The Ricoh Group considers that “compliance” includes observance of not only laws and regulations, but also company rules and social ethics. Therefore, the Ricoh Group provides thorough instruction of each company's action principle, which provides the principles of Ricoh Group's corporate behaviors, and “Ricoh Group Code of Conduct”, which indicates behavioral principle of directors and employees of the Ricoh Group. Every member of the Group is concerned to ensure all employees observe the principles in their daily activities.
In Japan, the Ricoh Group provides all of its directors and employees with the education on the Code of Conduct via e-learning programs every year. The content of the education includes, confirmation of each provision of the Code of Conduct, as well as other topics relating to the enforcement of laws and regulations as priority issues with actual case examples. So far, topics such as, “Banning participation in anti-social actions”, “Limits on entertainment and gifts”, “Banning insider trading” have been featured.
When the study is completed, a test to check the level of understanding of the education, a compliance awareness survey is conducted. At the end, each person sign a pledge to confirm that he or she understood and will observe the Code of Conduct.
The overseas Ricoh Group companies are also providing education tailored to each country's laws and customs and the forms of local operation.
Internal audit is conducted for the purpose of securing credibility of financial reports, improvement of operational efficiency, confirmation of the observation of the laws and regulations, etc. The implementation of compliance within each company and each department is also verified within the internal audit.
The Ricoh Group has established “Ricoh Group Hotline”, which is made available to all directors, employees, part-timers and temporary staff in Japan as a contact for whistle-blowing and consultation regarding violations of compliance. Independent contact points are set up externally at the first point of contact. In any case, the numbers and website for exclusive lines has been set up to provide protection for the security of details of the consultation. Furthermore, a ban on unfavorable treatment of whistle-blower for the act of whistle-blowing or consultation itself, but also a ban on retaliatory actions against them have been established to protect whistle-blowers. The reception hours are being reviewed in order to make it more accessible to consult, for instance, night-time and holidays are added to regular work hours for telephone calls, and 24 hours for contact by website. The Group standard on whistle-blowing system was established by including these details, and is now applied.
The content of whistle-blowing and consultations are reported to the top management periodically, for the horizontal spread of improvement of problems and preventive measures of the Ricoh Group as a whole.
In addition to “Ricoh Group Hotline”, major companies in Japan and in overseas have established their own contact for whistle-blowing and consultation according to their organizational and regional characteristics.
In addition, since November 2018, the Ricoh Group has established the “Ricoh Group Global Whistle-Blowing System,” which is available to all directors and employees at Ricoh Group companies in Japan and overseas. We have built a system in which workers can report directly to the full-time auditor of Ricoh by e-mail.
For the purpose of confirming that business activities of the Ricoh sites comply with the 10 principles of the United Nations Global Compact, the laws, regulations and ordinances of each country and the Ricoh Group Code of Conduct, in fiscal 2015, the CSR Self-Assessment was conducted at three production sites in China and one site in Thailand, which are major production sites of imaging systems.
As a result, we confirmed that these four sites have been executing business activities in compliance with the international norms, the laws and regulations and the Ricoh Group Code of Conduct. It has also been confirmed that, some CSR activities are highly evaluated by the Chinese government organizations and the three production sites in China have received remarkable commendation, especially in the categories of ‘labor practices’ and the ‘environment’. The said result shall be shared not only among these production sites in question but also across the entire Ricoh Group and contributed to our CSR driven business practice.
One of the seven values in Ricoh Way that should be respected by the Ricoh Group employees is the compliance mind “Ethics and Integrity - Act with honesty and accountability.” We are conducting awareness-raising activities for all Group employees to let the thought penetrate and motivate them to have a strong sense of ethics, a law-abiding spirit and always work with a sense of integrity and responsibility.
Furthermore, we translate into English and share the information on illegal matters throughout the Ricoh Group that are reported to top management.
As mentioned in “Risk Management” the risks relating to violations of compliance was set up as part of the risk management items which may exert a significant influence on the group's business (operation), the risk management is carried out, with focus on preventive measures on one hand, and rapid response in the event of an outbreak of a risk on the other.
“The Ricoh Group Code of Conduct” provides for the global basic policy and specific actions, while the Group standards and Guidelines provide for items that call for further responses.
The following shows examples of responses to some of the compliance related risks.
The Ricoh Group established RGS, “Ricoh Group Standard for Bribery Prevention” in compliance with “7. Ensuring fair corporate activities”, stipulated in “Ricoh Group Code of Conduct”.
This standard sets out procedures aimed at the prevention of acts of bribery and to ensure compliance with laws and regulations prohibiting corruption and bribery such as the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010, that are applied in any of the countries and regions in which the Ricoh Group operates business, and thus facilitates the bribery prevention of Ricoh Group companies and all of their directors and employees.
At the same time, the Ricoh Group established “Ricoh Group Bribery Prevention Guidelines for Third Parties” as well, in order to prevent bribery by third parties (*) of the Ricoh Group, by informing the Ricoh Group's policy of bribery prevention.
In addition, it is defined in the Guidelines that when making political contributions or other donations or providing sponsorship, it is necessary to comply with the laws and regulations applicable to the country or region concerned when doing so and to seek the approval of the decision-making authority at each Ricoh Group company in advance.
Political contributions in FY2019: JPY 0
Donations in FY2019: All donations were properly processed with the approval of the relevant authority.
In addition to the education of the Code of Conduct, the Ricoh Group has been conducting education about bribery prevention in accordance with the necessity of each region, attempting to familiarize the problems and taking preventive measures. In the United States and United Kingdom, in order to address the US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act 2010, the policy on bribery prevention and entertainment and gifts was established and the education is being provided as well.
Furthermore, in order to respond appropriately to the laws for the prevention of illegal transactions by corporations, we have been cooperating with subject matter experts such as lawyers in order to prevent any in appropriate behavior.
Preventive measures are being taken, for instance, guidebooks that provide the roles of responsible departments and daily behavioral norms are established in the RGS, and articles regarding the exclusion of organized crime are incorporated in various agreements with the third parties, etc.
As a company, in cooperation with the police, corporate lawyers and other external organizations, the Ricoh Group has established a framework to response timely and appropriately towards the contact from anti-social forces.
Because of the fact that the Group Headquarters is located in Japan, the possibility of insider trading is higher than in other regions. Thus, in Japan, education by e-learning program is provided and specific rules are established in the RGS.
In the RGS, as one of the measures to prevent insider trading with respect to the trading of stocks of listed companies of the Ricoh Group, the rule for in-advance application is established. For instance, the periods prior to stockholders' meetings or before the release of the business results, insider information is most likely to rises. Thus, these periods are designated as lock-up i.e. a closed period, for the concerned parties of the Ricoh Group, such as directors, employees, part-timers and temporary staff.
The Ricoh Group's Corporate Code of Conduct stipulates that we comply with the relevant laws and regulations regarding transactions with public institutions and political contributions, and that we will practice (1) strict impartiality, neither making (2) improper political contributions nor participating in election activities.
Ricoh's political contributions and other expenditures over the last four years are as follows:
Political contributions and other spending
(Millions of yen)
|Lobbying, interest representation or similar||0||0||0||0|
|Local, regional or national political campaigns / organizations / candidates||0||0||0||0|
|Trade associations or tax-exempt groups (ex. Think tanks)||77.5||76.7||74.8||75.1|
|Other (ex. Spending related to ballot measures or referendums)||0||0||0||0|
|Total contributions and other spending||77.5||76.7||74.8||75.1|
Major contributions / expenditures and Ricoh’s engagement
|Name of organization||Type of organization and Ricoh’s position / engagement|
|Japan Business Machine and Information System Industries Association
|The Japan Business Machine and Information System Industries Association (JBMIA) is an industrial organization dedicated to the development of the Japanese economy and the improvement of the office environment through the comprehensive development of the office equipment and information systems industry.
Ricoh served as a representative company for two years, from 2018 to 2019, and our CEO, Yoshinori Yamashita, led the activities of JBMIA as a chairman.
More than 100 Ricoh employees from R&D and business strategies divisions participate in research. They work based on JBMIA's philosophy of proposing new work styles, pursuing safety and security for customers, and realizing a low-carbon society/circulation-based society. They are mandated to make policy proposals regarding technology and trade, international cooperation, global warming prevention, environmental conservation, standardization, product safety, etc.
|Japan Electronics and Information Technology Industries Association
|The Japan Electronics and Information Technology Industries Association (JEITA) is an industrial organization tasked to promote the healthy manufacturing, international trade and consumption of electronics products and components in order to contribute to the overall development of the electronics and information technology (IT) industries, and thereby further Japan's economic development and cultural prosperity.
Ricoh works closely with other member companies to minimize the risks related to conflict mineral issues, human rights abuses, labor issues or environmental destruction, etc. We continue to secure transparency in the supply chain, and ensure responsible mineral sourcing practices.
|Japan Business Federation
|KEIDANREN (Japan Business Federation) is a comprehensive economic organization with a membership comprised of 1,444 representative companies of Japan, 109 nationwide industrial associations and the regional economic organizations of all 47 prefectures.
Keidanren is committed to the steady and prompt resolution of international issues by developing close economic relations with individual countries through policy dialogues with various governments and economic organizations. Ricoh is a member of the Executive Committee and the Standing Board, both of which deliberate policy recommendations and reports on all activities of Keidanren.
|Japan Association of Corporate Executives
|Japan Association of Corporate Executives (KEIZAI DOYUKAI) is a private, nonprofit, nonpartisan organization founded in 1946, whose mission is to improve the Japanese economic community and seek solutions for numerous domestic issues to ensure the overall well-being of Japanese society. KEIZAI DOYUKAI membership comprises approximately 1,500 top executives, and all members discuss various issues and make policy proposals, with the common belief that corporate managers should be key players in formulating solutions for a broad range of political, economic, and social issues.
Three executives from Ricoh are members and are actively engaged as chairs and vice chairs of various policy committees. Masamitsu Sakurai, chairman of Ricoh, was the lead secretary of DOYUKAI from 2007 to 2010.
|Japan Machinery for Center for Trade and Investment
|The Machinery for Center for Trade and Investment (JMC) is a non-profit organization established to engage in activities which enhance the common benefits of member companies and promote the sound development of international trade and investment by the machinery industry.
Ricoh sits on a committee that mainly deals with trade, economic cooperation, and export control. In cooperation with other members, we strive to analyze and study foreign laws and regulations, including foreign exchange laws, and make proposals to government organizations on enhancing export control conditions.
In accordance with our corporate social responsibility policy we strive to maintain and improve our tax compliance and pay all taxes in accordance with national and regional laws and international rules.