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                                                                     Exhibit 11

RICOH

THE RICOH GROUP
CODE OF CONDUCT

                                        1

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                                  Ricoh Group
                 Corporate Social Responsibility (CSR) Charter

To grow as a respected enterprise, the Ricoh Group must fully discharge its
corporate social responsibility (CSR) from a consistent global perspective and
throughout every aspect of its operations. To ensure this, the following
principles are to be observed, with the proper social awareness and
understanding, compliant with both the letter and the spirit of national laws
and the rules of international conduct.

Integrity in Corporate Activities

1.  Every company in the Ricoh Group will develop and provide useful products
    and services, with high quality, safety, reliability and ease of use, while
    maintaining security of information and giving proper consideration to the
    environment.

2.  Every company in the Ricoh Group will compete fairly, openly and freely,
    maintaining normal and healthy relationships with political institutions,
    government administration, citizens and organizations.

3.  Every company in the Ricoh Group will take responsibility for managing and
    safeguarding its own information and that of its customers.

Harmony with the Environment

4.  Every company in the Ricoh Group will take responsibility, as a citizen of
    the world, working voluntarily and actively to preserve the environment.

5.  Every company in the Ricoh Group, and all employees of each company, will
    seek to implement technological innovations that reflect environmental
    concerns and will participate in ongoing activities to preserve the
    environment.

Respect for People

6.  Every company in the Ricoh Group will, quite apart from corporate group
    activities, maintain a working environment that is safe and that makes it
    easier for its staff to do perform their duties, respecting their richly
    individual characteristics and encouraging their autonomy and creativity.

7.  Every company in the Ricoh Group will respect the rights of all those
    connected with it, and will seek to create a cheerful working environment,
    free of discrimination.

8.  No company in the Ricoh Group will permit forced labor or child labor, and
    none will tolerate the infringement of human rights.

Harmony with Society

9.  Every company in the Ricoh Group will, as a good corporate citizen, actively

                                        2

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    engage in activities that contribute to society.

10. Every company in the Ricoh Group will respect the culture and customs of
    its country or region, and will operate so as to contribute to their
    development.

11. Every company in the Ricoh Group will engage in the fullest possible
    communications with society, seeking actively to provide the proper and
    unbiased disclosure of corporate information.

                                        3

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Message from the CEO

   Ricoh, aiming at harmonizing with society and earning its trust, established
the Ricoh Business Code of Conduct in April, 1993 as the standard for corporate
behavior as well as individual behavior by each and every officer and employee
of the Group.

   Furthermore, each group company also created a Code of Conduct based on the
Ricoh model which helped to enhance the reputation of the entire Group.

   However, in recent years the company has stepped up its role and influence
as a committed environmentalist and global citizen. With these new roles coming
to the fore, it has now become essential for companies to step up their
activity level from mere social contribution to one of responsibility to
society, with a management oriented toward corporate social responsibility.
Thus it behooves companies to carry out their corporate activities with a
keener sense of ethics, morals and responsibility over and above compliance
with regulations.

   Along with the globalization of our corporate activity and group management,
the Ricoh Group has been increasingly composed of people with different sets of
values in a variety of countries around the world and therefore the need to
unite our thinking around common values and standard of behavior has become
more and more urgent.

   I therefore decided that it was time to review the original Ricoh Business
Code of Conduct from the viewpoint of " a corporation which has responsibility
to harmonize with society and with the environment ". Then, we established "
the Ricoh Group CSR Charter " to be shared globally by the Ricoh group and "
the Ricoh Group Code of Conduct " that Ricoh group members should adopt as a
mind set and behavior guide.

   This Code ensures that we will continue into the future to be " a good
global corporate citizen with reliability and appeal ". I firmly believe that
serious adherence to this Code and Charter will help us to be even more
appreciated by customers and society alike. I expect every member of the Ricoh
Group family to take these principles to heart.

January 1, 2004
                                              Masamitsu SAKURAI
                                              President and CEO,
                                              Ricoh Group

                                        4

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CONTENTS

                                                                          Page
------------------------------------------------------------------------------

General Principles.......................................................   6

Integrity in Corporate Activities
  1  Providing customer-centric products.................................   9
  2  Free competition and fair trading...................................  10
  3  Banning insider trading.............................................  11
  4  Managing corporate secrets..........................................  12
  5  Limits on entertainment and gifts...................................  13
  6  Doing business with public bodies and making political contributions  14
  7  Strict control of exports and imports...............................  15
  8  Protection and use of intellectual properties.......................  17
  9  Participation in anti-social actions................................  18
  10 Individual actions against the interests of the company.............  19
  11 Protection of corporate assets......................................  20

Harmony with the Environment
  12 Respecting the global environment...................................  21

Respect for People
  13 Respect for human rights............................................  23

Harmony with Society
  14 Practical contributions to society..................................  24
  15 Harmonizing with society............................................  25

Implementation...........................................................  26

                                        5

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General Principles

OBJECTIVES

The Ricoh Group Code of Conduct (abbrev. to "the Code" below) is intended to
establish the basic standards to ensure that Officers and Employees of the
company, when engaging in corporate activities to advance the Ricoh Group,
shall act in accordance with social ethics and in full compliance with the law.

DEFINITIONS

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

1.  "Ricoh" means Ricoh Company, Ltd.

2.  "Related Companies" means those whose accounts are consolidated with
    Ricoh's and those whose management is actually under Ricoh control.

3.  "Ricoh Group" means Ricoh and Related Companies.

4.  "Officers and Employees" means the directors, auditors, executive officers,
    board members, all those coming under the regulations governing employment
    and all others employed in any capacity (whether in part time or irregular
    employment).

APPLICABILITY

1.  This Code and its standards apply to Officers and Employees.

2.  Related Companies shall appoint a responsible person to implement these
    standards, who must make every effort to ensure that they are observed.
    However, under the following circumstances, the board of directors of
    Related Companies are permitted to enact supplementary standards provided
    they are consistent with the Code. Related Companies shall report such
    standards to the central authority of this Code.

    (1)  When changes are necessary in view of national or regional laws,
         commercial customs, employment practices, or systems of value.

    (2)  When changes are necessary because of the nature of the company's
         business, type of products, or those with whom it does business.

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THE BASIC ATTITUDES TO BE ADOPTED BY OFFICERS AND EMPLOYEES

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

1.  Activities shall always be based on national and regional laws, properly
    understand, and strictly obeyed.

2.  Activities shall be those that can be performed with a clear conscience as
    good citizens, aware of their social responsibilities, and maintaining high
    ethical and moral standards.

3.  As business persons, they must act in a disciplined way, while at the same
    time respecting the individual differences and value systems of others,
    observing all basic rules and regulations established by the Ricoh Group,
    never confusing public and private interests, and acting with a full sense
    of their responsibility as representatives of the Ricoh Group.

4.  Realizing that all corporate activities, not only those that involve direct
    contact with the customer such as sales and maintenance, are evaluated by
    our customers, every effort must be made to ensure the maximum possible
    customer satisfaction.

5.  In order to stay keenly aware of the various changes and problems we face,
    we must act autonomously. Always seeking to maintain the creativity to
    freely generate a full range of ideas, we must think independently and
    create new values.

6.  We must always put ourselves in the other person's place, whether they are
    fellow employees, customers, those with whom we do business, or cooperating
    companies, and make ourselves useful to them.

7.  We must make every effort to ensure that the progress of the company is
    fully consistent with the personal happiness of its people, seeking to
    bring about a richly satisfying life for all.

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THE BASIC ATTITUDE OF THE RICOH GROUP TO ITS EMPLOYEES

The Ricoh Group is committed, as follows, to ensuring that all employees
maintain the required basic attitudes in all their activities, making the
fullest use of their abilities, and so making the best of themselves:

1.  For all individual employees, the Ricoh Group seeks to create and provide a
    work place that caters for their broadest possible self-actualization,
    desiring their growth as human beings not only in work but also in making
    the best of themselves.

    For all individual employees, it seeks to create a free and generous
    corporate ethos in which they can feel that they are worthy, growing and
    fulfilled, and giving free reign to their creativity.

2.  The specialized abilities of all individual employees are prized by the
    Ricoh Group, which seeks to make the fullest use of them while at the same
    time providing a systematic support structure that encourages them to hone
    existing skills and develop new ones.

3.  A fair and impartial system of evaluating the degree to which all
    individual employees use their skills is a source of vitality within the
    group.

    All individual employees' success in meeting their targets are to be
    assessed fairly by clearly established standards when evaluating their
    abilities and contributions, and they are to be recognized accordingly.

4.  Concern for the safety and health of all individual employees is to be
    reflected in a pleasant and functional working environment and equipment.
    And in order that employees may enjoy a wide variety of lifestyles, the
    Ricoh Group will provide a variety of working conditions, terms of
    employment, and working hours, etc.

                                        8

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Integrity in Corporate Activities

1   PROVIDING CUSTOMER-CENTRIC PRODUCTS

..   Basic Policy

         The Ricoh Group's basic approach to developing the products and
         services it provides to its customers is that of adopting the
         customer's viewpoint.

..   Actions

         (1) WE SOLVE THE CUSTOMER'S PROBLEMS.

                 Officers and Employees shall actively seek to understand the
                 customer's problems, and must devote themselves to solving or
                 ameliorating those problems.

         (2) WE EARN THE CUSTOMER'S TRUST.

                 Officers and Employees, in developing the products and
                 services they provide to the customer, shall consider quality,
                 safety, the security of information, reliability,
                 environmental preservation and ease of use.

         (3) WE SEEK EVER HIGHER CUSTOMER SATISFACTION.

                 Officers and Employees shall regularly assess the degree of
                 customer satisfaction, and shall work to improve products and
                 services so as to achieve higher satisfaction.

..   Related Standards:

                 Ricoh Group Quality Assurance Regulation (RGS-AQAA0001)
                 Ricoh Group Product Safety Regulation (RGS-AQAA0002)

                                        9

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2   FREE COMPETITION AND FAIR TRADING

..   Basic Policy

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

..   Actions

         (1) WE WILL ENTER NO AGREEMENTS OR DISCUSSIONS FOR THE RECIPROCAL
             LIMITATION OF CORPORATE ACTIVITIES.

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

         (2) WE WILL NOT EXPLOIT OUR TRADING POSITION.

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

         (3) WE WILL NOT MAKE INAPPROPRIATE DISPLAYS NOT OFFER INAPPROPRIATELY
             LARGE PREMIUMS OR PRIZES.

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

..   Related Standards:

                 "Manual for Compliance with Antimonopoly Law"

                                       10

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3   BANNING INSIDER TRADING

..   Basic Policy

         The Ricoh Group shall not take advantage of insider information to
         which it gains access in the course of business to make profits nor do
         anything else that would undermine fair and healthy trading in
         securities.

..   Actions

         (1) NO DISCLOSURES TO THIRD PARTIES

                 Officers and Employees shall not, unless it is necessary in
                 the ordinary course of business, obtain insider information
                 concerning the Ricoh Group or other companies.

                 Again, 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.

                                       11

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4   MANAGING CORPORATE SECRETS

..   Basic Policy

         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.

..   Actions

         (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 CORPORATE SECRETS.

                 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 SECRETS.

                 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 COMPETITIVE SECRETS BY DISHONEST MEANS.

                 Officers and Employees shall not acquire the secrets of other
                 companies by dishonest means.

                 Again, when Officers and Employees acquire the secrets of
                 other companies in accordance with a contract, they must only
                 use the secret information as specified in the contract.

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5  LIMITS ON ENTERTAINMENT AND GIFTS

..   Basic Policy

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

..   Actions

         (1) GOVERNMENT EMPLOYEES (AND EX-EMPLOYEES) SHALL NOT BE ENTERTAINED
             NOR GIVEN GIFTS.

                 Officers and Employees shall neither entertain nor give gifts
                 to the employees (or former employees) of government
                 departments nor of regional (local) authorities or other
                 public bodies.

         (2) FOLLOW GENERAL GOOD BUSINESS PRACTICE

                 Officers and Employees, when giving entertainment or gifts,
                 shall not exceed the bounds of general good business practice.

                 Again, Officers and Employees shall make every effort to
                 inform those with whom they do business that they do not
                 accept entertainment nor gifts, and if they find themselves
                 unable to avoid being entertained, they shall immediately
                 inform their superior and follow instructions.

..   Related Standards:

                 "Employment regulations"

                                       13

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6   DOING BUSINESS WITH PUBLIC BODIES AND MAKING POLITICAL CONTRIBUTIONS

..   Basic Policy

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

..   Actions

         (1) STRICT IMPARTIALITY

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

         (2) NO IMPROPER POLITICAL CONTRIBUTIONS

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

                                       14

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7  STRICT CONTROL OF EXPORTS AND IMPORTS

..   Basic Policy

         The Ricoh Group shall not infringe laws intended to preserve
         international peace and safety, including those on foreign exchange
         transactions, those on overseas trading and export-related laws, and
         those on the countries with which to trade.

..   Actions

         (1) PERFORM ASSESSMENT OF APPLICABILITY

                 Officers and Employees shall follow the internal procedures in
                 accordance with company regulations, carefully checking
                 beforehand whether any restrictions apply to the import or
                 export of products being planned, developed or designed, and
                 on products, equipment and materials being purchased or sold.

         (2) CHECK THE RESULT OF THE ASSESSMENT OF THE APPLICABILITY OF
             IMPORT/EXPORT RESTRICTIONS

                 Officers and Employees, when importing or exporting goods
                 (products, components, equipment, materials, etc.) or
                 technology (technical documentation, programs, engineering
                 consultancy or other services), shall check beforehand in the
                 light of the assessment of the applicability of restrictions
                 whether such export or import would infringe the relevant laws
                 and regulations. When restrictions are found to be applicable,
                 transactions must conform with the restrictions.

         (3) PREVENTING CONVERSION FOR MILITARY USE

                 When importing or exporting goods or technology, whether or
                 not restrictions are found to be applicable, Officers and
                 Employees shall voluntarily apply controls in the spirit of
                 export restrictions for non-proliferation.

                 When there is fear that the customer may convert items for
                 military use, or when the destination country itself has
                 inadequate implementation of import/export restrictions, or
                 the country is one that is subject to international criticism
                 on the grounds of offences against the maintenance of world
                 order, or when the destination country or region is
                 experiencing conflict or the threat of conflict, Officers and
                 Employees shall check documents (contracts, memoranda,
                 confirmations, etc.) to ascertain the ultimate user and the
                 ultimate purpose for which the goods or technology will be
                 used and shall submit to the ruling of the Ricoh Group Export
                 Import Control Committee as to whether or not the transaction
                 should proceed.

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..   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)

                                       16

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8   PROTECTION AND USE OF INTELLECTUAL PROPERTIES

..   Basic Policy

         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.

..   Actions

         (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.

..   Related Standards:

                 Ricoh Group Regulations on Intellectual Properties
                 (RGS-ALAA2001)

                                       17

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9   PARTICIPATION IN ANTI-SOCIAL ACTIONS

..   Basic Policy

         The Ricoh Group takes a firm attitude to anti-social activities and
         elements and will have nothing to do with them.

..   Actions

         (1) HAVE NO DEALINGS WITH ANTI-SOCIAL ACTIVITIES AND ELEMENTS.

                 Officers and Employees must have absolutely nothing to do with
                 anti-social activities and elements that pose threats to the
                 safety and good order of society and the lives of its citizens.

         (2) DO NOT COMPROMISE IN THE FACE OF EXTORTION FROM ANTI-SOCIAL
             ELEMENTS.

                 Officers and Employees, if presented with extortion demands by
                 anti-social elements, shall not compromise with them by paying
                 money or in any other way. Officers and Employees shall
                 immediately report such demands to their superior and the
                 superior must contact the general administration of each
                 company affected.

         (3) HAVE NO DEALINGS WITH ANTI-SOCIAL ELEMENTS.

                 Officers and Employees must no have any dealings with
                 anti-social elements.

                                       18

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10  INDIVIDUAL ACTIONS AGAINST THE INTERESTS OF THE COMPANY

..   Basic Policy

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

..   Actions

         (1) INFORM THE COMPANY.

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

         (2) OBTAIN PRIOR COMPANY APPROVAL.

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

         (3) NO COMPETITION WITHOUT PERMISSION.

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

                                       19

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11  PROTECTION OF CORPORATE ASSETS

..   Basic Policy

         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.

..   Actions

         (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 Regulations:

                 "Employment regulations"

                                       20

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Harmony with the Environment

12  RESPECTING THE GLOBAL ENVIRONMENT

..   Basic Policy

         The Ricoh Group, aware that environmental preservation is the solemn
         duty of every citizen of the world, will align corporate activities
         with environmental preservation activities, taking responsibility for
         ensuring that the entire group participates in them.

..   Actions

         (1) SET HIGHER TARGETS FOR ENVIRONMENTAL ACTIVITIES AND MEET THEM.

                 Officers and Employees will not only be in full compliance
                 with all laws, but will take personal responsibility for
                 establishing targets that reflect the concerns of society to
                 reduce environmental impacts, and seek to create economic
                 value in achieving these targets.

         (2) IMPLEMENT TECHNOLOGICAL REFORMS.

                 Officers and Employees will make every effort to implement
                 technological reforms that can reduce the impact on the
                 environment, and make active use of such technologies.

         (3) OPERATE BUSINESSES IN HARMONY WITH THE ENVIRONMENT.

                 Officers and Employees, in managing business operations, will
                 always be aware of their environmental impact, and will
                 participate responsibly in efforts to prevent pollution, to
                 ensure the effective use of energy and other resources, and to
                 reduce the volume of waste materials. They will also engage in
                 ongoing efforts to maintain and improve the systems of
                 environmental preservation.

         (4) PROVIDE PRODUCTS AND SERVICES THAT REFLECT ENVIRONMENTAL CONCERNS.

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

         (5) ACT RESPONSIBLY TO ENHANCE ENVIRONMENTAL AWARENESS.

                 Officers and Employees will keep their eyes on the wider
                 society around them, and work actively through education and
                 other means to enhance their awareness and personally shoulder
                 their responsibility to work for environmental preservation.

         (6) MAKE SOCIAL CONTRIBUTIONS FOR THE ENVIRONMENT.

                 Officers and Employees will ensure that the company works
                 closely

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                 with society in all countries and regions, actively disclosing
                 information, and helping and supporting environmental
                 preservation so as to contribute largely to society.

..   Related Standards:

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

                                       22

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Respect for People

13 RESPECT FOR HUMAN RIGHTS

..   Basic Policy

         The Ricoh Group seeks always to respect fundamental human rights on
         the basis of mutual understanding.

         The Ricoh Group does not discriminate on the basis of race, religious
         faith, gender, social position, citizenship, sickness, handicaps, etc.

..   Actions

         (1) ELIMINATE ALL DISCRIMINATION.

                 Officers and Employees must respect all fundamental human
                 rights, and must not engage in any actions that ignore human
                 rights such as discriminatory language, violence, sexual
                 harassment, power harassment, etc.

         (2) PROTECT PERSONAL PRIVACY

                 When Officers and Employees acquire personal information in
                 the performance of their duties, they must take full care in
                 their handling of this information to protect the privacy of
                 those concerned, and must exercise the proper management
                 control over it.

         (3) DO AWAY WITH IMPROPER LABOR PRACTICES.

                 Officers and Employees must not make improper demands for
                 labor. Again, they must not employ children under the legal
                 working age of the country or region concerned. Officers and
                 Employees must also impose these same conditions on the Ricoh
                 Group's sales outlets and cooperating companies.

..   Related Standards:

                 "Employment regulations"
                 Basic regulations for the protection of personal information
                 (RGS-AITA0004)
                 Rules on internal group usage of personal information
                 (RGS-AITA0003)

                                       23

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Harmony with Society

14  PRACTICAL CONTRIBUTIONS TO SOCIETY

..   Basic Policy

         The Ricoh Group, aware of its role as a corporate citizen, joins in
         active partnership with like-minded people to make contributions to
         society.

..   Actions

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

                 Corporate activities take place in close contact with the
                 local community. Officers and Employees, because they want the
                 Ricoh Group to be welcome, familiar and trusted in local
                 society, should strive to work closely with that community,
                 making contributions to it that will further the local culture
                 and economy.

         (2) FOSTER A CORPORATE ETHOS THAT PLACES IMPORTANCE ON CONTRIBUTIONS
             TO SOCIETY

                 As well as making corporate contributions to society, each
                 individual officer and employee should consider how to
                 contribute to society, and take practical part in such
                 activities in their immediate vicinity. Officers and Employees
                 should, by voluntary participation in activities, strive
                 foster a corporate ethos that puts the proper value on social
                 contributions.

                                       24

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15 HARMONIZING WITH SOCIETY

..   Basic Policy

         The Ricoh Group seeks to coexist harmoniously with society, and its
         business will be managed so as to contribute to the regions within
         which it operates, while working to deepen mutual understanding and
         build relationships of trust.

..   Actions

         (1) RESPECT THE WORLD'S CULTURES AND CUSTOMS.

                 There are many things that, although they may be perfectly
                 acceptable in one country or region, are quite unacceptable in
                 another. Officers and Employees must therefore act with the
                 necessary respect for the history, culture and customs of the
                 various nations and regions within which they operate.

         (2) 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.

         (3) 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.

                                       25

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Implementation

ENACTMENT AND AMENDMENT

These standards shall be enacted and if necessary, amended, by decision of the
board of directors after full deliberation with the CSR Committee.

ENSURING GENERAL AWARENESS

The Ricoh Group section(s) responsible for CSR shall engage in an ongoing
program of educational and leadership activities to ensure general awareness of
these standards. Officers and Employees are required to affirm their strict
adherence to these standards by signing a statement to that effect annually and
submitting it to the company.

PENALTIES

Acts in contravention of these standards shall, in accordance with the
employment regulations of the company concerned, be subject to the penalties
prescribed therein.

TREATMENT OF TEMPORARY AND OTHER EMPLOYEES

(1) For employees on contracts from temporary employment agencies, the member
    of staff responsible for employing them in the section in which they work
    must explain the standards and require the employees to strictly adhere to
    these standards by signing a statement.

(2) For those who are in the company on out-sourcing contracts or consultancy
    contracts, the member of staff responsible in each section must explain to
    that person the standards to the work being performed under the contract
    which incorporating a provision for their strict adherence into the
    contract itself.

RELATED STANDARDS

Regulations, group standards and manuals, etc., that supplement the various
sections of these standards are itemized under "Related Standards."

OTHERS

Officers and Employees who become aware of contraventions of these standards,
or the danger that they will be contravened, are required to contact the
responsible CSR section either directly or via a superior, or to contact it via
the "hotline (AVAILABLE ONLY IN JAPAN)." No person so making such contact shall
suffer any disadvantage as a result of it.

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                "HOTLINE" INFORMATION (AVAILABLE ONLY IN JAPAN)

     Open:         10:00am to 5:00pm (closed on weekends and holidays)

     Apply to:
               Ricoh: CSR Office, CSR Division
                     Tel:     0120-344-670
                     E-mail:  ZPG_CSR@nts.ricoh.co.jp
                     Letters: CSR Office, CSR Division, Ricoh Company, Ltd.
                              8-13-1 Ginza, Chuo-ku,
                              Tokyo 104-8222

               Law Office: Nakajima Transactional Law Office
                     Tel:     03-3502-8763 (a dedicated Ricoh Group line)
                     E-mail:  rigrpcpl@proof.ocn.ne.jp

FOR FURTHER INFORMATION

Corporate activities are both vast in scale and complex in nature. It will not
always be clear how these standards apply in individual cases. In such cases,
please contact individual sections responsible or the central authority as
listed below.

When there is an organization change, please contact the new section or
authority informed of the standards.

INDIVIDUAL SECTIONS RESPONSIBLE

1   Providing customer-centric products .... Ricoh Quality Division
                                             ----------------------

2   Free competition and fair trading .... Ricoh Legal Division
                                           --------------------

3   Banning insider trading .... Ricoh Corporate Planning Division
                                 ---------------------------------

4   Managing corporate secrets .... Ricoh Personnel Division
                                    ------------------------

5   Limits on entertainment and gifts .... Ricoh Personnel Division
                                           ------------------------

6   Doing business with public bodies .... Ricoh Personnel Division
                                           ------------------------

    Making political contributions .... Ricoh Secretary Office
                                        ----------------------

7   Strict control of exports and imports
                                       .... Ricoh International Marketing Group
                                            -----------------------------------

8   Protection and use of intellectual properties .... Ricoh Legal Division
                                                       --------------------

9   Participation in anti-social actions .... Ricoh Personnel Division
                                              ------------------------

10  Individual actions against the interests of the company
                                                  .... Ricoh Personnel Division
                                                       ------------------------

11  Protection of corporate assets .... Ricoh Personnel Division
                                        ------------------------

12  Respecting the global environment .... Ricoh Corporate Environment Division
                                           ------------------------------------

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13  Respect for human rights .... Ricoh Personnel Division
                                  ------------------------

14  Practical contributions to society.... CSR Office
                                           ----------

15  Harmonizing with society .... Ricoh Corporate Planning Division
                                  ---------------------------------

CENTRAL AUTHORITY

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

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<PAGE>

                        The Ricoh Group Code of Conduct

                   Approved by the Board on November 4, 2003
                           Effective January 1, 2004

                 Ricoh Company, Ltd. CSR Office
                            8-13-1 Ginza, Chuo-ku,
                                Tokyo 104-8222
                               Tel: 03-6278-5202

                                Copyright 2003
                    RICOH COMPANY, LTD. All rights reserved

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