Code of Business Ethics

Fundamental Principles

The following fundamental principles provide the foundation for understanding and applying the standards of conduct found in this Code. Real-world circumstances will not always permit a neat fit for the application of these standards; so it is critical that you actively seek support and guidance from your supervisor, Human Resources representative, the Director of Compliance & Integrity or the Legal & Compliance Department.

Why is this Code of Business Ethics so important?

A good reputation supports our ability to do business and helps us build the strong relationships we need for continued success. It creates goodwill to draw upon when challenges or difficulties arise.

Our corporate reputation is built on the trust and confidence of our employees, customers and stakeholders and the communities in which we operate. This trust is one of our most valuable assets.

Rogers Corporation is a global business, and our activities touch many people’s lives - including customers, suppliers, regulators, shareholders, employees, business partners and the communities around us. All our interactions with these groups should be governed not only by legal and regulatory requirements, but also by our own high ethical standards. Remember that, with the speed of modern communication technologies, our actions are instantly and irretrievably visible worldwide.

Accordingly, we must all act properly and in ways that are consistent with the high ethical standards we have set for ourselves and Rogers. Doing so will enable us to maintain the trust and confidence of our stakeholders and continue to be a valued and respected member of the business community.

Who is covered by this Code of Business Ethics?

This Code and its supporting policies apply to all Rogers Corporation employees and to members of Rogers’ Board of Directors. Consultants and suppliers should also adhere to this Code in performing services for, and providing products to, the company.

What does it mean in practice and who is responsible?

All of us must act with honesty and integrity at all times and refrain from behaving and assisting others in behaving dishonestly or fraudulently. We are also responsible for contributing to an open and honest environment at Rogers that supports the ethical and effective management of risks to people, products, property, reputation and information.

We must be aware of, and act in accordance with, this Code of Business Ethics, all supporting policies and the laws and regulations of the countries in which we work and do business.

How is this Code of Business Ethics Implemented?

This Code of Business Ethics has been adopted by Rogers’ Board of Directors and applies worldwide. “Rogers” as used throughout this Code, includes Rogers’ controlled entities globally. This Code applies to all directors, officers, employees and representatives, including consultants and agents. The Director of Compliance & Integrity is responsible for implementing this Code. Waiver of all or part of this Code of Business Ethics, conflicts of interest, or various other policies issued to supplement the Code will be granted only in exceptional circumstances and only after approval by Rogers’ Director of Compliance & Integrity. Any waivers for directors and executive officers must be approved by both by Rogers’ Director of Compliance & Integrity and the Board of Directors or a Board committee and will be disclosed promptly as required by law, regulation and Rogers’ policy.

The standards of conduct contained in this section represent our minimum expectations for ethical business behavior.

All employees have an obligation to raise any questions or concerns he or she may have regarding this Code and report any good faith suspicions of its violation or violation of applicable law. Moreover, employees have an affirmative obligation to reasonably support the company in investigating any such suspected violations.

Our officers and all supervisors are responsible for providing appropriate support to enable their employees to understand the requirements of this Code and supporting policies and how they should be applied. You also must be prepared to exercise good judgment and common sense in deciding the right actions to take as this Code and our supporting policies cannot cover every situation that may arise. You should ask questions if you are unclear about any aspect of this Code or if you are not sure how to respond to an issue that the Code does not address.

You also must promptly report any violations of laws, regulations, this Code or company policies of which you become aware.

ANY FAILURE TO COMPLY WITH THIS CODE OR ITS SUPPORTING POLICIES WILL BE FULLY INVESTIGATED AND APPROPRIATE ACTION TAKEN SUCH AS RETRAINING, DISCIPLINE, OR OTHER CORRECTIVE ACTION, INLCLUDING TERMINATION OF EMPLOYMENT, DEPENDING ON THE CIRCUMSTANCES.

How do you ask a question or raise a concern?

Rogers Corporation is committed to an open and honest environment. ANYONE WHO RAISES A CONCERN IN GOOD FAITH ABOUT A POSSIBLE BREACH OF THIS CODE VIOLATION OF POLICY OR OTHER COMPLIANCE CONCERN WILL NOT BE SUBJECT TO RETALIATION. ANY ACT OR THREAT OF RETALIATION IS CONSIDERED A SERIOUS VIOLATION OF THIS CODE.

You may at some time come across a situation that may appear to violate this Code, company policy or applicable law. You also may have questions about this Code, a company policy or a particular situation. You are encouraged to ask questions, seek clarification or raise a concern through appropriate channels.

In general, you should first seek to address your question or concern with your supervisor. If you believe this is not appropriate under the circumstances, you may also contact Human Resources, the Director of Compliance & Integrity or the Legal & Compliance Department.

If you prefer to contact someone outside your area, you may also utilize our confidential Ethics Hotline:

USA: 888.475.8376
Belgium: 0.800.100.10.888.475.8376
China: 00.729.11.888.475.8376
Germany: 0.800.225.5288.888.475.8376
Hungary: 06.800.011.11.888.475.8376
Korea: 00.729.11.888.475.8376

OR via the web: http://Rogersvaluesline.alertline.com

For the most current contact information, as well as other helpful materials, please see the Compliance & Integrity page of RogersNet.

Asking Questions and Raising Concerns

Questions regarding this Code of Business Ethics, its application to specific circumstances, and reports of actual or suspected violations can be raised to any level of the supervisory chain, the Legal & Compliance Department, the Director of Compliance and Integrity, Human Resources, or by using the Rogers Ethics Hotline.

The Rogers Ethics Hotline is confidential (by protecting the identity of the person raising the issue) and independent (by operating separately from management). In addition, through the Ethics Hotline, questions or concerns can be submitted anonymously.

Practice Tips

A good strategy to follow when trying to make the right decision is to ask yourself the following questions:

  • Am I following the most stringent applicable law, policy or practice?
  • Am I acting in the best interests of our Company and our shareholders?
  • Is there someone at our Company that can help me with my decision?
  • Would I feel comfortable if my colleagues, family, friends or the public knew of my decision?

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