<PAGE>

                                                                     Exhibit 11

RICOH

THE RICOH GROUP
CODE OF CONDUCT

                                                                    Page 1 of 29

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Message from the CEO

     As globalization increases, companies have become more and more active in
their role as global citizens. This new movement has resulted in a move from
mere voluntarily social contribution to genuine social responsibility. This
trend is reflected at a management level. We are now entering a more vigorous
period of strong ethics, morals and responsibility beyond compliance.

     Along with the globalization of our corporate activity and group
management, the Ricoh Group has been increasingly populated with people of
diverse values and cultures in a variety of countries around the world. On the
business front, we have engaged in deeper relationships with a great diversity
of stakeholders. This in turn created the need to unite our thinking around
common values and standards of behavior resulting in " the Ricoh Group CSR
Charter " shared globally across the Ricoh group as well as " the Ricoh Group
Code of Conduct " adopted by all Ricoh group members in November, 2003.

     The Ricoh Group sees corporate social responsibility both as an opportunity
to create corporate value and to promote a sustainable society.

     Looking back at various circumstances since the establishment of the Code
of Conduct, we reaffirm the importance of our defined targets of CSR activity,
"Integrity of Corporate Activities", "Harmony with the Environment", "Respect
for People" and "Harmony with Society". We aim not only to implement CSR within
the Ricoh Group but also throughout the supply chain including procurement and
sales.

     Furthermore, the international community is taking an increasingly strong
stance on "Human Rights", "Labour Standards", "Environment", and
"Anti-corruption" as advocated in the United Nations Global Compact.

     Profound adherence to this Code will help us to earn society's trust,
ensure sustainability and to be recognized as "a reliable and attractive global
corporation". I expect each of you as a member of the Ricoh Group to make this
code part of your daily life.

October 1, 2008

                                                   Shiro Kondo
                                                   President and CEO,
                                                   Ricoh Group

                                                                    Page 2 of 29

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CONTENTS

                                                                            Page
                                                                            ----
Introduction.............................................................      4

Integrity in Corporate Activities
   1    Providing customer-oriented products and services................      7
   2    Free competition and fair trading................................      8
   3    Banning insider trading..........................................      9
   4    Managing corporate secrets.......................................     10
   5    Limits on entertainment and gifts................................     11
   6    Doing business with public bodies and making political
           contributions.................................................     12
   7    Strict control of exports and imports............................     13
   8    Protection and use of intellectual properties....................     15
   9    Participation in anti-social actions.............................     16
   10   Individual actions against the interests of the company..........     17
   11   Protection of corporate assets...................................     18

Harmony with the Environment
   12   Respecting the global environment................................     19

Respect for People
   13   Respect for human rights.........................................     21

Harmony with Society
   14   Practical contributions to society...............................     22
   15   Harmonizing with society.........................................     23

Employee "Hot Line" contents and information.............................     24
Ricoh Group CSR Charter..................................................     26
Ricoh Group CSR Framework................................................     28

                                                                    Page 3 of 29

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Introduction

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 and
in-company regulations.

                                   [GRAPHIC]

DEFINITIONS

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

1.   "Ricoh" refers to Ricoh Company, Ltd.

2.   "Ricoh Group" refers to Ricoh and consolidated Group Companies.

3.   "Ricoh Group Companies" refers to individual companies in the Ricoh Group.

4.   "Officers and Employees" refers to 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 temporary
     employment).

*    ADMINISTRATION OF THE CODE IS DEFINED BY RICOH GROUP CODE OF CONDUCT:
     ADMINISTRATION (RGS-ASRG0001)

*    THIS CODE IS ALSO AVAILABLE ON THE FOLLOWING WEBSITE.
     http://www.ricoh.com/about/pdf/code.pdf

                                                                    Page 4 of 29

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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, 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.

                                                                    Page 5 of 29

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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.

                                                                    Page 6 of 29

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Integrity in Corporate Activities

1    PROVIDING CUSTOMER-ORIENTED PRODUCTS AND SERVICES

     Basic Policy

     The Ricoh Group's basic policy in developing and providing products and
     services to its customers is based on a customer-driven approach.

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

     Related Standards:

          Quality Assurance Regulation for Ricoh Group (RGS-AQMA0001)
          Product Safety Regulation for Ricoh Group (RGS-AQMA0002)

                                                                    Page 7 of 29

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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"

          "Ricoh Group Regulations for Compliance with the Subcontractor Act"

          "Management Standard for the Prevention of Bid Rigging"

                                                                    Page 8 of 29

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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.

                                                                    Page 9 of 29

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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 confidential information.

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

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

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

     (4)  No acquisition of information by dishonest means.

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

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

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

     Related Standards:

     Ricoh Group ISMS Management Standards (RGS-AITC5001)

                                                                   Page 10 of 29
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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"

                                                                   Page 11 of 29

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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.

                                                                   Page 12 of 29

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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 such as tariff-related laws for
     appropriate export and import procedures, and those on the countries with
     which to trade.

     Actions

     (1)  Applicability assessment for trading goods and technologies

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

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

          Officers and Employees, when importing or exporting goods or related
          technologies, shall confirm beforehand in the light of applicability
          assessment of restrictions, customer assessment or country assessment,
          whether such export or import would infringe the relevant laws and
          regulations or require a permit. When restrictions are found to be
          applicable, appropriate import/export procedures shall be followed.

     (3)  Export restrictions for non-proliferation

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

          When there is concern that goods or related technologies may be
          converted for military use, Officers and Employees shall ascertain the
          ultimate user and the ultimate purpose for which the goods or
          technologies 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.

     Related standards:

          Rules on compliance with export & import related Regulations
          (RGS-ATRA5001)

                                                                   Page 13 of 29

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          Ricoh Group International Trade Regulations (RGS-ATRA0003)

          Origin Management (RGS-ATRC0004)

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

                                                                   Page 14 of 29

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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.

                                                                   Page 15 of 29

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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 own company.

     (3)  Have no dealings with anti-social elements.

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

                                                                   Page 16 of 29

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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.

                                                                   Page 17 of 29

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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"

                                                                   Page 18 of 29

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Harmony with the Environment

12   RESPECTING THE GLOBAL ENVIRONMENT

     Basic Policy

     The Ricoh Group is not only aware that environmental preservation is the
     solemn duty of every citizen of the world, but also aligns corporate
     activities with environmental preservation, taking responsibility for
     ensuring that the entire group participates.

     Actions

     (1)  Set higher targets for environmental activities and achieve them.

          Officers and Employees will not only be in full compliance with all
          laws, but will take personal responsibility for establishing high
          targets that reflect social expectations , and seek to create economic
          value in achieving these targets.

     (2)  Develop innovative environmental technologies.

          Officers and Employees will encourage the development of innovative
          environmental technologies that create customer value and can be
          utilized widely in society.

     (3)  Keep making continuous improvement.

          Officers and Employees, in business operations, will be aware of their
          environmental impact of their activities, and will seek continuous
          improvement to prevent pollution, and to ensure the effective use of
          energy and other resources.

     (4)  Provide products and services that reflect environmental concerns.

          Officers and Employees will make every effort to reduce environmental
          impact at all stages of the product cycle, from procurement of
          materials, through production, sales, distribution, recycling and
          disposal.

     (5)  Promote responsible environmental preservation while enhancing
          awareness s.

          Officers and Employees will remain aware of the wider society around
          them, and work actively through education and other means to
          personally shoulder their responsibility and work toward environmental
          preservation.

     (6)  Contribute to achieving a sustainable society.

          Officers and Employees will contribute to achieve sustainable society
          by participating or supporting environmental preservation activities.

                                                                   Page 19 of 29

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     (7)  Gain the trust of society through communication

          Officers and Employees will develop environmental preservation
          activities, cooperating with stakeholders and gain the trust of
          society through active communication

     Related Standards:

          "Ricoh General Principles on the Environment"

          Ricoh Group Environmental Management Regulation (RGS-AEP A0001)

                                                                   Page 20 of 29

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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)

                                                                   Page 21 of 29

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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.

                                                                   Page 22 of 29

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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.

     Related Standards:

          Ricoh Group Advertising Regulation (RGS-AADA001)

                                                                   Page 23 of 29

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Employee "Hot Line" contents and information

Officers and Employees who become aware of contraventions of this Code of
Conduct, or any risk that they might be contravened, are required to contact
Internal Management & Control 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.

                 "HOTLINE" INFORMATION (available only in Japan)

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

     Apply to:

                 Ricoh: Internal Management & Control Office

                 Tel: 0120-344-670 (tall-free)

                 E-mail: ZPG_CSR@nts.ricoh.co.jp

                 Letters: Internal Management & Control 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 as listed below.

INDIVIDUAL RESPONSIBLE SECTIONS

1    Providing customer-oriented products and services ..... Ricoh Quality of
                                                             ----------------
     Management Section
     ------------------

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

3    Banning insider trading ..... Ricoh Internal Management & Control Section
                                   -------------------------------------------

4    Managing corporate secrets ..... Ricoh Administration Section
                                      ----------------------------

                                                                   Page 24 of 29

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

6    Doing business with public bodies ..... Ricoh Personnel Section
                                             -----------------------
     Making political contributions ..... Ricoh Secretary Office
                                          ----------------------

7    Strict control of exports and imports ..... Ricoh Trading Section
                                                 ---------------------

8    Protection and use of intellectual properties ..... Ricoh Intellectual
                                                         ------------------
     Property Section
     ----------------

9    Participation in anti-social actions ..... Ricoh Administration Section
                                                ----------------------------

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

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

12   Respecting the global environment ..... Ricoh Environment Section
                                             -------------------------

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

14   Practical contributions to society ..... Ricoh CSR Section
                                              -----------------

15   Harmonizing with society ..... Ricoh Public Relations Section
                                    ------------------------------
                                    Ricoh CSR Section
                                    -----------------

                                                                   Page 25 of 29

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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 engage in activities that contribute to society.

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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.

                                                                   Page 27 of 29

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     Framework of the Ricoh Group's CSR

                                    [GRAPHIC]

                                                                   Page 28 of 29

<PAGE>

                         The Ricoh Group Code of Conduct

                    Approved by the Board on November 4, 2003
                    Effective January 1, 2004
                    Revised October 1, 2008

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

                    Copyright 2003, 2008
                    RICOH COMPANY, LTD. All rights reserved

                                                                   Page 29 of 29