Ricoh Group Code of Conduct

8. Earning trust by proper information management

8.1 Managing corporate secrets

Information that the Ricoh Group has acquired or created in the course of business must, depending on its importance, be treated as a corporate secret and managed with all proper care. Again, the information from third parties (including customers, client companies, subordinate companies) that the Ricoh Group has collected or that has been entrusted by third parties must be similarly managed as corporate secrets.

(1) Obey management rules

Officers and Employees, when they have received information, materials, or documents in the course of business, should notify their supervisor, and manage them in accordance with the applicable rules of the company concerned. Again, they must continue to obey these rules even after their employment has terminated.

(2) Only those authorized should reveal confidential information

Officers and Employees, when they are requested to answer questions or to provide materials, whether by someone inside or outside the company, unless they clearly have the required authority to reply to the question or to provide the materials, they should refer the request to a superior for instructions.

(3) No private use shall be made of such information

Officers and Employees shall only use corporate secrets in the course of the company's business, and neither during their employment nor after it has terminated, shall they make any use of it for themselves or for others.

(4) No acquisition of information by dishonest means

Officers and Employees shall not acquire information from third parties by dishonest means.

(5) No use of information other than for specified purpose and conditions.

When Officers and Employees acquire information from third parties in accordance with a contract, they must use it exclusively for the purpose and conditions of that contract.

• Related Standards:
• Ricoh Group Corporate Secret Management Regulations (RGS-AGAA0002)
• ISMS Management Standards (for ISMS-SCOs) (RGS-AITC0008)

8.2 Banning insider trading

The Ricoh Group shall not do anything that would undermine healthy and fair trading in securities market, such as taking advantage of insider information to which it gains access in the course of business to make profits.

(1) No disclosures to third parties

If Officers or Employees have come to know insider information in the ordinary course of business, they shall not disclose it to third parties who do not have a need to know it in the performance of their duties.

(2) No use for personal gain

Officers and Employees who have come to know insider information concerning the Ricoh Group or other companies either in the course of business or as a result of it, shall not trade the securities of the Ricoh Group nor or the other companies nor engage in any other related trades.

• * "Insider information" is unpublished information on increases (or reductions) in capitalization, agreements for business cooperation, sales figures, profits or other important internal information.

8.3 Proper management of personal information

The Ricoh Group properly manage and operate personal information of as customers and employees.

(1) Handle in accordance with related laws and internal regulations

Officers and employees must recognize the importance of personal information and handle it appropriately in accordance with relevant laws and regulations and internal rules in its collection, storage, use and disposal.

8.4 Protection and use of intellectual properties

The Ricoh Group will encourage activities that create intellectual properties of value to the Ricoh Group and will seek to protect and utilize them appropriately.

(1) Rapid Notification

Intellectual properties created at work all belong to the company. Officers and Employees shall notify the company immediately of all intellectual properties created at work (with patents, this includes free patents).

(2) Respect the rights of outside parties

Officers and Employees shall respect the rights of outside parties and ensure that, as they perform their duties, such rights are not infringed.

(3) Follow procedures for their disclosure and provision

Officers and Employees, when announcing intellectual properties to academic conferences or disclosing and licensing intellectual properties to outside parties when implementing a new business model, shall follow both Ricoh Group policy and standard procedures before doing so.

• * The intellectual properties referred to here are patents, utility models, designs, registered trademarks, copyrights on programs, rights to use specific circuit configurations, etc.

8.5 Protection of corporate assets

The Ricoh Group has established rules for the control of corporate assets (products, fixtures, information, and all other assets both tangible and intangible) and these must be rigorously implemented.

(1) Appropriate Controls

Officers and Employees must control corporate assets appropriately in strict conformity with the rules.

(2) No Improper Use

Officers and Employees must make no private use of any of the company's assets outside the requirements of their normal duties.

• Related Standards:
• "Employment regulations"

8.6 Providing proper information

The Ricoh Group will promote two-way communication with a wide range of stakeholders, and actively seek to provide proper and unbiased disclosure of corporate information.

(1) Actively disclose information

Accurately publicizing the Ricoh Group’s corporate attitudes is the first prerequisite for deeper mutual understanding between the group and society. In order to ensure that as many people as possible have a proper understanding of the Ricoh Group, Officers and Employees must follow the normal procedures and actively provide fair and timely information.

(2) Keep accurate records and make accurate reports

Officers and Employees must keep accounting and financial records in compliance with the relevant laws and company regulations. Again, such records must be prepared so that their content is complete, fair, accurate, timely and readily understandable.