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.
Insider trading generally refers to the buying or selling of 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.