Ricoh Group Code of Conduct

The Ricoh Group Code of Conduct is intended to establish the basic standards to ensure that each company, executives and employees of the Ricoh Group, when engaging in corporate activities to advance the Ricoh Group, shall act in accordance with social ethics and in full compliance with the law.

Contents

1. Proactive leadership of top management
2. Providing value beyond customer and society's expectations
3. Behaviors respecting human rights
   1. Respect for Human Rights of Stakeholders
   2. Human Rights Due Diligence
   3. Remedy
4. Pursuit of attractive work & life
5. Conservation of the global environment
6. Coexistence with the community
7. Ensuring fair corporate activities
   1. Free competition and fair trading
   2. Proper control of exports and imports
   3. Promote responsible procurement
   4. Limits on entertainment and gifts
   5. Comply with laws and regulations relating to dealings with public institutions and political contributions
   6. Prohibition on activities relating to Organized Crime Syndicates
   7. Individual actions against the interests of the company
8. Earning trust by proper information management
   1. Managing corporate secrets
   2. Banning insider trading
   3. Proper management of personal information
   4. Protection and use of intellectual properties
   5. Protection of corporate assets
   6. Providing proper information