Ricoh Group Code of Conduct

7. Ensuring fair corporate activities

7.1 Free competition and fair trading

The Ricoh Group will remain in strict compliance with the laws and regulations governing the banning of monopolies, fair competition, and fair trading, and will take no action seeking to evade them.

(1) We will enter no agreements or discussions for the reciprocal limitation of corporate activities.

Officers and Employees will not participate in discussions or agreements with competitors in the same industry to impose reciprocal limits on corporate freedom of action in connection with the conditions of competitive bids, product pricing, conditions of sale, profits, market share, sales areas, etc.

(2) We will not exploit our trading position.

Officers and Employees will not exploit our trading position to impose unprofitable transactions upon our trading partners, not will we impose limitations on trading between our trading partners and third parties.

(3) We will not make inappropriate displays not offer inappropriately large premiums or prizes.

Officers and Employees shall not provide displays nor offer inappropriately large premiums or prizes that might lead customers to a mistaken choice of product.

• Related Standards:
• "Manual for Compliance with Antimonopoly Law"
• Ricoh Group Basic Regulation for the Prevention of Cartels (RGS-ALAA1009)

7.2 Proper control of exports and imports

In order to realize security trade control and proper export/import procedures for the purpose of maintaining international peace and security, the Ricoh Group is required to comply with laws and regulations concerning export/import in the country/region (group companies in Japan in the case of "Foreign Exchange and Foreign Trade Law" and "Customs Law"), will not act against laws and regulations concerning export/import in the United States and laws concerning export/import of trading partner countries.

(1) Applicability assessment for trading goods and technologies

Officers and Employees shall, in accordance with the internal procedures specified by company regulations, judge beforehand whether any restrictions apply to the export or import of goods (products, components, equipment, materials) or related technologies, and record the result.

(2) Customer and trading assessment (Assessing the necessity of export/import permit)

When exporting, importing goods or providing related technologies, Officers and Employees shall confirm beforehand whether such transactions would infringe the export import relevant laws and regulations or require a permit, based on the result of the judgment of applicable restrictions and the customer and usage requirements assessment. When restrictions are found to be applicable, appropriate export/import procedures shall be followed.

(3) Export restrictions for non-proliferation

When trading goods or related technologies, whether or not restrictions are found to be applicable, Officers and Employees shall voluntarily apply controls in the spirit of export restrictions for non-proliferation.
Officers and Employees will not conduct transactions if the goods to be traded and the technologies to be provided are likely to be used for diversion, development, etc. of weapons related. Also, if there is any doubt, after strict customer review and transaction review, leaving a record of the examination, whether the transaction is possible or not shall be determined by the export import control person who is prescribed by the compliance rules of the export and import related laws and regulations or the Ricoh Group Rules on compliance with Export & Import related legislation.

• Related Standards:
• Ricoh Group International Trade Regulation (RGS-ATRA0003)
• Ricoh Group Rules on compliance with Export & Import related legislation (RGS-ATRA0001)
• Invoice Requirements (RGS-ATRC0002)
• Country of Origin Management (RGS-ATRC0004)
• Management Standard for Export-controlled Goods (RGS-ATRC0005)

7.3 Promote responsible procurement

The Ricoh Group is concerned with ESG (Environment, Society, Governance) in the supply chain, and it is sound that it is working with suppliers to solve or improve those tasks in response to various problems in their respective fields. The Ricoh Group believes that it will be the driving force for development to enterprises, ultimately realize a sustainable society, and will proceed from the viewpoint of long-term improvement of corporate value.

(1) Present procurement guidelines and request cooperation

Officers and Employees shall present to the suppliers the specific content of social responsibility they should fulfill.

(2) Confirm the status of initiatives and support improvement

Officers and Employees shall confirm suppliers' compliance with the guidelines and the status of their efforts by questionnaire, etc., and support the improvement of problems at suppliers as necessary.

7.4 Limits on entertainment and gifts

The Ricoh Group, in giving entertainment or gifts will not give bribes nor depart in any other way from general good business practice.

(1) Entertainment and gifts for public officials and government officials

Officers and Employees shall be in compliance with laws and regulations that exist in each country, region and area, when entertaining and giving gifts to officials of public agencies such as government, foreign public officials, those deemed to be civil servants in laws and regulations of each country, and government officials.

(2) Entertainment and gifts for business partners other than the above

Officers and Employees shall not give business partners, etc. inappropriate entertainment or gifts contrary to laws and sound business practices.

(3) Reception of entertainment and gifts

Officers and Employees shall immediately report to their superiors and ask for directions, when receiving entertainment or gifts.

• Related Standards:
• Ricoh Group Standard for Bribery Prevention (RGS-ALAA1010)

7.5 Doing business with public bodies and making political contributions

The Ricoh Group, in doing business with public bodies and making political contributions, will be in compliance with the relevant laws.

(1) Strict impartiality

Officers and Employees, when doing business with government departments or regional (local) authorities, shall comply strictly and impartially with the relevant legal requirements and regulations, always taking care to avoid legal problems.

(2) No improper political contributions

Officers and Employees, except where otherwise permitted by law, shall not in the course of business make contributions to politicians or candidates for political office, nor to political organizations, nor shall they cooperate directly or indirectly in political campaigning.

7.6 Prohibition on activities relating to Organized Crime Syndicates

The Ricoh Group takes a firm attitude against any groups or individuals that pursue economic profits through the use of violence, threats or fraud, even those who appear lawful (“Organized Crime Syndicates”) and will have absolutely no relationship with them.

(1) No relationship with Organized Crime Syndicates.

Officers and Employees must have absolutely no relationship with Organized Crime Syndicates that pose threats to the safety and order of civil society and disrupt economic activity.

(2) Rejecting any unjustified demands from Organized Crime Syndicates

Officers and Employees, if presented with extortion or any unjustified demands by Organized Crime Syndicates, shall not compromise with them by paying money or in any other way. Officers and Employees shall immediately report such demands to their superior, and the superior must contact its general administration department.

(3) No dealings with Organized Crime Syndicates

Officers and Employees shall not engage in any transaction with Organized Crime Syndicates.

7.7 Individual actions against the interests of the company

The Ricoh Group does not approve any actions by its officers or employees that would cause, or might threaten to cause, any disadvantage to the Ricoh Group in the performance of its normal business activities.

(1) Inform the Company

Officers and Employees shall not take any actions that would conflict with the interests of the company, or that might lead to such a conflict of interest. When such a situation arises, the Officers and Employees shall immediately inform their superior of the fact.

(2) Obtain Prior Company Approval.

Officers and Employees must obtain prior company permission before accepting appointment as officers of other companies or organizations, and before entering into employment contracts.

(3) No Competition without Permission.

Officers and Employees shall not, without first obtaining company permission, engage in any personal activities that would constitute competition with the Ricoh Group, nor shall they accept appointment in the management of a competitive company.

• Related Standards:
• "Employment regulations"