Preventing Bribery and Corruption

Rogers Corporation, its employees, and others who act on its behalf must not offer, pay, or accept bribes. We must not offer or give money or anything else of value if this would constitute either an improper inducement to make, or a reward for making, any decision favorable to the interests of Rogers. This includes providing improper benefits of any kind to government officials, suppliers, or customers. It also includes providing benefits to charities, companies, or individuals if these benefits would provide an improper advantage, inducement, or reward.

We do not permit any third party working on our behalf to engage in this type of conduct. We comply with all applicable international laws, treaties, and regulations that forbid bribery, including the local laws where we conduct business, such as U.K. Bribery Act and the U.S. Foreign Corrupt Practices Act (“FCPA”).

What is bribery?

Offering or making payments to secure or retain business, or to obtain an improper advantage, is a crime in many of the countries in which we do business, whether such payments are in cash or in kind.

What is expected of you?

• Never make, authorize, or accept bribes to obtain, retain, or influence business or to secure any other improper advantage, or permit third parties, such as distributors, contractors, sales representatives, or agents, to do so.
• Promptly report to a supervisor, the Director of Global Compliance & Integrity, or a member of the Legal & Compliance Department any behavior of this type, including that of Rogers’ employees, contractors, advisors, or other third parties.
• Do not make a gift or engage in conduct that would embarrass the Company if publicly disclosed.
• Do not provide any form of “facilitation payment” to any public official without the express written authorization of the company’s General Counsel. A facilitation payment, also known as a “grease payment”, is a payment made to a government official with the intention of expediting an administrative process.
• Consult the Legal & Compliance Department if in doubt.