Code of Business Ethics

Managing Insider and Confidential Information

Rogers Corporation directors and employees are prohibited from using material non-public information obtained during their employment for their own personal profit or the profit of anyone else. Accordingly, Rogers prohibits insider trading, including the purchase or sale of securities when in possession of material non-public information. Also prohibited is any communication of material non-public information to another person for purposes of trading on that information. This policy applies not only to insider trading relating to Rogers, but also to its business partners (such as suppliers and customers), since material non-public information about these business partners may be obtained during the normal course of employment. In addition, this policy applies to employees even after leaving employment with Rogers for as long as the information remains confidential and non-public.

What is insider trading?

Insider trading generally refers to the buying or selling a security (for example, stocks, debt instruments or bonds), while in possession of material, non-public information about the security. Information is “material” if a person would consider the information important in making a decision to buy or sell securities of that company. Material information can include positive or negative information about a company. Non-public information includes proprietary and other information about Rogers or other companies learned through employment with the company that is not available to those generally outside of the company. This non-public information may include sales and financial results, strategic plans, research results, introduction of new products, material contracts or new licensing agreements, anticipated government actions, significant personnel changes and acquisition or divestiture information.

What is expected of you?

  • Do not buy or sell securities of any company on the basis of any material, non-public information gained during employment with Rogers.
  • Do not disclose any material, non-public information gained during employment to anyone outside Rogers, including family members or friends, so that they can buy or sell securities.
  • Comply with all applicable laws and regulations regarding disclosures and the sale or purchase of Rogers securities as well as the company’s insider trading policy.
  • Seek guidance from the Legal & Compliance Department if you are unsure whether information is “material”, “non-public” or otherwise.

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