Code of Business Ethics

Complying with Competition and Antitrust Laws

Rogers Corporation is committed to complying with all competition and antitrust laws applicable in the countries where we do business. We must compete vigorously and fairly in our efforts to be successful, and we must only seek competitive advantage through lawful means. We must not act in ways that stifle the free market, and we must not exchange information or enter into agreements or understandings with competitors, customers, suppliers or other third parties that improperly influences free competition, research and development activity, or manufacturing, marketing, sales or distribution practices.

Do not engage in business dialogue with our competitors unless there is a legitimate business reason to do so. If you expect to engage in these types of discussions, be sure to take appropriate precautions, such as consulting with your supervisor, a member of senior management or the Legal & Compliance Department, to ensure that your discussions focus only on permissible topics.

What are competition and antitrust laws?

Competition and antitrust laws seek to promote and protect the competitive process. These laws prevent companies from entering into anti-competitive agreements (formal or informal) and prevent companies that have dominance in a particular market from abusing their position. Practices that damage competition, the ability of other companies to access a market, or consumers are generally prohibited by these laws. In many cases these laws can be applied to conduct that occurs outside a country’s borders.

What is expected of you?

  • Do not enter into agreements and understandings, whether written or oral, formal or informal, that are anti-competitive.
  • Consult the Legal & Compliance Department before having discussions with competitors that could appear to be anti-competitive, or if you have any questions regarding whether a communication or agreement might be, or might give the appearance of being, anti-competitive.
  • Avoid any discussion with a competitor on topics that are, or could give the appearance of being, anti-competitive, such as specific customers, price, terms and conditions of sale.
  • Avoid exchanging non-public or other sensitive information with customers or other third parties where not necessary for legitimate business purposes, or if it would give the appearance of an inappropriate agreement.

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