RICOH AMERICAS

CODE OF ETHICS

Message from the Ethics Officer

As Ricoh employees, the RICOH Way defines who we are and brings all employees together to share a common set
of core values. This includes our commitment to the highest standards of ethics and integrity and how we must act
with integrity and honesty in all situations and take personal responsibility for our actions. This shared
commitment is defined in the guiding Principles of ethics and integrity set forth in our Code of Ethics which we
must live by every day.

Our Code of Ethics and company policies provide the framework and principles to guide our decisions and actions
and how we interact with each other, our customers, our communities and our environment. The Code and policies
are resources designed to help us understand our responsibility for acting with integrity and to create an awareness
of the many legal, regulatory and ethical issues we may face. When confronted with those issues, compliance with
the Code’s Principles is essential. However, the Code of Ethics does not address every situation in which an ethical
dilemma may be presented. Should you find yourself in a difficult or unusual situation, the rules are simple:
follow the Code’s direction, use common sense and good business judgment, be honest, and act with integrity.

Every Ricoh employee is expected to understand and abide by each of the Principles of the Code of Ethics every
day and in every situation. Periodically you will be asked to certify that you have read and understand the Code of
Ethics, and you will be required to participate in Code of Ethics training sessions as directed by management.

We all have a responsibility to report behavior or activities that may violate the Code of Ethics. There are a number
of reporting options:

• If you prefer the option of reporting anonymously, 24 hours a day, 7 days a week, you can:

o Scan QR code via mobile device

o Call the EthicsPoint toll-free telephone hotline at 866-258-6637 or
o Report your concerns online by accessing the Compliance and Ethics Portal under the Legal
Department in RWorld.
• You may call the HR Advisory Line at 1-844-RICOH HR (844-742-6447) Monday through Friday (8 a.m.
– 8 p.m. EST).
• Visit askHR on RWorld
• You may speak with your manager or their manager.
• There is an Ombudsperson (610-408-2069 or 123@ricoh-usa.com), whose role is to ensure you receive an
answer to your concern.
• You may report a possible violation of the Code of Ethics or company policy to a member of the Business
Ethics Committee or the Ethics Officer.

Your report of unlawful or unethical behavior or a violation of company policy will be reviewed promptly, and the
Company will not tolerate threats or acts of retaliation against you for making that report.

At Ricoh, we are committed to fostering trust, honesty and integrity throughout the organization. We are confident
that this commitment is the foundation of a healthy and productive work environment.

Christine Czarnecki Ciarrocchi

VP, Deputy General Counsel & Corporate Secretary

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 RICOH AMERICAS
CODE OF ETHICS
PRINCIPLE #1: Compliance with Law and Company Policy
Employees are responsible for knowing and adhering to all laws and Company policies relevant to their work
responsibilities, including being aware of and abiding by laws and policies related to employment discrimination
and harassment, workplace violence, drugs and alcohol, health, safety and the environment, fair competition, anti-
corruption/anti-bribery, and international trade.

PRINCIPLE #2: Protecting the Company’s Assets and Resources

The protection of the Company’s assets and business interests is critical to the Company’s operations and
employees are expected to use the Company’s assets and resources for business purposes.

PRINCIPLE #3: Proprietary Information and Intellectual Property

Employees are personally responsible for protecting the Company’s proprietary information, such as the
Company’s intellectual property and confidential information, which are valuable assets. Employees must protect
the intellectual property of the Company from improper use or disclosure and respect the intellectual property rights
of others. All employees are subject to an agreement in which they assigned to the Company their rights to any
intellectual property they develop. To protect the Company’s proprietary information, employees must not use or
disclose the Company’s confidential information at any time without proper authorization.

PRINCIPLE #4: Reporting, Recording and Retaining Information

All information submitted to the Company must be recorded and reported accurately, completely and honestly.
Recording or reporting any information in a way that could be misleading is strictly prohibited. The use or
disclosure of material non-public information about the Company or another company, such as a supplier or
business partner, is a violation of the Company policy and may be unlawful. External communications, including
press releases, speeches, interviews or through social media, which might be attributed to the Company, must be
authorized in advance. All Company records and data should be retained and disposed of in accordance with the
Company’s Records Creation and Retention Policy.

PRINCIPLE #5: Protecting Private Information

The Company’s business depends to a large extent on the trust and confidence employees, customers and other
stakeholders place in the Company’s ability to protect personal, private and confidential information. Employees
who may have access to personal information as part of their work, such as information about other Company
employees, customers and their clients or patients, suppliers and others, may use such information only to the
extent necessary to perform their assigned responsibilities and in accordance with applicable Company policies and
procedures.

PRINCIPLE #6: Conflicts of Interest

A conflict of interest occurs when an individual’s private interest (or the interest of a member of their family)
interferes, or appears to interfere, with the interests of the Company. A conflict of interest can arise when an
employee takes actions or has interests that may make it difficult to perform their role for the Company in an

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objective and effective manner, or when an employee receives improper personal benefits as a result of their
position in the Company. Employees must avoid situations in which their loyalty may become divided.

PRINCIPLE #1: Compliance with Law and Company Policy

Employees are responsible for knowing and adhering to all laws and Company policies relevant to their
work responsibilities, including being aware of and abiding by the laws and policies related to employment
discrimination and harassment, workplace violence, drugs and alcohol, health, safety, and the environment,
fair competition, anti-corruption/anti-bribery, and international trade.

A. Workplace Conduct
The Company is committed to provide a work environment free from discrimination, sexual harassment or any
other harassment based on race, color, religion, gender, age, ethnicity, sexual orientation, marital status, national
origin, disability, status as a special disabled veteran, other covered veteran, newly separated veteran or veteran of
the Vietnam era or any other legally protected status. The Company has a zero tolerance level for discrimination or
harassment, and any employee found to have engaged in such behavior will be disciplined.

While the Company cannot discipline non-Company personnel or change conduct at other companies, if Company
employees become the victims of discrimination or harassment at non-Company facilities by employees of
companies with which we do business, the Company will take reasonable steps to eliminate discrimination or
harassment of its employees occurring in the course of the performance of their work at locations controlled by
customers or other third-parties.

Other conduct that is prohibited because of its adverse impact on the work environment includes: (1) threats or
violent behavior; (2) the possession of weapons of any type; and (3) the use, distribution or possession of illegal
drugs or any other controlled substance, except for approved medical purposes. In addition, employees should not
be on the Company’s premises or in the work environment if they are under the influence of or affected by illegal
drugs, controlled substances used for nonmedical purposes, or alcoholic beverages. Consumption of alcoholic
beverages on Company premises is only permitted with prior management approval, for company-sponsored
events.
See also:
Policy Number HRP01CEN – Non-Discrimination and Anti-Harassment Policy
Policy Number HRP15 – Substance Abuse Control
Policy Number HRP51 – Workplace Standards of Conduct
Policy Number HRP52 – Workplace Violence

B. Health, Safety and Environmental Practices

The Company is strongly committed to the principle that our activities will not harm the health and safety of our
employees or the environment. You must comply with applicable laws and regulations and if faced with an
environmental health or safety violation or concern, you must report it to your manager or Human Resources
Business Partner.

The Ricoh Group is a global leader in the area of environmental sustainability. Ricoh and its employees seek to
implement technological innovations that reflect environmental concerns and participate in ongoing activities to
preserve the environment. The Ricoh Group has developed a number of principles in respect to the global
environment that are observed around the globe: For example, the Ricoh Group encourages the development of
innovative environmental technologies that create customer value and can be used widely in society. Ricoh makes
every effort to reduce environmental impact at all stages of the product cycle, from procurement of materials,
through production, sales, distribution, recycling and disposal. Finally, the Company is aware of the environmental

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impact of its activities and seeks continuous improvement to reduce pollution and ensure the effective use of energy
and other resources.

C. Competing Fairly
You may not engage in a sales practice that is intended to mislead a customer or vendor or misrepresent the
Company or its services or products. If you are performing a marketing, sales or service activity, you are expected
to compete lawfully, ethically, vigorously and effectively. All comparisons to competitors and their products must
be substantiated and be accurate and not misleading.

D. Antitrust Violations
Competition laws prevent interference with the functioning of a competitive market system. Under these laws,
companies may not enter into agreements with other companies, including their distributors and dealers, which
unreasonably restrict the functioning of the competitive system. You may not agree with representatives of
competitors to:

• fix prices or any other economic terms of sale or purchase;

• set terms of bid or whether or not to bid;
• allocate markets or customers; boycott competitors, customers or suppliers; or
• restrain competition.

In all contacts with competitors, do not discuss pricing policy, contract terms, costs, inventories, marketing and
product plans or any other Company proprietary or confidential information. Discussion of these subjects or
collaboration on them with competitors can be illegal.

E. Bribery and Corruption

You must comply with the Company’s Anti-Corruption / Anti-Bribery Policy, which prohibits giving, receiving or
offering anything of value to a government official or member of a political party of any country or international
organization for the purpose of obtaining or keeping business or in furtherance of routine governmental action.
Acceptable practices in the commercial business environment, such as providing education, transportation, meals,
entertainment or other things of value, may be entirely unacceptable, and may even violate certain federal, state,
local or foreign laws and regulations, when the Company is dealing with government employees or those who act
on the government’s behalf. Therefore, you must be aware of, and adhere to, the relevant laws and regulations
governing relations between government employees and customers, business partners, and suppliers in every
territory where you conduct business. You must not give money or a gift to an official or an employee of a
governmental entity if doing so could be reasonably construed as having any connection with the Company’s
business relationship. U.S. and foreign laws often prohibit such actions; for example, the Foreign Corrupt Practices
Act (FCPA), a U.S. law, makes it a crime to pay money or give anything of value to a foreign official to assist the
company or another to obtain or retain business with the government, whether the improper payment or gift is made
directly by a company or indirectly through someone acting for the company. If you have any questions about the
applicable law or regulations, you should consult your manager or an attorney in the Ricoh Legal Department.

See also:
Policy Number L-11 – Anti-Corruption / Anti-Bribery Policy
Policy Number HRP05 – Gratuity and Gift Policy

F. Public Sector Procurement Regulations

If your responsibilities include selling to customers in the public sector, you must understand and adhere to all
applicable public sector procurement laws and regulations and must immediately report any actual or possible
violation of a public sector procurement law or regulation. During the course of a public sector procurement, you

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should not try to improperly influence the decisions of the customer or obtain restricted information about the
procurement.
G. International Operations
Employees of Ricoh subsidiaries in countries other than the U.S. and Employees conducting business across
country borders must comply with all applicable laws, Company policies and all local subsidiary policies and rules
and regulations of the countries in which the business is transacted. For example, most countries in which the
Company operates regulate the import and export of products and technology, affecting how and in which countries
the Company may transact business. Company technology in the form of products, services and technical data
relating to the design, production and use of the products and services is subject to both U.S. and non-U.S. export
laws and regulations. Before the Company’s products and technical data can be exported or shipped outside the
U.S. or another country, the Company must obtain an export authorization from the U.S. and any applicable non-
U.S. government.

Export laws apply to all international transactions, including international intercompany activity and where the
recipient is a non-U.S. person located in the U.S. These laws also apply to transactions with customers and
suppliers and when the Company uses business partners, subcontractors or agents to complete delivery or provide a
service. In addition, export laws cover more than just shipments of equipment – also covered are electronic
transfers of technical data, software or technology, the provision of services over the Internet, application
development and delivery, and e-commerce activities. It is against the law to engage in export activities without
proper authorization or to facilitate the unauthorized transfer of Company technology.

The Company must comply with import regulations and requirements when engaging in international trade.
Employees need to be aware of import regulations and requirements, as a failure to comply with the law can result
in fines, penalties, imprisonment and/or loss of import privileges.

H. Legal Matters
Employees must consult with the Ricoh Legal Department on all legal issues, including but not limited to customer
requests for non-standard contract terms, receipt of legal documents such as subpoenas ordering the Company to
produce internal communications or to respond to questions, and notices from government agencies. Additionally,
employees must consult with the Ricoh Legal Department before signing a contract or other legal document on
behalf of the Company.

See also:
Ricoh Personnel's Guide to Referring Legal Matters

PRINCIPLE #2: Protecting the Company’s Assets and Resources

The protection of the Company’s assets and business interests is critical to the Company’s operations and
employees are expected to use the Company's assets and resources for business purposes.

A. Improper Use of Company Assets and Information Technology Resources

Employees have access to many Company assets and resources, including office equipment and supplies,
corporate credit cards, mail resources and Company and customer facilities. Employees are expected to use all
these assets and resources for Company business or for purposes authorized by management.

The Company’s information technology and communications systems, including connections to the Internet, are
vital to the business – they should be used only for appropriate purposes. Limited non-business use of the
Company’s information technology resources and communications systems is permitted, provided good judgment
is exercised regarding the reasonableness of personal use. It is inappropriate to use the Company’s systems to visit
Internet sites that are offensive, feature sexual conduct, gambling, or advocate intolerance. Inappropriate use of the

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Company’s systems, as determined in management’s sole and complete discretion, is a misuse of the Company’s
assets.

In the event of theft, illegal or improper use of the Company’s assets, including its information technology
resources, the Company will take disciplinary action against the offending employee, up to and including dismissal,
and may pursue legal action or refer the matter to law enforcement authorities.

See also:
Policy Number HRP39 – Personal Use of Company Property Policy
Policy Number ITP01 – Electronic Communications & Use Policy

B. Payments to Outside Parties

Employees have a duty to safeguard the Company’s assets and resources and to make all business decisions in the
best interest of the Company. Business must be awarded solely on merit, without favoritism, so that the Company
can be assured that it acquires products and services on the basis of quality and cost. Any payment made to an
outside party, such as a vendor, customer or business partner, must be properly authorized in accordance with
Company policies and procedures.

PRINCIPLE #3: Proprietary Information and Intellectual Property

Employees are personally responsible for protecting the Company’s proprietary information, such as the
Company’s intellectual property and confidential information, which are valuable assets. Employees must
protect the intellectual property of the Company from improper use or disclosure and respect the intellectual
property rights of others. All employees are subject to an agreement in which they assigned to the Company
their rights to any intellectual property they develop. To protect the Company’s proprietary information,
employees must not use or disclose confidential information at any time without proper authorization.
A. Disclosure of Confidential or Proprietary Information
The disclosure of Company confidential or proprietary information, whether intentional or unintentional, can injure
the Company financially and competitively. Confidential information about the Company, its business interests,
employees, customers or suppliers should not be disclosed to other employees unless they have a business need-to-
know such information. Company confidential, proprietary or other nonpublic information must not be disclosed to
anyone outside the Company without prior authorization from management, working in consultation with the Ricoh
Legal Department. A written confidentiality agreement is required to disclose confidential information to a third
party. Notwithstanding an employee's duty not to disclose confidential or proprietary information, the Defend Trade
Secrets Act of 2016 (the “Act”) provides that: (1) An individual shall not be held criminally or civilly liable under
any Federal or State trade secret law for the disclosure of a trade secret that: (A) is made – (i) in confidence to a
Federal, State, or local government official, either directly or indirectly, or to an attorney; and (ii) solely for the
purpose of reporting or investigating a suspected violation of law; or (B) is made in a complaint or other document
filed in a lawsuit or other proceeding, if such filing is made under seal. The Act further provides that: an
individual who files a lawsuit for retaliation by an employer for reporting a suspected violation of law may disclose
the trade secret to the attorney of the individual and use the trade secret information in the court proceeding, if the
individual: (A) files any document containing the trade secret under seal; and (B) does not disclose the trade secret,
except pursuant to court order.
B. Securing Confidential Information
Employees must secure documents containing confidential or proprietary information from unauthorized access and
public view. This includes documents stored in electronic format. When such information is being discarded, steps
must be taken to ensure proper destruction.

See also:
Policy Number ITP02 – Confidential Information Policy

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Policy Number APM GP-2 – Record Creation and Retention Policy

C. Protecting the Company’s Intellectual Property

The Company’s intellectual property includes ideas, concepts, know-how, techniques, inventions, software,
publications and other materials related to the Company’s current or anticipated product or service offerings and
research and development activities. The Company owns all rights to the intellectual property developed by
employees using the Company’s time, materials or facilities, or relating to any aspect of the Company’s business,
plans, products, software or proposals, no matter where or when the intellectual property is created – at work or
after hours. Employees must disclose that intellectual property to the Company and protect it like any other
Company confidential, proprietary or non-public information. Employees must provide their assistance to allow
the Company to capture, perfect and maintain its rights in such intellectual property. In addition, employees must
seek advice and direction from Ricoh’s U.S. Intellectual Property Office before filing for a patent other than
through the Company. Further, employees are required to provide the Company with copies of any patents they
have applied for or obtained. Before employees publicly disclose or offer for sale any new products or services for
the first time, employees should confirm that Ricoh’s U.S. Intellectual Property Office has filed, or has had the
opportunity to file, any patent applications for inventions related to the products or services.

The Company uses trademarks – words, names, symbols or designs – to identify and distinguish the Company and
its products and services. It is important that employees properly use the Company’s and any third party
trademarks. Further, employees may not use a word, name, symbol or design as a trademark without first obtaining
approval from the Company’s Marketing Department.

D. Protecting the Intellectual Property of Others

Software includes computer programs, applications, web-based services, databases and related documentation.
Software may be on CDs, portable devices, in publications or other tangible media, or may be downloadable or
accessible for use online. Software may only be used with the owner’s permission and employees must comply
with the terms of use applicable to the license for the software, including how and where it may be used, whether it
may be modified or distributed and, especially in the case of open source software, what rights the Company may
be obligated to grant to others. For assistance in understanding our license rights and obligations, you should
consult with the Ricoh Legal Department.

Employees may not copy for distribution any non-Company copyrighted documents or materials without the
copyright owner’s permission; nor may employees copy any form of recorded media or rebroadcast any television
or internet program, including any music, or incorporate such program, music or creative work into a Company
production, or have music performed or images displayed at a Company event, without first obtaining the owner’s
permission. Employees also are prohibited from including a customer’s name, logo or trademark in any external
communication, such as marketing materials or a press release, without first obtaining the customer’s written
consent.

PRINCIPLE #4: Reporting, Recording and Retaining Information

All information submitted to the Company must be recorded and reported accurately, completely and
honestly. Recording or reporting any information in a way that could be misleading is strictly prohibited.
The use or disclosure of material non-public information about the Company or another company, such as a
supplier or business partner, is a violation of Company policy and may be unlawful. External
communications, including press releases, speeches, interviews or through social media, which might be
attributed to the Company, must be authorized in advance. All Company records and data should be
retained and disposed of in accordance with the Company’s Record Creation and Retention Policy.

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 A. Maintaining Accurate Books and Records
Employees must record and report information accurately and honestly. Accurate reporting of time worked and
business expenses incurred is critical. The submission of fraudulent claims for time or expenses will result in
termination of employment.

Company financial statements and the records on which they are based must always accurately and fairly reflect
actual activities and transactions. All reports and documents submitted to or retained for review and audit by
government agencies or customers and any other public communications made by the Company must contain full,
fair, accurate, timely, and understandable disclosure. No undisclosed or unrecorded Company funds or assets shall
be established for any purpose, nor should Company funds be placed in any personal or non-corporate account. No
employee shall make an entry on the Company’s books and records that intentionally hides or disguises the true
nature of a transaction. Altering contract documents without authorization, executing side letter agreements or
falsifying customer signatures are all strictly prohibited.

You must ensure that you do not make false or misleading statements in financial reports and other documents
submitted to or maintained for government agencies, or in status reports on contracts, particularly in situations
where the Company is selling equipment or providing services to a government customer.

B. Use of Non-public or “Inside” Information

The use of non-public information about the Company or another company, such as a supplier or business partner,
for personal financial benefit is unethical and may be a violation of law. Under U.S. securities law, a person who
possesses “material” non-public information about a company is prohibited from trading on that knowledge and
may not disclose the information to others who may trade. Non-public information is deemed material if there is a
substantial likelihood that the disclosure of the information would have been viewed by a reasonable investor to
substantially alter the “total mix” of information that is available about the company.

C. Public Statements and Personal Communications

Any public statement that might be attributed to the Company, including speeches, news releases and interviews,
must be carefully considered by the Company senior management and may be made only by an authorized
individual. Therefore, you may not speak publicly on behalf of the Company, and Company business units may not
issue news releases or other public information about the Company, unless such activity has been approved by the
Company’s Communications team. You must refer inquiries about the Company received from the media, industry
or financial analysts, or others to an authorized individual on the Communications team.

You must keep your personal views separate from Company views. Without prior approval from your Human
Resources business partner, you may not use Company stationery or titles in communications involving non-
Company business (e.g., a letter to the editor or to an elected official), and you should not associate the Company
with or imply the Company endorses your personal opinions.

See also:
Policy Number MKT-01; SLP-016 – News Media Policy

D. Social Networking
Social media includes all forms of public, web-based communication and expression that brings people together by
making it easy to publish content to many audiences including, but not limited to, personal websites, web logs
(blogs), news groups and discussion forums. Some examples include: Twitter, Facebook, You Tube, LinkedIn,
Snapchat and Instagram. Your personal social media networking activities may not interfere with your job duties
or customer commitments. Without the prior written approval of the Vice President leading your functional area
and the Company’s Senior Vice President, Marketing, employees are strictly prohibited from: (i) creating work-
related social media networking sites that contain Company confidential information; (ii) acting as a Company
spokesperson; or (iii) appearing to provide Company information on behalf of the Company on a social networking
site.

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See also:
Policy Number ITP03 – Social Media Policy

E. Creation and Retention of Records

All employees must comply with the Company’s Record Creation and Retention Policy. The Policy is applicable
to documents in any form of media, including hard copy and electronic records such as email. You may not destroy
or alter any document that is subject to a hold order issued by Company legal counsel. Such documents are or may
be relevant to a threatened or pending lawsuit or government investigation.

See also:
Policy Number APM GP-2 – Record Creation and Retention Policy

PRINCIPLE #5: Protecting Private Information

The Company’s business depends to a large extent on the trust and confidence employees, customers and
other stakeholders place in the Company’s ability to protect personal, private and confidential information.
Employees who may have access to personal information as part of their work, such as information about
other Company employees, customers and their clients or patients, suppliers and others, may use such
information only to the extent necessary to perform their assigned responsibilities and in accordance with
applicable Company policies and procedures.

A. Employee Private Information

The Company and its parent and subsidiary companies collect and maintain personal information that relates to
your employment, including compensation, medical and benefit information. Because the Company is part of a
global organization with business processes and systems that cross country borders, you acknowledge that the
Company may transfer personal information about you as an employee to any of the countries where Ricoh
Company, Ltd., our parent company, and its subsidiaries (collectively, the Ricoh Group) do business. The Ricoh
Group has world-wide policies that are intended to protect information wherever it is stored or processed, and
access to your personal information is restricted to people with a need-to-know.

Information that you consider private should not be placed or kept anywhere in the Company workplace and the
Company’s management has the right to access network communications systems and devices, office systems,
electronic files, offices, desks, lockers and any other Company furnished facilities. The Company’s
communications network and technology, as well as the IT resources that support them, are provided to facilitate
Company business and are the property and assets of the Company. Employees or others who access or use
Company resources (including Company applications) and/or equipment should have no expectation of privacy
with regard to their use of these resources, even if the resources and/or equipment are used for personal purposes.
The Company may, at its option, search IT equipment and communications devices or audit the use of its resources
to ensure compliance with Company policies, including searching any messages sent, stored, posted or received on
them.

B. Receiving and Handling the Private Information of Customers and other Stakeholders
Individuals, such as consumers, and our customers and their employees, clients, and patients, also are concerned
about the privacy of their personal information. The Company is dedicated to protecting the privacy of personal
information of others and will only collect, use, process, and disclose an individual’s personal information in
accordance with the Company’s privacy policies and applicable law.

Employees whose responsibilities include the receipt or handling of Personally Identifiable Information (PII) of
other employees or of our customers have a continuing obligation to respect the security and confidentiality of

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those employees’ and customers’ non-public personal information, and must take reasonable measures to protect
against unauthorized access to or use of PII. In addition, employees with access to the Personal Health Information
(PHI) of other employees, or of the Company’s customers and their clients, must ensure they comply with all
administrative, physical and technical safeguards established by the Company to protect PHI, and must report any
actual or suspected data breaches to their manager immediately. Under the laws of the U.S. and many states and
countries, significant fines and possible jail time can apply to data breaches involving PHI, and breach response
costs can be enormous.

See also:
Policy Number SLP-065 – Privacy and Protection of Personally Identifiable Information
Policy Number HRP19 – Employment Records Policy

PRINCIPLE #6: Conflicts of Interest

A conflict of interest occurs when an individual’s private interest (or the interest of a member of their
family) interferes, or appears to interfere, with the interests of the Company. A conflict of interest can arise
when an employee takes actions or has interests that may make it difficult to perform their role for the
Company in an objective and effective manner, or when an employee receives improper personal benefits as
a result of their position in the Company. Employees must avoid situations in which their loyalty may
become divided.

A. Outside Affiliations and Interests

You should have no relationship with any supplier, customer, competitor or other party that creates or appears to
create a conflict of interest. If you plan to become affiliated (for example, as an employee, director, consultant or
agent) or acquire a significant ownership interest in any business entity that is a Company supplier, customer,
competitor, or that otherwise does business with the Company, you must report the proposed affiliation to your
Human Resources business partner and request that the Company’s Business Ethics Committee review the
proposed affiliation. If the affiliation creates or appears to create a conflict of interest, the Committee may deny
your request to enter into the affiliation, or require certain conditions or limitations.

The Company expects its employees to be fully committed to their job responsibilities. You may not engage in any
outside activity or employment if it will negatively impact your ability to perform your work responsibilities at the
Company.

B. Family and Personal Relationships

When an employee’s family member or close friend (living in the same household) works or is otherwise involved
with a Company supplier, customer, competitor or a business entity which does business with the Company, there
is a potential for favoritism or inappropriate sharing of confidential information. All such situations must be
reviewed with your Human Resources business partner and approved by the Business Ethics Committee.

The Company prohibits intimate personal relationships between a member of the Company’s management team
and any employee within his/her chain of command, whether direct or through matrix reporting.

See also:
Policy Number HRP21 – Personal Relationships Policy

C. Accepting or Giving Gifts

Employees must comply with the Company Gratuity/Gift Policy, and maintain the highest ethical standards when
receiving gifts from, or giving gifts to, customers, suppliers or business partners.

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You must not personally give, accept or solicit, either directly or indirectly, gifts, loans, unusual hospitality,
preferential treatment or any other thing of genuine value from potential or existing customers, suppliers or vendors
if there is a pending business decision involving the Company or the other party.

Employees are prohibited from giving gifts to or accepting gifts from employees of federal, state, provincial or
local governments or governmental entities.

See also:
Policy Number HRP05 – Gratuity and Gift Policy

D. Political Contributions and Lobbying

Any contact with government personnel for the purpose of influencing legislation or rule making, including such
activity in connection with procurement matters, is considered lobbying. Some laws also define lobbying even
more broadly to include normal marketing activities. You are responsible for knowing and adhering to all the
relevant lobbying laws and associated gift laws, if applicable, and for compliance with all reporting requirements.
You may not use Company resources to make direct or indirect political contributions unless you obtain approval
from the Ricoh Legal Department. For example, you may not use Company funds to support lobbying efforts, to
make contributions or loans to political parties or candidates, to purchase tickets for political fundraising events, or
to furnish goods or services for a political cause at other than normal and customary prices.

Asking Questions; Reporting Noncompliance

You are required to promptly report any potential or actual noncompliance with the Code of Ethics (by you or
another Company employee). Failure to report any potential or actual noncompliance with the Code of Ethics is
itself a violation of the Code. The Company will maintain confidentiality to the extent possible during a compliance
investigation, and will not tolerate retribution or retaliation of any kind against a person for reporting in good faith
an incident of noncompliance by another Company employee.

Every employee must read, understand and sign a certification acknowledging their agreement to comply with the
Code of Ethics. The Code may be revised and updated from time to time, and Company employees are responsible
for reading and complying with all updates. As a convenience, links to relevant Company policies are provided
throughout the Code of Ethics to provide easy reference to additional information about the Code’s principles.
Compliance with the Code of Ethics is a condition of employment. An employee who fails to comply with the Code
of Ethics, a Company policy, or the laws and regulations applicable to the Company’s businesses activities will be
subject to disciplinary action, up to and including dismissal.

Administration of the Code of Ethics

The Business Ethics Committee has the responsibility and authority to define and interpret the principles contained
in the Code of Ethics and to review and address significant ethical questions or issues which arise. Managers are
encouraged to consult with their Human Resources business partner or a member of the Ricoh Legal Department
for assistance in addressing employee issues and concerns related to the Code of Ethics.

Application of the Code of Ethics

The Code of Ethics, and each of the Principles contained in it, applies to every director, officer, member of the
Senior Management team and employee of Ricoh USA, Inc. and its subsidiaries wherever located, including the
direct and indirect subsidiaries of Ricoh Canada, Inc. and Ricoh Latin America, Inc (collectively and individually
referred to herein as the “Company”).

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 Who to Contact
If you have questions or wish to report suspected violations of the Code of Ethics, there are a number of reporting
options:

• If you prefer the option of reporting anonymously, 24 hours a day, 7 days a week, you can:

o Scan QR code via mobile device

o Call the EthicsPoint toll-free telephone hotline at 866-258-6637 or
o Report your concerns online by accessing the Compliance and Ethics Portal under the Legal
Department in RWorld.
• You may call the HR Advisory Line at 1-844-RICOH HR (844-742-6447) Monday through Friday (8 a.m.
– 8 p.m. EST).
• Visit askHR on RWorld
• You may speak with your manager or their manager.
• There is an Ombudsperson (610-408-2069 or 123@ricoh-usa.com), whose role is to ensure you receive an
answer to your concern.
• You may report a possible violation of the Code of Ethics or company policy to a member of the Business
Ethics Committee or the Ethics Officer.

Business Ethics Committee

George Gowen (610) 408-2998
Senior Vice President, Chief Financial and Legal Officer

Donna Venable (610) 408-7412

Executive Vice President, Human Resources
and Deputy General Manager, Shared Services

Ethics Officer
Christine Czarnecki Ciarrocchi (610) 408-7221
VP, Deputy General Counsel & Corporate Secretary

U.S. Human Resources Ethics Advisor

Michael Jones (678) 728-8014
Vice President, Human Resources

Canada Human Resources Ethics Advisor

Peter Pontone (905) 795-5779
Vice President, Human Resources

Latin America Human Resources Ethics Advisor

Lorna Hernandez, PHR (954) 745-3388
Vice President, Human Resources

Internal Audit
Jennifer Kirwin (610) 408-7146
Senior Director, Internal Audit

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