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Ricoh Electronics, Inc. Disclosures

On September 30, 2010, California Senate Bill 657, the California Transparency in Supply Chains Act of 2010 (the “Act”), was signed into law and codified in Section 1714.43 of the California Civil Code and Section 19547.5 of the California Revenue and Taxation Code. The Act requires large retail and manufacturing companies to disclose what efforts they have taken to eliminate slavery and human trafficking from their supply chains. As explained in the policy statement in the beginning of the Act, the law aims to “provide consumers with information regarding [companies’] efforts to eradicate slavery and human trafficking from their supply chains” and to “educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains.” The Act becomes effective on January 1, 2012.

Each company that is required to comply with the Act must, at a minimum, disclose whether, and to what extent, the company:

1. Engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
   
2. Conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.
   
3. Requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
   
4. Maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
   
5. Provides company employees and management who have direct responsibility for supply chain management with training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.

Overview of Ricoh Electronics’ Actions

Overview of Ricoh Electronics’ Actions to Promote Corporate Social Responsibility and Support Human Rights

Within Ricoh we use our core values to operate with integrity, respect and trust in our dealings with our customers, fellow employees and our community. The commitment to integrity, respect and trust in all of our actions and responsible corporate citizenship are the core philosophies we want to encourage in all suppliers of Ricoh Electronics, Inc. (REI). This commitment means that all suppliers must share a common set of objectives and conduct their business activities in a manner that scrupulously adheres to our principles of business. REI established a Supplier Code of Conduct that applies to every supplier and governs the manner in which they conduct all of their business activities.

Ricoh Electronics’ Response to the Act

The following are REI’s actions related to each key point described in the Act.

1. Ricoh regularly evaluates and addresses human rights issues as part of its worldwide commitment to fair labor practices within the Ricoh Group supply chain. The UN Global Compact, launched in July 2000, advocates ten principles in the fields of human rights, labour, environment and anti-corruption. Ricoh joined the Compact in 2002, as one of the first Japanese companies to do so and has been serving as one of the directors on the Global Compact Japan Network since fiscal 2008.

The Ten Principles
  • [Human Rights]
  • 1. Businesses should support and respect the protection of internationally proclaimed human rights; and
  • 2. make sure that they are not complicit in human rights abuses
  • [Labour]
  • 3. Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;
  • 4. the elimination of all forms of forced and compulsory labour;
  • 5. the effective abolition of child labour; and
  • 6. the elimination of discrimination in respect of employment and occupation.
  • [Environment]
  • 7. Businesses should support a precautionary approach to environmental challenges;
  • 8. undertake initiatives to promote greater environmental responsibility; and
  • 9. encourage the development and diffusion of environmentally friendly technologies.
  • [Anti-Corruption]
  • 10. Businesses should work against corruption in all its forms, including extortion and bribery.

REI’s Supplier Code of Conduct specifically addresses the prohibition of human trafficking and/or slave labor in three points. The Code elements read as follows:

Human Rights
  • - Treat people with dignity and respect.
  • - Support and respect the protection of international human rights within the organization’s sphere of influence.
  • - Encourage your organization and its supply chain to avoid complicity in human or employment rights abuses.
   
2. REI strives to do business with suppliers of sound business character and reputation. Currently REI does not audit or monitor factories producing goods in its supply chain. REI’s Supplier Code of Conduct, however, requires that vendors adhere to REI’s Code of Conduct standards which prohibit engaging in human trafficking and/or slave labor in their production facilities. We will continue to promote fair labor practices and safe working conditions throughout our supply chain as we evaluate the best methods and tools for detecting noncompliance with our Supplier Code of Conduct.
   
3. REI recognizes the importance of protecting the human rights of workers who produce the goods and materials for our products. We require direct suppliers to certify in writing that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
   
4. REI considers fair labor practices an important part of human rights. We specify in our Supplier Code of Conduct that business partners must conduct their business activities in a manner that scrupulously adheres to our principles of business, which are grounded in concepts of integrity, good judgment and the highest ethical standards. Failure to comply with legal requirements in any country in which their business is conducted, including laws related to slavery or trafficking, will trigger an investigation by senior executives, including our corporate general counsel, into the potential violation and may result in the suspension or termination of the supply agreement.
   
5. REI has established a corporate training program on human trafficking and slavery issues. Our Procurement/Sourcing team, who has direct responsibility for both our domestic and international supply chain, has already received the training. We will provide training as appropriate for other company employees and management with supply chain involvement.

We will continue to update this webpage to reflect our progress in preventing and addressing potential human rights violations in our supply chain through the continued promotion of corporate social responsibility and support of human rights.

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