product
line with private and government hospitals in the United Kingdom.

Based on the current tax treaties there is no withholding on distributions between Switzerland and the United Kingdom, and the United Kingdom and the

U.S.  Accordingly, the Company will no longer accrue Swiss withholding tax on foreign earnings after fiscal 2018.

STAAR Surgical AG

Due  to  STAAR  Surgical  AG’s  history  of  profits,  the  deferred  tax  assets  are  considered  fully  realizable.  The  Company  had  net  deferred  tax  liabilities  in

Switzerland of $222,000 and $658,000 as of January 1, 2021 and January 3, 2020, respectively, as discussed above.

STAAR Japan, Inc.

Since 2012, STAAR Japan functions as a limited-risk distributor with a guaranteed return from STAAR AG and accordingly, STAAR Japan’s deferred tax
assets  are  considered  fully  realizable.    The  Company  had  net  deferred  tax  assets  of  $1,073,000  and  $896,000  as  of  January  1,  2021  and  January  3,  2020,
respectively.    STAAR  Japan  net  deferred  tax  assets  included  a  valuation  allowance  of  $35,000  and  $46,000  as  of  January  3,  2020  and  December  28,  2018,
respectively, related to non-deductible stock compensation for directors.

The following tax years remain subject to examination:

Significant jurisdictions
U.S. Federal
California
Switzerland
Japan

Note 11 – Employee Benefit Plans

Defined Benefit Plan – Switzerland

Open Years
2017 – 2019
2016 – 2019
2019
2018 – 2019

The Company maintains a passive pension plan (the “Swiss Plan”) covering employees of its Swiss subsidiary, which is accounted for as a defined benefit

plan.

In Switzerland employers are required to provide a minimum pension plan for their staff.  Contributions of both the employees and employer finance the
Swiss Plan. The amount of the contributions is defined by the plan regulations and cannot be decreased without amending the plan regulations. It is required that
the employer contribute an amount equal to or greater than the employee contribution.

The following table shows the changes in the benefit obligation and plan assets and the Swiss Plan’s funded status as of January 1, 2021 and January 3, 2020

(in thousands):

F-29

 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 11 – Employee Benefit Plans (Continued)

Defined Benefit Plan – Switzerland (Continued)

Change in Projected Benefit Obligation:

Projected benefit obligation, beginning of period
Service cost
Interest cost
Participant contributions
Benefits deposited (paid)
Actuarial loss
Prior service credit

Projected benefit obligation, end of period

Change in Plan Assets:

Plan assets at fair value, beginning of period
Actual return on plan assets (including foreign currency impact)
Employer contributions
Participant contributions
Benefits deposited (paid)

Plan assets at fair value, end of period
Funded status (pension liability), end of year(1)

Amount Recognized in Accumulated Other Comprehensive Income
   (Loss), net of tax:

Actuarial loss on plan assets
Actuarial loss on benefit obligation
Actuarial gain recognized in current year
Prior service credit
Effect of curtailments

Accumulated other comprehensive loss

Accumulated benefit obligation at year end

2020

2019

12,864    $
1,139   
51   
579   
6,299   
4,620   
(82)  
25,470    $

6,774    $
1,195   
704   
579   
6,299   
15,551    $

(9,919)   $

(198)   $

(8,453)  
1,029   
301   
610   
(6,711)   $

8,794 
739 
77 
458 
492 
2,429 
(125)
12,864 

5,130 
152 
542 
458 
492 
6,774 

(6,090)

(1,031)
(4,317)
744 
258 
609 
(3,737)

(24,291)   $

(12,043)

  $

  $

  $

  $

  $

  $

  $

  $

(1)

The underfunded balance was included in pension liability on the Consolidated Balance Sheets.

The change in the Projected Benefit Obligation during fiscal year 2020 was due to an increase in participant contributions, an increase in the number of
participants, a translation effect (as the Swiss Plan is in Swiss Francs but the Company’s Swiss subsidiary currency is U.S. dollar, as described in Note 1) and a
slight reduction in the discount rate.

F-30

 
 
 
 
 
   
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 11 – Employee Benefit Plans (Continued)

Defined Benefit Plan – Switzerland (Continued)

Net periodic pension cost associated with the Swiss Plan included the following components (in thousands):

Service cost(1)
Interest cost(2)
Expected return on plan assets(2)
Prior service credit(2),(3)
Actuarial loss recognized in current period(2),(3)

Net periodic pension cost

2020

Years Ended
2019

2018

  $

  $

1,139    $
51   
(264)  
(34)  
318   
1,210    $

739    $
77   
(147)  
(21)  
129   
777    $

(1) Recognized in selling general and administrative expenses on the Consolidated Statements of Income.
(2) Recognized in other income (expense), net, on the Consolidated Statements of Income.
(3) Amounts reclassified from accumulated other comprehensive income (loss).

Changes in other comprehensive income (loss), net of tax, associated with the Swiss Plan included the following components (in thousands):

Current year actuarial gain (loss) on plan assets
Current year actuarial loss on benefit obligation
Actuarial gain recorded in current year
Prior service credit
Effect of curtailments

Change in other comprehensive loss

2020

Years Ended
2019

2018

  $

  $

833    $

(4,136)  
285   
43   
1   
(2,974)   $

4    $

(2,172)  
114   
93   
—   
(1,961)   $

474 
56 
(116)
(21)
113 
506

(101)
(243)
103 
(19)
— 
(260)

Net  periodic  pension  cost  and  projected  and  accumulated  pension  obligation  for  the  Company’s  Swiss  Plan  were  calculated  on  January  1,  2021  and

January 3, 2020 using the following assumptions:

Discount rate
Salary increases
Expected return on plan assets
Expected average remaining working lives in years

2020

2019

0.2%   
2.0%   
2.5%   
10.1 

0.3%
2.0%
2.5%
10.0

The discount rates are based on an assumed duration of the pension obligations and estimated using the rates of returns for AAA and AA-rated Swiss and
foreign  CHF-denominated  corporate  bonds  listed  on  the  SIX  Swiss  Exchange.    The  salary  increase  rate  was  based  on  the  Company’s  best  estimate  of  future
increases over time.  The expected long-term rate of return on plan assets is based on the expected asset allocation and assumptions concerning long-term interest
rates,  inflation  rates,  and  risk  premiums  for  equities  above  the  risk-free  rates  of  return.  These  assumptions  take  into  consideration  historical  long-term  rates  of
return for relevant asset categories.

Under Swiss law, pension funds are legally independent from the employer and all the contributions are invested with regulated entities. The Company has a
contract  with  Allianz  Suisse  Life  Insurance  Company’s  BVG Collective  Foundation  (the  “Foundation”)  to  manage  its  Swiss  pension  fund.  Multiple  employers
contract  with  the  Foundation  to  manage  the  employers’  respective  pension  plans.  The  Foundation  manages  the  pension  plans  of  its  contracted  employers  as  a
collective entity. The investment strategy is determined by the Foundation and applies to all members of the collective Foundation. There are no separate financial
statements for each employer contract. The pension plan assets of all the employers that contract with the Foundation are comingled. They are considered multiple-
employer plans under ASC 715-30-35-70 and therefore accounted for as single-employer plans.

F-31

 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 11 – Employee Benefit Plans (Continued)

Defined Benefit Plan – Switzerland (Continued)

As there are no separate financial statements for each employer contract, there are no individual investments that can be directly attributed to the Company’s
pension  plan  assets.  However,  the  funds  contributed  by  an  employer  are  specifically  earmarked  for  its  employees  and  the  total  assets  of  the  plan  allocable  to
Company’s employees are separately tracked by the Foundation. The lack of visibility into the specific investments of the plan assets and how they are valued is a
significant unobservable input, therefore, the Company considers the plan assets collectively to be Level 3 assets under the fair value hierarchy (see Note 1).

The table below sets forth the fair value of Plan assets at January 3, 2020 and January 1, 2021, and the related activity in years ended 2019 and 2020, in

accordance with ASC 715-20-50-1(d) (in thousands):

Beginning balance at December 28, 2018

Actual return on plan assets
Purchases, sales, and settlement
Ending balance at January 3, 2020
Actual return on plan assets
Purchases, sales, and settlement
Ending balance at January 1, 2021

During fiscal year 2021, the Company expects to make cash contributions totaling approximately $775,000 to the Swiss Plan.

The estimated future benefit payments for the Swiss Plan are as follows (in thousands):

Year Ended
2021
2022
2023
2024
2025
Thereafter
Total

Defined Benefit Plan-Japan

Insurance
Contracts
(Level 3)

Amount

5,130 
152 
1,492 
6,774 
1,195 
7,582 
15,551

72 
96 
138 
156 
176 
9,281 
9,919

$

$

$

$

$

STAAR Japan maintains a noncontributory defined benefit pension plan (“Japan Plan”) substantially covering all the employees of STAAR Japan. Benefits
under the Japan Plan are earned, vested, and accumulated based on a point-system, primarily based on the combination of years of service, actual and expected
future grades (management or non-management) and actual and future zone (performance) levels of the employees.  Each point earned is worth a fixed monetary
value, 1,000 Yen per point, regardless of the level grade or zone of the employee.  Gross benefits are calculated based on the cumulative number of points earned
over the service period multiplied by 1,000 Yen.  The mandatory retirement age limit is 60 years old.

STAAR Japan administers the pension plan and funds the obligations of the Japan Plan from STAAR Japan’s operating cash flows.   STAAR Japan is not
required, and does not intend, to provide contributions to the Plan to meet benefit obligations and therefore does not have any plan assets.   Benefit payments are
made to beneficiaries as they become due.

F-32

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 11 – Employee Benefit Plans (Continued)

Defined Benefit Plan-Japan (Continued)

The funded status of the benefit plan at January 1, 2021 and January 3, 2020 was as follows (in thousands): 

2020

2019

Change in Projected Benefit Obligation:

Projected benefit obligation, beginning of period
Service cost
Interest cost
Actuarial gain
Benefits paid
Foreign exchange adjustment

Projected benefit obligation, end of period

Change in Plan Assets:

Plan assets at fair value, beginning of period
Actual return on plan assets
Employer contributions
Benefits paid
Distribution of plan assets
Foreign exchange adjustment

Plan assets at fair value, end of period
Funded status (pension liability), end of year(1)

Amount Recognized in Accumulated Other Comprehensive Income
   (Loss), net of tax:

Transition obligation
Actuarial loss
Prior service cost
Net gain

Accumulated other comprehensive income

Accumulated benefit obligation at year end

  $

  $

  $

  $

  $

  $

  $

  $

1,750    $
180   
5   
34   
(35)  
87   
2,021    $

—    $
—   
—   
—   
—   
—   
—    $

1,646 
185 
7 
(58)
(66)
36 
1,750 

— 
— 
— 
— 
— 
— 
— 

(2,021)   $

(1,750)

—    $
(38)  
7   
46   
15    $

— 
(37)
7 
68 
38 

(1,858)   $

(1,599)

(1)

The underfunded balance was included in pension liability on the Consolidated Balance Sheets.

Net periodic pension cost associated with the Japan Plan included the following components (in thousands):

Service cost(1)
Interest cost(2)
Net amortization of transitional obligation(2),(3)
Prior service credit(2),(3)

Net periodic pension cost

2020

Years Ended
2019

2018

  $

  $

180    $
5   
—   
(1)  
184    $

185 

 $

7   
—   
(1)  
191    $

153 
4 
11 
(1)
167

(1) Recognized in selling general and administrative expenses on the Consolidated Statements of Income.
(2) Recognized in other income (expense), net, on the Consolidated Statements of Income.
(3) Amounts reclassified from accumulated other comprehensive loss.

F-33

 
 
 
 
 
   
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 11 – Employee Benefit Plans (Continued)

Defined Benefit Plan-Japan (Continued)

Changes in other comprehensive income (loss), net of tax, associated with the Japan Plan include the following components (in thousands):

Amortization of net transition obligation
Amortization of actuarial loss
Prior service cost
Actuarial income (loss) recorded in current year

Change in other comprehensive income (loss)

2020

Years Ended
2019

2018

  $

  $

—    $
(1)  
—   
(22)  
(23)   $

—    $
(1)  
(1)  
30   
28    $

7 
(1)
— 
(84)
(78)

Net periodic pension cost and projected and accumulated pension obligation for the Company’s Japan Plan were calculated on January 1, 2021 and January 3,

2020 using the following assumptions:

Discount rate
Salary increases
Expected return on plan assets
Expected average remaining working lives in years

2020

2019

0.3% 
4.4% 
N/A 
10.7 

0.3%
4.5%
N/A 
10.0

The discount rates are based on the yield curve of corporate bonds rated AA or higher.  The salary increase average rate was based on the Company’s best

estimate of future increases over time.

The estimated future benefit payments for the Japan Plan are as follows (in thousands):

Year Ended
2021
2022
2023
2024
2025
Thereafter
Total

Defined Contribution Plan

Amount

104 
39 
212 
93 
212 
1,361 
2,021

$

$

The  Company  has  a  401(k)  profit  sharing  plan  (“401(k)  Plan”)  for  the  benefit  of  qualified  employees  in  the  U.S.  During  the  year  ended  January  1, 2021
employees who participate may elect to make salary deferral contributions to the 401(k) Plan up to $19,500 of the employees’ eligible payroll subject to annual
Internal  Revenue  Code  maximum  limitations  (with  a  $6,500  annual  catch-up  contribution  permitted  for  those  over  50  years  old).  The  Company’s  contribution
percentage is 80% of the employee’s contribution up to the first 6% of the employee’s compensation. In addition, STAAR may make a discretionary contribution
to qualified employees, in accordance with the 401(k) Plan.  The Company’s contributions, net of forfeitures, to the 401(k) Plan were as follows (in thousands):

Employer contributions, net of forfeitures

  $

1,281    $

1,279    $

996

2020

Years Ended
2019

2018

F-34

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 12 — Stockholders’ Equity

Incentive Plan

The Amended and Restated Omnibus Equity Incentive Plan (“the Plan”) provides for various forms of stock-based incentives. To date, of the available forms
of awards under the Plan, the Company has granted  only stock options, restricted  stock, unrestricted  share grants, RSUs and PSUs. Options under the Plan are
granted at fair market value on the date of grant, become exercisable generally over a three-year period, or as determined by the Board of Directors, and expire
over periods not exceeding 10 years from the date of grant. Certain option and share awards provide for accelerated vesting if there is a change in control and pre-
established financial metrics are met (as defined in the Plan). Grants of restricted stock outstanding under the Plan generally vest over periods of one to three years.
Grants  of  RSUs  and  PSUs  outstanding  under  the  Plan  generally  vest  based  on  service,  performance,  or  a  combination  of  both.  On  July  30,  2020,  stockholders
approved  a  proposal  to  increase  the  number  of  shares  under  the  Plan  by  2,650,000  shares,  for  a  total  of  18,035,000  shares.  As  of  January  1,  2021,  there  were
3,380,231 shares available for grant under the Plan.

Stock-Based Compensation

The  Company  recognized  a  net  income  tax  benefit  in  the  Consolidated  Statements  of  Income  for  stock-based  compensation  expense  for  incentive  stock
options and non-qualified stock options, as a result of disqualifying dispositions and exercises, respectively.   The Company does not recognize deferred income
taxes for incentive stock option compensation expense, and records a tax deduction only when a disqualified disposition has occurred (see Note 10).

The following table represents the fair value of stock-based compensation granted during the year ended 2020 (in thousands):

Stock options
Restricted stock units
Performance stock units
Restricted stock

Total stock-based compensation expense

The Company recorded stock-based compensation expense by award as follows (in thousands):

Fair Value

8,592 
4,260 
790 
644 
14,286

$

$

Employee stock option
Restricted stock
Restricted stock units
Performance stock units
Nonemployee stock options

Total stock-based compensation expense

2020

Years Ended
2019

2018

  $

  $

9,577    $
428   
1,732   
147   
262   
12,146    $

8,144    $
320   
1,905   
—   
178   
10,547    $

4,013 
274 
2,120 
— 
355 
6,762

F-35

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 12 — Stockholders’ Equity (Continued)

Stock-Based Compensation (Continued)

The Company recorded stock-based compensation expense in the following categories (in thousands):

Cost of sales
General and administrative
Selling and marketing
Research and development

Total stock-based compensation expense, net

Amounts capitalized as part of inventory

Total stock-based compensation expense, gross

2020

Years Ended
2019

2018

  $

  $

112    $

4,925   
3,471   
3,638   
12,146   
1,129   
13,275    $

52    $

4,010   
3,318   
3,167   
10,547   
1,017   
11,564    $

15 
2,635 
1,805 
2,307 
6,762 
637 
7,399

As of January 1, 2021, total unrecognized compensation cost related to non-vested stock-based compensation arrangements granted under the Plan were as

follows (in thousands):

Stock options
Restricted stock, restricted stock units and performance stock units

Total unrecognized stock-based compensation cost

This cost is expected to be recognized over a weighted-average period of approximately two years.

Assumptions

$

$

2020

12,545 
3,917 
16,462

The  fair  value  of  each  option  award  is  estimated  on  the  date  of  grant  using  a  Black-Scholes  option  valuation  model  applying  the  weighted-average
assumptions noted in the following table. Expected volatilities are based on historical volatility of the Company’s stock. The expected term of options granted is
derived  from  the  historical  exercises  and  post-vesting  cancellations,  and  represents  the  period  of  time  that  options  granted  are  expected  to  be  outstanding.  The
Company  has  calculated  an  6%  estimated  forfeiture  rate  based  on  historical  forfeiture  experience.  The  risk-free  rate  is  based  on  the  U.S.  Treasury  yield  curve
corresponding to the expected term at the time of the grant.  

Expected dividend yield
Expected volatility
Risk-free interest rate
Expected term (in years)

2020

Years Ended
2019

2018

0% 
53% 
0.53% 
5.72 

0% 
53% 
2.40% 
5.66 

0%
53%
2.71%
5.72

F-36

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 12 — Stockholders’ Equity (Continued)

Stock Options

A summary of option activity under the Plan for the year ended January 1, 2021 is presented below:

Outstanding at January 3, 2020
Granted
Exercised
Forfeited or expired
Outstanding at January 1, 2021

Exercisable at January 1, 2021

Weighted-
Average
Exercise
Price

Weighted-
Average
Remaining
Contractual
Term (years)

Aggregate
Intrinsic
Value
(in 000’s)

16.46   
28.78   
13.70   
32.35   
19.80   

15.05   

6.60    $

5.66    $

203,087 

152,218

Shares
(in 000’s)

4,326    $
621   
(1,507)  
(22)  
3,418    $

2,372    $

A summary of unvested options activity under the Plan for the year ended January 1, 2021 was as follows:

Unvested at January 3, 2020
Granted
Forfeited or expired
Vested
Unvested at January 1, 2021

Shares
(in 000’s)

Weighted-Average
Grant-Date
Fair Value

1,279    $
621   
(22)  
(832)  
1,046    $

15.44 
13.85 
16.52 
14.66 
15.09

The weighted average grant date fair value of options granted and the total intrinsic value of options exercised were as follows:

Weighted-average grant-date fair value
Intrinsic value of options (in thousands)

2020

Years Ended
2019

  $
  $

13.85    $
59,771    $

17.95    $
9,955    $

2018

11.95 
13,699

F-37

 
 
 
 
 
 
   
   
   
 
 
 
 
    
 
  
 
 
 
 
    
 
  
 
 
 
 
    
 
  
 
 
 
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 12 — Stockholders’ Equity (Continued)

Restricted Stock, Restricted Stock Units and Performance Stock Units

A summary of restricted stock, RSU and PSU activity under the Plan for the year ended January 1, 2021was as follows:

Restricted Stock

Restricted Stock Units

Performance Stock Units

Weighted-
Average
Grant-
Date Fair
Value

Units
(in 000’s)

Weighted-
Average
Grant-
Date Fair
Value

Units
(in 000’s)

Units
(in 000’s)

11    $
11   
(11)  
—   
11    $

29.39   
58.25   
29.82   
—   

59.06 

104    $
127   
(108)  
(1)  
122    $

10.79   
33.57   
12.52   
13.80   
32.97 

Weighted-
Average
Grant-
Date Fair
Value

—    $
15   
—   
—   
15    $

— 
51.42 
— 
— 
51.42

Outstanding at January 3, 2020
Granted
Vested
Forfeited or expired
Outstanding at January 1, 2021

Stock Offering  

On August 10, 2018, the Company closed an offering of its common stock.  As part of this transaction, the Company issued 1,999,850 shares of its common

stock at a price of $36.309 per share.  Net proceeds, after deducting expenses, received from this offering were $72,150,000.  

Note 13 — Commitments and Contingencies

Asset Retirement Obligation

The  Company  recorded  certain  Asset  Retirement  Obligations  (“ARO”),  in  accordance  with  ASC  410-20  in  connection  with  the  Company’s  obligation  to
return  its  Japan  facility  to  its  “original  condition”,  as  defined  in  the  lease  agreement.  The  Company  has  recorded  approximately  $221,000  and  $211,000,
representing the fair value of the ARO liability obligation in noncurrent liabilities at January 1, 2021 and January 3, 2020, respectively. This lease expires in 2021
and the Company intends to renew the lease in 2021 under similar terms and conditions.

Open Purchase Orders and Severance Payable

As of January 1, 2021, there were open purchase orders of $8,446,000.

Indemnification Agreements

The  Company  has  entered  into  indemnification  agreements  with  its  directors  and  officers  that  may  require  the  Company:  (a)  to  indemnify  them  against
liabilities that may arise by reason of their status or service as directors or officers, except as prohibited by applicable law; (b) to advance their expenses incurred as
a result of any proceeding against them as to which they could be indemnified; and (c) to make a good faith determination whether or not it is practicable for the
Company to obtain directors’ and officers’ insurance. The Company currently has directors’ and officers’ liability insurance through a third-party carrier. Also, in
connection with the sale of products and entering into business relationships in the ordinary course of business, the Company may make representations affirming,
among other things, that its products do not infringe on the intellectual property rights of others and agrees to indemnify customers against third-party claims for
such infringement as well as its negligence. The Company has not been required to make material payments under such provisions.

F-38

 
 
 
 
 
 
   
   
 
 
 
   
   
   
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
   
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 13 — Commitments and Contingencies (Continued)

Tax Filings

The Company’s tax filings are subject to audit by taxing authorities in jurisdictions where it conducts business. These audits may result in assessments of
additional taxes that are subsequently resolved with the authorities or potentially through the courts. Management believes the Company has adequately provided
for taxes; however, final assessments, if any, could be significantly different than the amounts recorded in the consolidated financial statements.

Employment Agreements

The Company’s Chief Executive Officer entered into an employment agreement with the Company, effective March 1, 2015. She and certain officers have as
provisions  of  their  agreements  certain  rights,  including  continuance  of  cash  compensation  and  benefits,  upon  a  “change  in  control,”  which  may  include  an
acquisition of substantially all its assets, or termination “without cause or for good reason” as defined in the employment agreements.

Litigation and Claims

On August 19, 2020, a putative federal securities class action, Alwazaan v. STAAR Surgical Co., et al., was filed against the Company and certain of its
executives in the U.S. District Court for the Central District of California. On September 1, 2020, a substantially similar federal securities class action, Zhang v.
STAAR Surgical Co., et al., was filed against the Company and the same executives in the U.S. District Court for the Central District of California. On September
11,  2020,  the  court  consolidated  the  two  actions  under  the  caption  In  re  STAAR  Surgical  Co. Securities  Litigation.  The  plaintiffs  in  the  lawsuit  allege  that  the
Company  made  material  misstatements  regarding  its  sales  in  China,  its  marketing  spend,  and  its  R&D  expenses.  Plaintiffs  seek  compensatory  and  punitive
damages as well as attorneys’ fees.  On October 29, 2020, the court appointed a lead plaintiff.  On January 15, 2021, the lead plaintiff filed a notice of voluntary
dismissal of the lawsuit, which dismissed the lead plaintiff's claims with prejudice as to him, and without prejudice as to any absent putative class members.

On December 31, 2020, Amir Sitabkhan filed a stockholder derivative complaint against certain members of our Board of Directors, Caren Mason, Stephen
C. Farrell, John C. Moore, and Louis E. Silverman, as well as current Chief Financial Officer (CFO) Patrick F. Williams and former CFO Deborah Andrews in the
U.S. District Court for the Central District of California. The plaintiff alleges breaches of fiduciary duties by, among other things, allowing STAAR to disseminate
misleading statements to investors regarding its sales and growth in China and overstating marketing and research and development expenses, failing to properly
oversee the Company, and unjust enrichment. The complaint seeks damages, restitution and governance reforms, attorneys’ fees, and costs. On January 21, 2021,
the court granted the parties’ stipulation extending the time for defendants to respond to the complaint to March 8 2021.  Although the ultimate outcome of this
action cannot be determined with certainty, the Company believes that the allegations in the Complaint are without merit.

Note 14 — Related Party Transactions  

The Company has made various advances to certain non-executive employees.  Amounts due from employees are included in prepayments, deposits, and

other current assets at January 1, 2021 and January 3, 2020 were as follows (in thousands):  

Due from employees

2020

2019

  $

5    $

1

F-39

 
 
 
 
 
   
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 15 — Supplemental Disclosure of Cash Flow Information

The Company’s non-cash investing and financing activities, and cash paid were as follows (in thousands):

Non-cash investing and financing activities:

ROU assets obtained in exchange for new finance
     lease liabilities
Purchase of property and equipment included in
     accounts payable

Cash paid:
Interest
Taxes

Note 16 — Basic and Diluted Net Income Per Share

2020

Years Ended
2019

2018

  $

  $

  $
  $

22    $

679    $

1,656 

523    $

381    $

64    $
1,336    $

105    $
792    $

207 

130 
635

The following table sets forth the computation of basic and diluted net income per share (in thousands except per share amounts):

Numerator:

Net income
Denominator:

Weighted average common shares:
Common shares outstanding
Less:  Unvested restricted stock

Denominator for basic calculation

Weighted average effects of potentially diluted common stock:

Stock options
Unvested restricted stock
Restricted stock units
Performance stock units

Denominator for diluted calculation

Net income per share:

Basic

Diluted

2020

Years Ended
2019

2018

  $

5,913    $

14,048    $

4,968 

45,616   
(11)  
45,605   

2,272   
4   
71   
1   
47,953   

44,504   
(11)  
44,493   

2,254   
6   
142   
—   
46,895   

  $

  $

0.13    $

0.12    $

0.32    $

0.30    $

42,598 
(11)
42,587 

2,360 
10 
300 
— 
45,257 

0.12 

0.11

The following table sets forth (in thousands) the weighted average number of options to purchase shares of common stock, restricted stock, RSUs and PSUs
with either exercise prices or unrecognized compensation cost per share greater than the average market price per share of the Company’s common stock, which
were not included in the calculation of diluted per share amounts because the effects would be anti-dilutive.

Stock options
Restricted stock, restricted stock units and performance stock units

Total

F-40

2020

Years Ended
2019

2018

20   
—   
20   

1,503   
—   
1,503   

315 
— 
315

 
 
 
 
 
 
 
 
 
   
   
 
 
 
    
 
    
 
  
 
 
    
 
    
 
  
 
 
 
 
 
 
 
   
   
 
 
 
    
 
    
 
  
 
 
    
 
    
 
  
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 17 — Disaggregation of Revenues, Geographic Sales and Product Sales

In the following tables, revenues are disaggregated by category, sales by geographic market and sales by product data.  The following breaks down revenues

into the following categories (in thousands):  

Non-consignment sales
Consignment sales
Total net sales

2020

137,369    $
26,091   
163,460    $

  $

  $

Years Ended
2019

132,716    $
17,469   
150,185    $

2018

106,338 
17,616 
123,954

The Company markets and sells its products in more than 75 countries and conducts its manufacturing in the United States. Other than China and Japan, the
Company does not conduct business in any country in which its sales in that country exceed 10% of consolidated net sales. Sales are attributed to countries based
on location of customers. The composition of the Company’s net sales to unaffiliated customers was as follows (in thousands):

Domestic
Foreign:

China(1)
Japan
Other(2)

Total foreign sales
Total net sales

2020

Years Ended
2019

2018

  $

6,158    $

8,106    $

7,316 

71,692   
34,986   
50,624   
157,302   
163,460    $

64,820   
26,881   
50,378   
142,079   
150,185    $

46,070 
23,151 
47,417 
116,638 
123,954

  $

(1)
The China region includes sales into China and Hong Kong.  
(2) No other location individually exceeds 10% of the total net sales.

100%  of  the  Company’s  sales  are  generated  from  the  ophthalmic  surgical  product  segment  and  the  chief  operating  decision  maker  makes  the  operating
decisions and allocates resources based upon the consolidated operating results, therefore, the Company operates as one operating segment for financial reporting
purposes. The Company’s principal products are IOLs used in cataract surgery and ICLs used in refractive surgery.  The composition of the Company’s net sales
by product line was as follows (in thousands):

ICLs
Other product sales

IOLs
Other surgical products

Total other product sales

Total net sales

2020

Years Ended
2019

2018

  $

141,407    $

129,322    $

101,082 

13,574   
8,479   
22,053   
163,460    $

15,689   
5,174   
20,863   
150,185    $

16,193 
6,679 
22,872 
123,954

  $

The Company sells its products internationally, which subjects the Company to several potential risks, including fluctuating exchange rates (to the extent the
Company’s transactions are not in U.S. dollars), regulation of fund transfers by foreign governments, U.S. and foreign export and import duties and tariffs, and
political instability

F-41

 
 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
   
 
 
 
    
 
    
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 18 —Geographic Assets

The composition of the Company’s long-lived assets between those in the U.S., Japan and Switzerland is set forth below as of January 1, 2021 and January 3,

2020 (in thousands):

Property, plant and equipment, net
Finance lease ROU assets, net
Operating lease ROU assets, net
Intangible assets, net

Total

Property, plant and equipment, net
Finance lease ROU assets, net
Operating lease ROU assets, net
Intangible assets, net

Total

U.S.

Japan

Switzerland    

Total

2020

19,289    $
527   
4,380   
83   
24,279    $

420    $
69   
530   
187   
1,206    $

2019

4,321    $
—   
3,854   
—   
8,175    $

24,030 
596 
8,764 
270 
33,660 

U.S.

Japan

Switzerland    

Total

14,956    $
1,756   
2,920   
83   
19,715    $

306    $
80   
919   
213   
1,518    $

1,803    $
31   
2,845   
—   
4,679    $

17,065 
1,867 
6,684 
296 
25,912

  $

  $

  $

  $

Note 19 — Quarterly Financial Data (Unaudited)

Summary unaudited quarterly financial data from continuing operations for years ended 2020 and 2019 was as follows (in thousands except per share data).
The  Company  has  derived  this  data  from  the  unaudited  consolidated  interim  financial  statements  that,  in  the  Company’s  opinion,  have  been  prepared  on
substantially the same basis as the audited financial statements contained elsewhere in this report and include all normal recurring adjustments necessary for a fair
presentation of the financial information for the periods presented. These unaudited quarterly results should be read in conjunction with the financial statements
and notes thereto included elsewhere in this report. The operating results in any quarter are not necessarily indicative of the results that may be expected for any
future period.

January 1, 2021
Net sales
Gross profit
Net income (loss)
Net income (loss) per share – basic
Net income (loss) per share – diluted

January 3, 2020
Net sales
Gross profit
Net income
Net income per share – basic
Net income per share – diluted

  $

  $

1st Quarter

2nd Quarter    

3rd Quarter    

4th Quarter

35,187    $
24,760   
(134)  
—   
—   

35,194    $
24,430   
(1,172)  
(0.03)  
(0.03)  

47,081    $
34,871   
3,892   
0.08   
0.08   

45,998 
34,301 
3,327 
0.07 
0.07 

1st Quarter

2nd Quarter    

3rd Quarter    

4th Quarter

32,583    $
24,180   
1,367   
0.03   
0.03   

39,664    $
29,899   
3,914   
0.09   
0.08   

39,055    $
29,051   
2,388   
0.05   
0.05   

38,883 
28,824 
6,379 
0.14 
0.14

Quarterly  and  year-to-date  computations  of  net  income  per  share  amounts  are  made  independently.  Therefore,  the  sum  of  the  per  share  amounts  for  the

quarters may not agree with the per share amounts for the year.

F-42

 
 
 
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
    
 
  
 
 
 
 
 
   
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
    
 
    
 
    
 
  
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

Note 20 – Reclassifications

Certain amounts in previously issued financial statements related to income tax expense, deferred taxes and valuation allowance have been reclassified to

conform to fiscal 2020 presentation.

Note 21 – COVID-19 and CARES Act Developments

In December 2019, COVID-19 surfaced and in March 2020, the World Health Organization declared a pandemic related to the rapid spread of COVID-19
around the world.  The impact of the COVID-19 outbreak on the businesses and the economy in the U.S. and the rest of the world is, and is expected to continue to
be, uncertain and may continue to be significant. Accordingly, the Company cannot predict the extent to which its financial condition and results of operation will
be affected. On March 17, 2020, the Company suspended most of its production and non-essential business locations where employees can work from home.  A
very  limited  number  of  manufacturing  personnel  remained  at  work  for  critical  late  staged  processes,  until  the  end  of  March  2020.    Manufacturing  resumed  on
April 27, 2020.  The Company’s revenues have been adversely impacted, and the Company experienced a substantial slowdown in sales beginning March 20, 2020
in global geographies characterized as “hot spots” for the COVID-19 virus, including parts of Europe, North America, Asia, the Middle East and India.  In certain
of these markets, sales have paused as elective surgeries are discouraged to support COVID-19 related needs.  The Company expects decreases in sales in certain
geographies to continue in 2021 as different geographies resume business activities on differing timelines.  

The CARES Act, among other things, includes provisions relating to refundable payroll tax credits, deferment of employer side social security payments, net
operating loss carryback periods, alternative minimum tax credit refunds, modifications to the net interest deduction limitations, increased limitations on qualified
charitable  contributions,  and  technical  corrections  to  tax  depreciation  methods  for  qualified  improvement  property.    The  Company  did  not  apply  for  or  require
financing available under the CARES Act and does not expect to do so.  The Company will continue to monitor the impact that the CARES Act may have on its
business, financial condition, results of operations, or liquidity.

The CAA among other things, opened up another round of Paycheck Protection Program loans, expanding eligibility to small nonprofits, destination marking
organizations,  and  housing  cooperatives,  provided  additional  funding  for  the  Economic  Injury  Disaster  Loans  and  grants,  extends  the  Employee  Retention  Tax
Credit, also extended and expanded Paid Sick and Family Leave Credits and the Employee Social Security tax deferral.  The Company will continue to monitor the
impact that the CAA may have on its business, financial condition, results of operations, or liquidity.

F-43

 
 
 
 
STAAR SURGICAL COMPANY AND SUBSDIARIES

SCHEDULE II — VALUATION AND QUALIFYING ACCOUNTS AND RESERVES

Column A

Description

2020

Allowance for doubtful accounts
Sales return reserve
Deferred tax asset valuation allowance

2019

Allowance for doubtful accounts
Sales return reserve
Deferred tax asset valuation allowance

2018

Allowance for doubtful accounts
Sales return reserve
Deferred tax asset valuation allowance

  Column B    
Balance at
Beginning
of Year

Column C - Additions

Column D     Column E  

Charged to
costs and
expenses

Charged to

other accounts     Deductions
(in thousands)

Balance at
End of
Year

115   $
6,182    
5,640    
11,937   $

(320)  $
6,183    
(5,124)   
739   $

207   $
5,474    
2,534    
8,215   $

  $

  $

  $

  $

  $

  $

88    $
3,644     
37,007     
40,739    $

550    $
2,895     
43,075     
46,520    $

349    $
2,182     
40,656     
43,187    $

F-44

—    $
—     
—     
—    $

—    $
—     
—     
—    $

—    $
—     
—     
—    $

144    $
5,294     
145     
5,583    $

142    $
5,434     
944     
6,520    $

6    $
4,761     
115     
4,882    $

59 
4,532 
42,502 
47,093 

88 
3,644 
37,007 
40,739 

550 
2,895 
43,075 
46,520

 
 
 
 
   
 
   
   
   
 
 
 
 
   
      
     
      
      
  
   
   
 
   
      
     
      
      
  
   
   
 
   
      
     
      
      
  
   
   
 
 
 
Subsidiaries of STAAR Surgical Company

Exhibit 21.1

Name of Subsidiary
STAAR Surgical UK LTD
STAAR Surgical AG
STAAR Japan Inc.
STAAR Surgical PTE. LTD
STAAR Optical Equipment
Technology (Shanghai) Co., LTD
STAAR Surgical CHINA 
CO., LTD
STAAR Surgical India Private Limited

Other Names Under
Which it Does Business
None
None
STAAR Japan Godo Kaisha
None

None

None
None

State or Other
Jurisdiction of Incorporation
United Kingdom
Switzerland
Japan
Singapore

China

China
India

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

Exhibit 23.1

STAAR Surgical Company
Lake Forest, California

We hereby consent to the incorporation by reference in the Registration Statements on Form S-3 (No. 333-217888, No. 333-148902, No. 333-143131, No. 333-
124022, No. 333-116901 and No. 333-238043) and Form S-8 (No. 333-228138, No. 333-213046, No. 333-201232, No. 333-167595, No. 333-111154 and No. 333-
240332) of STAAR Surgical Company of our reports dated February 24, 2021, relating to the consolidated financial statements and financial statement schedules,
and the effectiveness of STAAR Surgical Company’s internal control over financial reporting, which appear in this Annual Report on Form 10-K.

/s/ BDO USA, LLP

Los Angeles, California
February 24, 2021

 
 
 
Exhibit 31.1

I, Caren Mason certify that:

1. I have reviewed this annual report on Form 10-K of STAAR Surgical Company;

CERTIFICATIONS

2.  Based  on  my  knowledge,  this  report  does  not  contain  any  untrue  statement  of  a  material  fact  or  omit  to  state  a  material  fact  necessary  to  make  the

statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.  Based  on  my  knowledge,  the  financial  statements,  and  other  financial  information  included  in  this  report,  fairly  present  in  all  material  respects  the

financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4.  The  registrant’s  other  certifying  officer(s)  and  I  are  responsible  for  establishing  and  maintaining  disclosure  controls  and  procedures  (as  defined  in
Exchange Act Rules 13a-15(e) and 15d-15(e))  and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f))  for the
registrant and have:

a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to
ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

b)  Designed  such  internal  control  over  financial  reporting,  or  caused  such  internal  control  over  financial  reporting  to  be  designed  under  our
supervision,  to  provide  reasonable  assurance  regarding  the  reliability  of  financial  reporting  and  the  preparation  of  financial  statements  for  external
purposes in accordance with generally accepted accounting principles;

c)  Evaluated  the  effectiveness  of  the  registrant’s  disclosure  controls  and  procedures  and  presented  in  this  report  our  conclusions  about  the

effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent
fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect,
the registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the

registrant’s auditors and the audit committee of registrant’s board of directors (or persons performing the equivalent functions):

a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably

likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control

over financial reporting.

Dated: February 24, 2021

/s/ CAREN MASON
Caren Mason
President, Chief Executive Officer, and 
Director (principal executive officer)

 
 
 
 
 
 
 
Exhibit 31.2

I, Patrick F. Williams, certify that:

1. I have reviewed this annual report on Form 10-K of STAAR Surgical Company;

CERTIFICATIONS

2.  Based  on  my  knowledge,  this  report  does  not  contain  any  untrue  statement  of  a  material  fact  or  omit  to  state  a  material  fact  necessary  to  make  the

statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3.  Based  on  my  knowledge,  the  financial  statements,  and  other  financial  information  included  in  this  report,  fairly  present  in  all  material  respects  the

financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this report;

4.  The  registrant’s  other  certifying  officer(s)  and  I  are  responsible  for  establishing  and  maintaining  disclosure  controls  and  procedures  (as  defined  in
Exchange Act Rules 13a-15(e) and 15d-15(e))  and internal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f))  for the
registrant and have:

a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to
ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities,
particularly during the period in which this report is being prepared;

b)  Designed  such  internal  control  over  financial  reporting,  or  caused  such  internal  control  over  financial  reporting  to  be  designed  under  our
supervision,  to  provide  reasonable  assurance  regarding  the  reliability  of  financial  reporting  and  the  preparation  of  financial  statements  for  external
purposes in accordance with generally accepted accounting principles;

c)  Evaluated  the  effectiveness  of  the  registrant’s  disclosure  controls  and  procedures  and  presented  in  this  report  our  conclusions  about  the

effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation; and

d) Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s most recent
fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected, or is reasonably likely to materially affect,
the registrant’s internal control over financial reporting; and

5. The registrant’s other certifying officer(s) and I have disclosed, based on our most recent evaluation of internal control over financial reporting, to the

registrant’s auditors and the audit committee of registrant’s board of directors (or persons performing the equivalent functions):

a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably

likely to adversely affect the registrant’s ability to record, process, summarize and report financial information; and

b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control

over financial reporting

Dated: February 24, 2021

/s/ PATRICK F. WILLIAMS
Patrick F. Williams
Chief Financial Officer 
(principal financial officer)

 
 
 
 
 
 
 
CERTIFICATION PURSUANT TO 18 U.S.C. SECTION 1350,
AS ADOPTED PURSUANT TO SECTION 906 OF THE SARBANES-OXLEY ACT OF 2002

In connection with the filing of the Annual Report on Form 10-K for the year ended January 1, 2021 (the “Report”) by STAAR Surgical Company (“the

Company”), each of the undersigned hereby certifies that:

1. The Report fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended, and

2. The information contained in the Report fairly presents, in all material respects, the financial condition and results of operations of the Company as

Exhibit 32.1

of and for the periods presented in the Report.

Dated:February 24, 2021

Dated: February 24, 2021

/s/ CAREN MASON
Caren Mason
President, Chief Executive Officer, 
and Director (principal executive officer)

/s/ PATRICK F. WILLIAMS
Patrick F. Williams
Chief Financial Officer 
(principal financial officer)

A signed original of this statement has been provided to the Company and will be retained by the Company and furnished to the Securities and Exchange

Commission or its staff upon request.