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                                                                      Exhibit 11

[LOGO] RICOH

THE RICOH GROUP
CODE OF CONDUCT

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                                   Ricoh Group
                  Corporate Social Responsibility (CSR) Charter

To be an enterprise whose growth and development is welcomed in society, and to
discharge its "Corporate Social Responsibility" (CSR) from a global perspective
in every aspect of its operations, the Ricoh Group shall comprehend and comply
with the laws and regulations of each and every country, and the international
rules and underlying sprits thereof pursuant to the following principles, in
addition to acting with good and sound social sense.

Integrity in Corporate Activities

1.   Every company in the Ricoh Group shall develop and provide useful,
     environmental-conscious and customer-friendly products and services that
     exceed in quality, safety, information security and reliability.

2.   Every company in the Ricoh Group shall engage in fair, open and free
     competition, and maintain normal and healthy relationships with political
     and governmental figures and bodies, citizens and organizations.

3.   Every company in the Ricoh Group shall ensure proper control and protection
     of its own information and that of its customers.

Harmony with the Environment

4.   Every company in the Ricoh Group shall make efforts, as a responsible
     global citizen, to voluntarily and actively conserve the environment.

5.   Every company in the Ricoh Group and all employees of such company shall
     seek to implement technological reforms that take the environment into
     consideration and shall continuously participate to conserve the
     environment.

Respect for People

6.   Every company in the Ricoh Group shall maintain a safe and comfortable
     working environment for all persons connected with the corporate activities
     of the Ricoh Group and respect the personalities of all of its employees to
     foster their sense of independence and creativity.

7.   Every company in the Ricoh Group shall respect the rights of all those
     concerned, and seek to create a cheerful working environment without
     discrimination.

8.   No company in the Ricoh Group shall permit any form of forced labor or
     child labor, or participate in any activity that infringes upon human
     rights.

Harmony with Society

9.   Every company in the Ricoh Group shall, as a "good corporate citizen,"
     actively engage in activities that contribute to society.

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10.  Every company in the Ricoh Group shall respect the cultures and customs of
     every country and region, and operate its business in such a manner that
     contributes to their development.

11.  Every company in the Ricoh Group shall communicate with society and ensure
     that its corporate information is disclosed actively, properly and fairly.

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Message from the CEO
as to the Establishment of the Ricoh Group Corporate
Social Responsibility Charter

     Aiming to create a harmonious relationship with and earn trust from
society, Ricoh enacted the Ricoh Business Code of Conduct in April 1993 as the
standard of each director, officer and employee of the Group for both corporate
and individual activities, and has acted to achieve its management philosophy.

     Furthermore, each group company has engaged in activities that are in line
with its own code of conduct, which was established based on the Ricoh model.
Such actions have served to enhance the reputation of the entire Group.

     Nowadays, companies, as global citizens as well as members of society, are
becoming more and more important in their roles and influences. Accordingly,
companies are being asked to switch their activities from those that contribute
to society to those that are responsible to society. In other words, socially
responsible management of companies are beginning to be sought to a greater
degree. This means that it has become even more important for companies to carry
out their corporate activities with a greater sense of responsibility towards
ethics, morals and responsibility, not to speak of, compliance with the laws and
regulations.

     Along with the recent trend towards the globalization of corporate
activities and group management, the Ricoh Group has been increasingly composed
of people with different values from a variety of countries around the world,
and therefore the need to establish values and standards of behavior that can be
shared throughout the group has been growing.

     Under such circumstances, we reviewed the original Ricoh Business Code of
Conduct from the perspective of "a corporation that undertakes activities with a
sense of responsibility towards achieving harmony with society as well as the
environment." Consequently, we established "the Ricoh Group CSR Charter" as the
document that sets forth the principles of our corporate activities to be shared
globally within the Ricoh Group, and "the Ricoh Group Code of Conduct" as the
document that sets forth the standard of conducts or attitudes that individual
members within the Ricoh Group should follow.

     To attain Ricoh Group's goal of becoming a "Reliable and Attractive Global
Enterprise" and to remain a group that is loved by society and whose growth and
development is welcomed, it is strongly expected that every group company and
individual member thereof adhere to and act to achieve the philosophy of this
Ricoh

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Group CSR Charter and this Ricoh Group Code of Conduct.

January 1, 2004

                                                              Masamitsu SAKURAI
                                                              President and CEO,
                                                              Ricoh Group

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CONTENTS

<TABLE>
<S>                                                                                <C>
General Principles..................................................................7

Integrity in Corporate Activities

   1  Providing customer-friendly products.........................................10
   2  Free competition and fair trading............................................11
   3  Prohibition of insider trading...............................................12
   4  Managing corporate secrets...................................................13
   5  Limitation on entertainment and gifts, etc...................................14
   6  Transactions with public bodies and management of political contributions....15
   7  Strict control of exports and imports for international peace and security...16
   8  Protection and application of intellectual properties........................18
   9  Prohibition of anti-social activities........................................19
   10 Prohibition of individual activities that are against the
      interests of the company.....................................................20
   11 Protection of corporate assets...............................................21

Harmony with the Environment

   12 Respect for the global environment...........................................22

Respect for People

   13 Respect for human rights.....................................................24

Harmony with Society

   14 The practice of contributions to society.....................................25
   15 Mutual understanding with society............................................26

Implementation.....................................................................27
</TABLE>

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General Principles

OBJECTIVE

The objective of the Ricoh Group Code of Conduct (hereinafter referred to as the
"Code") is to set forth the basic standards of conduct that Officers and
Employees of the companies within the Ricoh Group shall follow to comply with
the laws and regulations and observe to abide by the social ethics in developing
the Ricoh Group's corporate activities.

DEFINITIONS

The definitions of the terms used in this Code are as follows:

1.   "Ricoh" means Ricoh Company, Ltd.

2.   "Affiliate" means a consolidated subsidiary of Ricoh and a company
     substantially controlled by Ricoh.

3.   "Ricoh Group" means Ricoh and its Affiliates.

4.   "Officers and Employees" means directors, statutory auditors, officer,
     board members, all persons who are subject to the Employment Regulations
     (SHUGYO KISOKU) of each company and all others who are in an employment
     relationship with a company within the Ricoh Group (including part-time or
     temporary employees).

APPLICABILITY

1.   This Code applies to Officers and Employees.

2.   Each Affiliate shall appoint a responsible person to implement this Code
     and make every effort to ensure its implementation. However, under the
     following circumstances, each Affiliate may, pursuant to the resolution of
     its board of directors, enact supplemental provisions to this Code to the
     extent they are consistent with this Code:

     (1)  when modifications are necessary due to changes in the laws and
          regulations, commercial customs, employment practices, or values in a
          specific country or region; or

     (2)  when modifications are necessary due to the nature of the business or
          the type of products or transactions that a company within the Ricoh
          Group engages in or enters into.

     Each Affiliate shall report such supplemental provisions to the central
     authority in charge of this Code.

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BASIC ATTITUDES TO BE ADOPTED BY OFFICERS AND EMPLOYEES

It is important that all Officers and Employees, as individuals, citizens and
business persons, understand the following basic concepts and seek to implement
them in their daily activities.

1.   Officers and Employees shall always be attentive to, seek to understand,
     and act in compliance with, the laws and regulations in each and every
     country or region.

2.   Officers and Employees shall recognize their social responsibilities, and
     act with common sense as good citizens with high ethical and moral
     standards.

3.   Officers and Employees shall respect each other's personalities and values,
     and act in a self-controlled way as a good business person. In addition,
     Officers and Employees shall comply with all the basic rules of the Ricoh
     Group, including its regulations, standards, etc., draw distinctions
     between business and personal matters, and act with a full sense of
     responsibility as a member of the Ricoh Group.

4.   Officers and Employees shall make efforts to achieve customer satisfaction
     recognizing that all activities, not limited to those involving direct
     contact with customers such as sales and maintenance services, are always
     evaluated by them.

5.   To stay keenly aware of the various developments and problems, Officers and
     Employees shall act autonomously and always seek to maintain the creativity
     to freely generate new ideas so as to create new values.

6.   Officers and Employees shall put themselves, not only in the place of their
     customers, but also in the place of their counterparties, business partners
     and fellow employees, and make themselves useful.

7.   Officers and Employees shall make every effort to balance the growth of the
     company and their own personal happiness, and to seek to realize rich and
     full personal lives.

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BASIC ATTITUDE OF THE RICOH GROUP TOWARDS ITS EMPLOYEES

The Ricoh Group shall take the following measures to ensure that all employees
can act on the above-mentioned Basic Attitudes, make the fullest use of their
abilities and self-actualize:

1.   Desiring their growth as human beings and responding to their wish for
     self-actualization both in and outside of the work setting, the Ricoh Group
     shall create and provide a wide range of opportunities for
     self-actualization to its employees.

     The Ricoh Group shall create a free and healthy corporate atmosphere in
     which each employee can gain a sense of self-existence, self-development
     and self-confidence, and act freely based on his or her creativity.

2.   The Ricoh Group shall cherish and seek to actively utilize each employee's
     specialized abilities, while at the same time provide proper support for
     proactive efforts by each employee to enhance his or her specialized
     abilities by establishing a system or entering into an arrangement that
     encourages such proactive efforts.

3.   By making an objective and fair evaluation of each employee's achievement,
     the Ricoh Group shall promote vitality within the Group.

     The Ricoh Group shall specify items and standards used for the evaluation
     of its employees, fairly evaluate the degree of achievement of each
     employee's goals, the ability to perform his or her duties, the degree of
     his or her contributions and other factors, and reward each employee based
     on such evaluation.

4.   The Ricoh Group shall develop and maintain a safe, healthy, comfortable and
     efficient work environment, and make effort to shorten working hours and
     provide various work conditions and types of employment to accommodate a
     wide variety of lifestyles.

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Integrity in Corporate Activities

1    PROVIDING CUSTOMER-FRIENDLY PRODUCTS

..    Basic Policy

          The Ricoh Group's basic policy is to develop and provide products and
          services to its customers from the customer's point of view.

..    Model Conduct

          (1)  WE SEEK TO SOLVE THE CUSTOMERS' PROBLEMS.

                    Officers and Employees shall actively seek to identify the
                    customers' problems, and make an effort to solve such
                    problems.

          (2)  WE SEEK TO EARN THE CUSTOMERS' TRUST.

                    Officers and Employees shall consider quality, safety,
                    information security, reliability, environmental
                    conservation and user-friendliness in developing products
                    and services to be provided to the customers.

          (3)  WE SEEK TO HEIGHTEN CUSTOMER SATISFACTION.

                    Officers and Employees shall regularly assess the level of
                    satisfaction of the customers, and make every effort to
                    improve its products and services to attain higher levels of
                    satisfaction by the customers.

..    Related Standards:

                    Ricoh Group Quality Assurance Regulation (RGS-AQAA0001)

                    Ricoh Group Product Safety Regulation (RGS-AQAA0002)

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2    FREE COMPETITION AND FAIR TRADING

..    Basic Policy

          The Ricoh Group shall strictly comply with the applicable laws and
          regulations of each and every country and region with respect to
          anti-monopoly, fair competition and fair trade, and shall not take any
          action to violate these laws and regulations.

..    Model Conduct

          (1)  WE DO NOT ENTER INTO ANY DISCUSSIONS OR AGREEMENTS THAT LIMIT
               CORPORATE ACTIVITIES.

                    Officers and Employees shall not participate in any
                    discussions or agreements with competitors that limit
                    corporate activities, including conditions on bids, pricing
                    of products, sales terms, profits, market share, sales
                    areas, etc.

          (2)  WE DO NOT ABUSE OUR TRADING POSITION.

                    Officers and Employees shall not abuse their trading
                    position to impose disadvantageous terms upon the
                    counterparties, or to limit transactions between the
                    counterparties and third parties.

          (3)  WE DO NOT DISPLAY OUR PRODUCTS INAPPROPRIATELY OR OFFER EXCESSIVE
               PREMIUMS OR PRIZES.

                    Officers and Employees shall not inappropriately display
                    Ricoh Group products or offer excessive premiums or prizes
                    that might mislead the customers' decision on the choice of
                    product.

..    Related Standards:

                    "Manual for Compliance with Anti monopoly Law"

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3    PROHIBITION OF INSIDER TRADING

..    Basic Policy

          The Ricoh Group shall not take advantage of any insider information
          obtained in the course of its business for its financial gain, or
          engage in other activities that would undermine the soundness and
          fairness of the securities markets.

..    Model Conduct

          (1)  WE DO NOT DISCLOSE INSIDER INFORMATION TO THIRD PARTIES.

                    Officers and Employees shall not obtain insider information
                    on the Ricoh Group or other companies unless it is necessary
                    for the purpose of performing their duties.

                    Officers and Employees shall not disclose any insider
                    information on the Ricoh Group or other companies obtained
                    in the course of its business to anyone except to those who
                    require such information to perform their duties.

          (2)  WE DO NOT USE INSIDER INFORMATION FOR PERSONAL GAIN.

                    Officers and Employees who come to know of insider
                    information on the Ricoh Group or other companies, either in
                    the course of or as a result of its business, shall not
                    carry out any sale or purchase of stocks or other securities
                    of the Ricoh Group or other companies or engage in any other
                    trades.

*    "Insider information" means unpublished material corporate information,
     including but not limited to, increase or decrease in capital, launching of
     new products, business alliances, sales revenue and ordinary profits, etc.

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4    MANAGING CORPORATE SECRETS

..    Basic Policy

          Information that the Ricoh Group acquired or created in the course of
          its business shall, depending on its importance, be treated as a
          corporate secret and shall be managed appropriately. In addition,
          information on third parties (such as customers, business partners and
          client companies) obtained by the Ricoh Group and information
          entrusted by third parties shall be managed as a corporate secret in
          the same manner.

..    Model Conduct

          (1)  WE COMPLY WITH THE RULES REGARDING THE MANAGEMENT OF CORPORATE
               SECRETS.

                    When Officers and Employees obtain information, materials or
                    documents in the course of business, they shall notify such
                    fact to their superiors, and manage them in accordance with
                    the applicable rules, etc. of each company.

                    Officers and Employees shall continue to comply with the
                    related rules, etc. after the termination of their
                    employment.

          (2)  WE ONLY DISCLOSE CORPORATE SECRETS UPON RECEIPT OF PROPER
               AUTHORIZATIONS.

                    When Officers and Employees are requested from inside or
                    outside the company to respond to inquiries or to provide
                    materials relating to business matters, they shall ask their
                    superior for instructions as to the handling of such
                    requests unless they have clearly been given the necessary
                    authority to respond to the inquiry or provide the
                    materials.

          (3)  WE DO NOT EXPLOIT CORPORATE SECRETS FOR PERSONAL INTERESTS.

                    Officers and Employees shall only use corporate secrets for
                    business purposes, and shall not exploit them for their own
                    interests or those of third parties during or after their
                    employment.

          (4)  WE DO NOT OBTAIN THIRD PARTIES' SECRETS BY UNFAIR METHODS.

                    Officers and Employees shall not obtain other companies'
                    secrets by unfair methods.

                    When Officers and Employees obtain another company's secret
                    based on a contractual relationship with such company, they
                    shall use such secret in compliance with the objectives and
                    the terms and conditions of such contract.

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5    LIMITATION ON ENTERTAINMENT AND GIFTS, ETC.

..    Basic Policy

          The Ricoh Group, in connection with offering and accepting
          entertainment or gifts, shall not offer or accept bribes or engage in
          any activity which deviates from general good business practice.

..    Model Conduct

          (1)  WE DO NOT OFFER ENTERTAINMENT OR GIFTS TO GOVERNMENT OFFICERS OR
               EMPLOYEES OF PUBLIC BODIES (INCLUDING FORMER OFFICERS AND
               EMPLOYEES).

                    Officers and Employees shall not offer entertainment or
                    gifts to officers or employees (including former officers or
                    employees) of national, local or regional, or other public
                    bodies as well as foreign governments.

          (2)  WE FOLLOW GENERAL GOOD BUSINESS PRACTICE.

                    When Officers and Employees offer entertainment or gifts,
                    the offer by such Officers and Employees shall not deviate
                    from general good business practice.

                    Officers and Employees shall make every effort to notify
                    business counterparties and clients in advance that Officers
                    and Employees do not accept entertainment or gifts, but if
                    the circumstances make it difficult to refuse being
                    entertained, they shall immediately report such
                    circumstances to their superior and ask for instruction.

..    Related Standards:

                    "Employment Regulations"

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6    TRANSACTIONS WITH PUBLIC BODIES AND MANAGEMENT OF POLITICAL CONTRIBUTIONS

..    Basic Policy

          The Ricoh Group shall comply with the relevant laws and regulations
          with respect to transactions with public bodies and political
          contributions.

..    Model Conduct

          (1)  WE MANAGE TRANSACTIONS WITH PUBLIC BODIES IN STRICT COMPLIANCE
               WITH THE RELEVANT LAWS AND REGULATIONS.

                    When Officers and Employees engage in transactions with
                    public bodies such as national, regional or local
                    governments, they shall strictly comply with the relevant
                    laws and regulations which set forth the rules governing the
                    manner of such transactions, etc., and always pay full
                    attention to the legality of such business.

          (2)  WE DO NOT MAKE ILLEGAL POLITICAL CONTRIBUTIONS.

                    Except as otherwise permitted under the relevant laws and
                    regulations, Officers and Employees shall not directly or
                    indirectly make political contributions to or provide
                    support for an election campaign of political figures
                    (including candidates for a political office) or political
                    organizations in connection with the business.

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7    STRICT CONTROL OF EXPORTS AND IMPORTS FOR INTERNATIONAL PEACE AND SECURITY

..    Basic Policy

          The Ricoh Group shall not engage in any activity that violates the
          relevant laws and regulations governing exports and imports, including
          the Foreign Exchange and Foreign Trade Law of Japan that aims to
          preserve international peace and security and the relevant foreign
          laws and regulations of the country where the counterparty is located.

..    Model Conduct

          (1)  WE PERFORM APPLICABILITY ASSESSMENTS.

                    When Officers and Employees engage in the planning,
                    development or design of products or the purchase of parts,
                    equipment or raw materials, they shall make assessments in
                    advance as to whether such products, parts, equipment or raw
                    materials fall within a category of contraband products
                    pursuant to the procedures provided for in the internal
                    regulations.

          (2)  WE CONFIRM RESULTS OF THE ASSESSMENT.

                    When Officers and Employees engage in export or import
                    transactions of goods (products, parts, equipment, raw
                    materials, etc.) or technology (technical documentation,
                    programs, technical instruction or other services), they
                    shall confirm in advance based on the results of the
                    assessment whether any restrictions under the relevant
                    export-import laws and regulations are applicable, and if so
                    they shall comply with such restrictions.

          (3)  WE PREVENT THE CONVERSION OF OUR PRODUCTS FOR MILITARY USE.

                    When Officers and Employees engage in export or import
                    transactions of goods or technology, they shall voluntarily
                    apply controls to such transactions in the spirit of
                    nonproliferation, regardless of whether the results of the
                    assessment have found the rules and regulations to be
                    inapplicable. Officers and Employees shall confirm in
                    writing (such as a contract, memorandum, confirmation, etc.)
                    the ultimate user and the ultimate purpose for which the
                    goods or technology will be used, and ask the Ricoh Group
                    Export-Import Control Committee for instructions as to
                    whether they may undertake the transaction when (i) there is
                    a risk that the counterparty may convert the goods or
                    technology for military

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                    use, or (ii) the counterparty is (a) a country that does not
                    have adequate export-import regulations, (b) a country that
                    is subject to international criticism from the perspective
                    of maintaining international peace and order or (c) a
                    country or region that is or is likely to be in a conflict
                    situation.

..    Related Standards:

                    Regulations requiring compliance with export-import laws
                    (RGS-ATRA0001)

                    Export-import controls and assessment of applicability,
                    screening of customers and trading (RGS-ATRC0001)

                    "Guidebook for Export & Import Control" (published by the
                    Ricoh Group Export-Import Control Committee)

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8    PROTECTION AND APPLICATION OF INTELLECTUAL PROPERTIES

..    Basic Policy

          The Ricoh Group shall encourage the creation of intellectual
          properties that are important to the Ricoh Group, and make an effort
          to protect and utilize such intellectual properties appropriately.

..    Model Conduct

          (1)  WE PROVIDE PROMPT NOTIFICATION.

                    All intellectual properties created in connection with the
                    business shall belong to the company.

                    Officers and Employees shall promptly notify the company of
                    all intellectual properties (including personal inventions
                    in the case of patent rights) created in connection with the
                    business.

          (2)  WE RESPECT THE INTELLECTUAL PROPERTIES RIGHTS OF THIRD PARTIES.

                    Officers and Employees shall, in performing their duties,
                    respect the intellectual properties rights of third parties
                    and ensure that such rights are not infringed upon.

          (3)  WE COMPLY WITH THE PROCEDURES FOR DISCLOSURE AND TRANSFER OF
               INTELLECTUAL PROPERTIES.

                    Officers and Employees shall follow the Ricoh Group policies
                    and undertake the proper procedures when disclosing
                    intellectual properties to third parties through a
                    presentation at academic conferences, or the implementation
                    of a new business model, etc., or when transferring
                    intellectual properties to third parties by a license or an
                    assignment thereof.

*    "Intellectual properties" referred to herein means patents, utility models,
     designs,  registered  trademarks,  copyrights  on  programs,  rights to use
     circuit configurations, etc.

..    Related Standards:

                    Ricoh Group Regulations on Intellectual Properties
                    (RGS-ALAA2001)

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9    PROHIBITION OF ANTI-SOCIAL ACTIVITIES

..    Basic Policy

          The Ricoh Group shall take a firm stance towards, and have no
          involvement in, any anti-social activities or elements.

..    Model Conduct

          (1)  WE DO NOT ASSOCIATE OURSELVES WITH ANY ANTI-SOCIAL ACTIVITIES OR
               ELEMENTS.

                    Officers and Employees shall not have any involvement in any
                    anti-social activities or elements that threaten the order
                    and security of society and interfere with economic
                    activities.

          (2)  WE DO NOT YIELD TO OR COMPROMISE WITH ANY UNJUST DEMANDS FROM
               ANTI-SOCIAL ELEMENTS.

                    Officers and Employees shall not yield to or compromise with
                    any unjust demands from anti-social elements by agreeing to
                    pay money, etc.

                    When Officers and Employees are faced with such demands,
                    they shall immediately report such events to their superior,
                    and such superior shall notify such events to the person or
                    department in charge of the general administration of each
                    company.

          (3)  WE DO NOT ENTER INTO ANY TRANSACTION WITH ANY ANTI-SOCIAL
               ELEMENTS.

                    Officers and Employees shall not enter into any transaction
                    with any anti-social elements.

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10   PROHIBITION OF INDIVIDUAL ACTIVITIES THAT ARE AGAINST THE INTERESTS OF THE
     COMPANY

..    Basic Policy

          The Ricoh Group shall not approve any personal activities by its
          Officers or Employees that result or is likely to result in a
          disadvantage to the Ricoh Group.

..    Model Conduct

          (1)  WE INFORM THE COMPANY.

                    Officers and Employees shall not engage in any activities
                    that result or is likely to result in a disadvantage to the
                    company, and shall inform their superior if such situation
                    arises.

          (2)  WE OBTAIN THE COMPANY'S APPROVAL IN ADVANCE.

                    Officers and Employees shall obtain the company's approval
                    in advance when they intend to assume offices of a director
                    or an officer of, or enter into an employment agreement
                    with, another company or organization.

          (3)  WE DO NOT ENTER INTO COMPETING ACTIVITIES WITHOUT PERMISSION.

                    Officers and Employees shall not, without obtaining the
                    company's permission in advance, engage in any activities
                    that compete with the Ricoh Group, such as entering into
                    transactions that compete with the Ricoh Group or
                    participating in the management of a competitor.

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11   PROTECTION OF CORPORATE ASSETS

..    Basic Policy

          The Ricoh Group shall establish and strictly implement rules that
          protect the corporate assets (i.e., tangible and intangible assets
          including products, equipment and information, etc.).

..    Model Conduct

          (1)  WE APPROPRIATELY CONTROL THE CORPORATE ASSETS.

                    Officers and Employees shall appropriately control the
                    corporate assets in compliance with the relevant rules.

          (2)  WE DO NOT USE THE CORPORATE ASSETS FOR IMPROPER PURPOSES.

                    Officers and Employees shall not use the corporate assets
                    for non-business purposes, such as exploiting the corporate
                    assets for personal gain.

..    Related Regulations:

                    "Employment Regulations"

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Harmony with the Environment

12   RESPECT FOR THE GLOBAL ENVIRONMENT

..    Basic Policy

          Recognizing that environmental conservation is our mission as a global
          citizen and that the activities for environmental conservation are
          indispensable for our business, the Ricoh Group shall ensure that the
          entire Group participates in such activities with responsibility.

..    Model Conduct

          (1)  WE SET AND ACHIEVE HIGHER TARGETS FOR ENVIRONMENTAL CONSERVATION.

                    Officers and Employees shall not only be in full compliance
                    with all laws but take personal responsibility to set higher
                    targets to reduce the environmental impact of its business
                    activities taking into consideration the expectation of
                    society, and make every effort to create new economic values
                    in achieving these targets.

          (2)  WE IMPLEMENT TECHNOLOGICAL REFORMS.

                    Officers and Employees shall make every effort to promote
                    technological reforms that make it possible to reduce the
                    environmental impact of its business activities and actively
                    utilize such technologies.

          (3)  WE DEVELOP BUSINESS OPERATIONS IN HARMONY WITH THE ENVIRONMENT.

                    In managing the business operations, Officers and Employees
                    shall always grasp the environmental impact of the business
                    operation and make efforts to prevent pollution, utilize
                    energy and other natural resources effectively, and reduce
                    the volume of and take measures to responsibly dispose
                    industrial waste.

                    Officers and Employees shall also engage in continuous
                    efforts to maintain and improve the systems that promote
                    environmental conservation.

          (4)  WE PROVIDE ENVIRONMENT-FRIENDLY PRODUCTS AND SERVICES.

                    Officers and Employees shall provide products and services
                    that have minimal impact on the environment at all stages,
                    from the procurement of materials and production of the
                    products to the sales, distribution, recycling and disposal
                    of the products.

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          (5)  WE ENHANCE OUR ENVIRONMENTAL AWARENESS AND ACT RESPONSIBLY.

                    Officers and Employees shall make efforts to enhance their
                    environmental awareness by keeping their eyes open to
                    various events in the community and actively studying
                    environmental issues, and be personally responsible for
                    actively engaging in environmental conservation activities.

          (6)  WE MAKE SOCIAL CONTRIBUTIONS FOR THE ENVIRONMENT.

                    In the various countries and regions in the world, Officers
                    and Employees shall seek to establish close relationships
                    with the society and actively contribute to the society by
                    disclosing information and aiding and supporting
                    environmental conservation activities.

..    Related Standards:

                    "Ricoh General Principles on the Environment" Ricoh Group
                    Environmental Conservation Regulation (RGS-AEP A0001)

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Respect for People

13   RESPECT FOR HUMAN RIGHTS

..    Basic Policy

          The Ricoh Group shall always respect fundamental human rights, which
          is the basis for mutual understanding.

          The Ricoh Group shall not discriminate on the basis of race, religious
          faith, gender, social position, nationality, sickness, physical or
          mental disability, etc.

..    Model Conduct

          (1)  WE ELIMINATE ALL TYPES OF DISCRIMINATION.

                    Officers and Employees shall respect all types of
                    fundamental human rights and shall not engage in any action
                    that ignores fundamental human rights, such as
                    discriminatory speech and behavior, violent behavior, sexual
                    harassment, power harassment, etc.

          (2)  WE PROTECT INDIVIDUAL PRIVACY.

                    When dealing with personal information in the course of
                    business of any individual, whether inside or outside the
                    company, Officers and Employees shall pay attention not to
                    infringe on his or her privacy, and manage such information
                    appropriately.

          (3)  WE ELIMINATE IMPROPER LABOR PRACTICES.

                    Officers and Employees shall not make improper demands for
                    labor.

                    Officers and Employees shall not employ children under the
                    legal working age of each country or region.

                    Officers and Employees shall require the Ricoh Group's
                    distributors and allied companies, etc. to implement similar
                    restrictions.

..    Related Standards:

                    "Employment Regulations"

                    Basic regulations for the protection of personal information
                    (RGS-AITA0004)

                    Rules on internal group usage of personal information
                    (RGS-AITA0003)

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<PAGE>

Harmony with Society

14   THE PRACTICE OF CONTRIBUTING TO SOCIETY

..    Basic Policy

          Recognizing its role as a corporate citizen, the Ricoh Group shall
          actively engage in activities that contribute to society in
          partnership with like-minded people.

..    Model Conduct

          (1)  WE ENGAGE IN ACTIVITIES THAT CONTRIBUTE TO THE LOCAL COMMUNITY.

                    It is important to recognize that corporate activities are
                    carried out in close contact with the local community.

                    With the hope that the Ricoh Group will be welcomed by,
                    familiar to and trusted by the local society, Officers and
                    Employees shall make efforts to engage in activities that
                    are closely connected with the local community so that it
                    supports or aids the local community's cultural and
                    economical development.

          (2)  WE FOSTER A CORPORATE CULTURE THAT PLACES IMPORTANCE ON
               CONTRIBUTING TO SOCIETY.

                    In addition to the social contribution by the company, it is
                    important that each and every Officer and Employee consider
                    how to contribute to society, and take part in such
                    activities in their own community.

                    Through participating in volunteer activities that
                    contribute to society, Officers and Employees shall make
                    every effort to foster a corporate culture that places
                    importance on social contributions.

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<PAGE>

15   MUTUAL UNDERSTANDING WITH SOCIETY

..    Basic Policy

          To coexist harmoniously with society, the Ricoh Group shall actively
          operate its business in a manner that cultivates a mutual
          understanding with, establishes a trusting relationship with, and
          makes contributions to society.

..    Model Conduct

          (1)  WE RESPECT THE CULTURES AND CUSTOMS OF THE WORLD.

                    There are many things that are not accepted in one country
                    or region, that are accepted in another country or region.

                    Officers and Employees shall properly act to respect the
                    histories, cultures and customs of each and every country or
                    region in the world.

          (2)  WE ACTIVELY DISCLOSE INFORMATION.

                    Accurately communicating the corporate attitudes of the
                    Ricoh Group is the first step for deepening the mutual
                    understanding between the Ricoh Group and society.

                    To ensure that as many people have a proper understanding of
                    the Ricoh Group, Officers and Employees shall actively and
                    fairly disclose corporate information in a timely manner
                    pursuant to the appropriate procedures of the company.

          (3)  WE KEEP ACCURATE RECORDS AND REPORTS.

                    Officers and Employees shall keep accounting and financial
                    records and reports in compliance with the relevant laws and
                    regulations and internal rules, etc.

                    Such records and reports shall be prepared so that its
                    contents is complete, fair, accurate, timely and readily
                    understandable.

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<PAGE>

Implementation

ENACTMENT, ABOLISHMENT AND AMENDMENT

This Code shall be enacted, abolished or amended by the decision of the board of
directors of Ricoh after discussions are held at the CSR Committee.

ENSURING RECOGNITION OF THE CODE

To ensure that this Code is well-known, the department of Ricoh in charge of CSR
shall implement and promote the necessary activities, including providing
continuing education and instruction programs.

All of the Officers and Employees shall submit to the company every year a
certification swearing that they will adhere to this Code.

PENALTIES

Any activity that breaches this Code shall be subject to penalties as provided
in the Employment Regulations of each company.

TREATMENT OF TEMPORARY EMPLOYEES, ETC.

(1)  With regards to temporary employees on contract dispatched from a temporary
     employment agency, the responsible person of the department that hired such
     temporary employee shall explain this Code to such temporary employee, and
     have the temporary employee submit a certification swearing that they will
     adhere to this Code.

(2)  With regards to full-time employees that work for the Ricoh Group pursuant
     to an outsourcing agreement or a consultancy agreement, etc., the
     responsible person of the relevant department of each company shall
     appropriately explain this Code to such full-time employees, taking into
     consideration the nature of their job, and incorporate the proper
     provisions with regard to compliance of this Code in the relevant
     agreements.

RELATED STANDARDS

To supplement the contents of each section of this Code the relevant
regulations, group standards and manuals, etc., have been provided in this Code
under the heading "Related Standards."

MISCELLANEOUS

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<PAGE>

Officers and Employees who come to know of any activity that breaches or is
likely to breach this Code may consult with the relevant department of Ricoh in
charge of CSR either directly or indirectly through their superior or call the
"Hotline." No person shall suffer from any disadvantage due to the fact that he
or she consulted such person or department about such events.

FOR FURTHER INFORMATION

Corporate activities are both vast in scale and complex in nature. It will not
always be clear how this Code applies in individual cases. In such case, please
contact the responsible section or the central authority as listed below.

When there is an organization change, please contact the new section or
authority that assumed the relevant function.

RESPONSIBLE SECTION

1    Providing customer-friendly products ..... Ricoh Quality of Management
                                                ---------------------------
     Division
     --------
2    Free competition and fair trading ..... Ricoh Legal Division
                                             --------------------

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<PAGE>

3    Prohibition of insider trading ..... Ricoh Corporate Planning Division
                                          ---------------------------------
4    Managing corporate secrets ..... Ricoh Personnel Division
                                      ------------------------
5    Limitation on entertainment and gifts, etc ..... Ricoh Personnel Division
                                                      ------------------------
6    Transactions with public bodies ..... Ricoh Personnel Division
                                           ------------------------
     Management of political contributions ..... Ricoh Secretary Office
                                                 ----------------------
7    Strict control of exports and imports for international peace and
     security..... Ricoh International Marketing Group
                   -----------------------------------
8    Protection and application of intellectual properties ..... Ricoh Legal
                                                                 -----------
     Division
     --------
9    Prohibition of anti-social actions ..... Ricoh Personnel Division
                                              ------------------------
10   Prohibition of individual activities that are against the interests of the
     company ..... Ricoh Personnel Division
                   ------------------------
11   Protection of corporate assets ..... Ricoh Personnel Division
                                          ------------------------
12   Respect for the global environment ..... Ricoh Corporate Environment
                                              ---------------------------
     Division
     --------
13   Respect for human rights ..... Ricoh Personnel Division
                                    ------------------------
14   The practice of contributing to society ..... Ricoh Corporate Citizenship
                                                   ---------------------------
     Promotion Office
     ----------------
15   Mutual understanding with society ..... Ricoh Corporate Planning Division
                                             ---------------------------------
CENTRAL AUTHORITY

     Ricoh Group Code of Conduct ..... Ricoh CSR Division
                                       ------------------

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<PAGE>

                           Ricoh Group Code of Conduct

--------------------------------------------------------------------------------

     Enacted November 4, 2003
     Effective January 1, 2004

     CSR Division, Ricoh Company, Ltd.
     1-15-5 Minami Aoyama
     Minato-ku, Tokyo 107-8544
     Tel: 03-5411-4670

     Copyright 2003
     RICOH COMPANY, LTD. All rights reserved

--------------------------------------------------------------------------------

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