Ricoh Disclosure Policy (for engaging with capital markets)

1. Basic Approach

The Ricoh Way encompasses the Spirit of Three Loves of founder Kiyoshi Ichimura and Ricoh's Mission & Vision, and Values, and guides our efforts to pursue sustainable growth and build corporate value over the medium and long terms.

To that end, we engage energetically and constructively with shareholders, other investors, and other capital market participants. We maintain a cycle in which we reflect feedback from those stakeholders in our activities to cultivate trust through mutual understanding.

In operating based on that cycle, we endeavor to innovate and deliver value that is useful for everyone, everywhere, helping to enhance their lifestyles and create social sustainability while increasing medium- and long-term corporate value.

2. Policy Objectives

We aim to engage efficiently in timely and fair-minded dialogue with the capital markets by maintaining a clear structure and stance with respect to our policy on handling our own information and engagement.

3. Relevant Information and Disclosure Methods (Timely and Voluntary)

We disclose information in a timely manner in keeping with the Financial Instruments and Exchange Act and other related regulations and the rules of stock exchanges on which our securities are listed. Through our website and other channels, we swiftly disclose facts that could materially affect the investment decisions of shareholders and other investors even when such regulations and rules do not require it to do so.

This policy encompasses the disclosure of financial information, medium-term management strategies, results backgrounds and analyses, as well as environmental, social, and other non-financial information that helps deepen understanding of Ricoh. We use dialogue, briefings, our website, our publications, and other tools in striving to bolster voluntary disclosure.

4. Internal Structure for Disclosure

We maintain the following internal structure to ensure appropriate disclosure, and will accordingly keep enhancing relevant systems.

• We maintain policies to disclose accurate, timely, and fair information.
• The Chief Financial Officer (CFO) is responsible for disclosing information to shareholders, other investors, and other capital markets participants.
• We set up the Disclosure Committee which the CFO chairs, to assess the importance, necessity, and suitability of disclosure.
• We created an organization to oversee disclosure, centrally hold and safeguard important corporate information, and define responsibility for disclosure.
• We confirm the suitability of disclosure by using databases to record disclosure processes and conduct regular internal audits.
• We use our website and publications extensively and strive to improve the quality and browsability of information to streamline access to management, financial, and non-financial information.

5. Policy for constructive engagement with shareholders

• The President and CEO is the person responsible for engagement with shareholders, and an executive in charge may be appointed as required.
• The Investor Relations Department is responsible for promotion engagement with shareholders, and takes charge of liaising with related departments.
• Depending on the purpose of the dialogue and the number of shares held, the President and CEO, the CFO, business unit presidents, the Chief Human Resources Officer (CHRO), ESG officers, Internal as well as Outside Directors/Audit & Supervisory Board Members, and the Investor Relations Department conduct engagement activities.
• As main dialogue opportunities, we conduct large and small meetings such as medium to long term strategy briefings, quarterly financial results briefings, and business briefings, Outside Directors small meetings, and 1-on-1 individual dialogues. In addition, we hold briefings at externally sponsored IR events and conferences as appropriate.
• We provide feedback to management according to the following policies:
  1. We report on the reaction from the capital market based on information including the content of dialogue with shareholders and investors and analyst reports after conducting large meetings such as quarterly financial results briefings and medium to long term strategy briefings.
  2. We share the views on the Ricoh Group obtained through dialogue with management and the Investor Relations Department, as well as with the capital market through means such as a perception study survey, with management and executives. The President and CEO and the CFO take the lead in improving disclosure that leads to more constructive dialogue based on the views.
  3. We report the opinions of shareholders and investors, mainly when management engages in dialogue with them, unchanged in principle in terms of content, in order to provide feedback to management as clearly and without discrepancies as possible.

6. Handling Confidential Information

We maintain internal rules to ensure that Group executives and employees treat material undisclosed information properly prior to public announcements and to prevent insider trading. We also devote considerable attention to educating executives and employees to ensure thorough management of insider information.

7. Managing Material Information when Engaging in Dialogue

We refrain from engaging in individual discussions about material undisclosed information that could affect the investment decisions of shareholders and other investors because we wish to avoid selective disclosure to just some market participants.

We engage in dialogue with shareholders and other investors based on facts and information that we have already disclosed publicly. We do not comment, including with regard to quantitative or qualitative information, on undisclosed matters.

8. Quiet Periods

We prevent information leaks while preparing earnings announcements and ensure fair disclosure by maintaining quiet periods that extend from the day after each fiscal quarter ends through the results announcement date. In principle, we refrain during such periods from answering questions or commenting.

9. Results Forecasts and Other Forward-Looking Information

We disclose earnings plans, capital policies, their underlying business strategies, and other forward-looking information through our medium-term management strategies, annual plans, and other channels. We do this based on management's assessments of information available at the time of disclosure, such information being subject to risks and uncertainties. When disclosing such information, we ensure that we present management issues or factors that could affect future developments.