The following fundamental principles and our Cultural Behaviors 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. Therefore, it is critical that you actively seek support and guidance from your supervisor, Human Resources representative, the Director of Global Compliance & Integrity or the Legal & Compliance Department.
A strong reputation is essential for our business success and for building lasting relationships. It fosters goodwill, which is vital during challenging times. Our reputation is built on the trust of employees, customers, stakeholders, and the communities we serve. This trust is one of our most valuable assets.
As a global company, our actions impact a wide range of people—customers, suppliers, regulators, shareholders, employees, and communities. All interactions must adhere to legal requirements and our high ethical standards. Given the visibility of modern communication, our actions are instantly global and we must uphold the highest standards to maintain trust and respect in the business community.
This Code and its supporting policies apply to all Rogers Corporation (“Rogers” or the “Company”) directors, officers, and employees. Consultants, representatives, agents, subcontractors, and suppliers are also expected to adhere to standards of conduct consistent with this Code in performing services for, and providing products to, the Company. All Company directors, officers, and employees are required to be familiar with the Code, comply with its provisions, and report any actual or suspected violations.
You must always act with honesty and integrity and refrain from behaving, or assisting others in behaving, dishonestly or fraudulently. Each director, officer, and employee also has a “duty of fair dealing” and must treat the Company’s customers, suppliers, competitors, and employees fairly and should not take unfair advantage of anyone by manipulation, misrepresentation, or abuse of information.
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.
The Code has been adopted by Rogers’ Board of Directors and applies worldwide. “Rogers,” “Rogers Corporation” or “Company” as used throughout this Code, includes Rogers’ controlled entities globally. This Code applies to all directors, officers, employees, and representatives, including consultants and agents, as well as suppliers to the Company.
The Director of Global 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 Global Compliance & Integrity and General Counsel. Any waivers for directors and executive officers must be approved by both by Rogers’ Director of Global Compliance & Integrity and the Board of Directors or a Board committee and will be disclosed promptly as required by law, regulation, and or Rogers’ policy.
All employees have an obligation to raise any questions or concerns they 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. Anyone who raises a concern in good faith about a possible breach of this Code, violation of policy, or any other compliance concern, will not be subject to retaliation. Any act or threat of retaliation is considered a serious violation of this Code.
Our managers and 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. The standards of conduct contained in this section represent our minimum expectations for ethical business behavior. 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.
Any failure to comply with this Code or its supporting policies will be fully investigated and appropriate action will be taken such as retraining, reassignment, demotion, discipline, notification to government authorities, or other corrective action, including termination of employment, depending on the circumstances.
