Code of Business Ethics Results, but results in the right way Eredmények, de a megfelelő módon Resultaten, maar op juiste wijze verkregen 有结果，但以正确的方式获得 Ergebnisse, aber in der korrekten Art und Weise 성과, 바른 방법을 통하여

®

®

ROGERS CORPORATION

At Rogers, we are passionate about helping the world’s leading innovators solve their toughest material challenges to help power, protect and connect our world. We are proud to empower breakthroughs in reliability, efficiency and performance by providing advanced materials technologies, application knowledge, global manufacturing and design collaboration to customers around the world. We believe that how we conduct our business is just as important as what we achieve. We strive for “Results, but Results in the Right Way.” That means making choices that are based on what is ethically sound and not just what is easy or expedient. Our Code of Business Ethics describes how our Cultural Behaviors are to be translated into concrete actions. It explains what is expected of each of us as we work to achieve our business goals. It is the cornerstone of our ethical culture that we reaffirm daily in our business activities. Compliance with this Code and all supporting policies is mandatory. Together, they provide the framework for the application of consistent standards of responsible behavior that will ensure that our company is valued and respected now and in the future. Bruce Hoechner President & CEO

CODE OF BUSINESS ETHICS

Contents Our Cultural Behaviors Our Fundamental Principles

3-5

Asking Questions and Raising Concerns

6-7



1. Promoting Product Quality and Safety

8



2. Conducting Research and Development

9



3. Protecting Intellectual Property

10



4. Marketing Our Products

11



5. Promoting Equal Opportunity and Appropriate Workplace Behavior 12



6. Preventing Bribery and Corruption

13



7. Recognizing and Avoiding Conflicts of Interest

14



8. Gift Giving and Receiving

15



9. Managing Insider and Confidential Information

16



10. Complying with Competition and Antitrust Laws

17



11. Promoting Safety and Health

18



12. Protecting the Environment

19



13. Protecting Company Property and Resources

20



14. Maintaining Records and Making Disclosures

21



15. Financial Reporting

22



16. Working with Suppliers and Other Third Parties

23



17. Protecting Personal Information

24



18. Complying with Trade Controls

25



19. Respecting Human Rights

26

Questions to Consider in Your Everyday Business Activities 1

2

ROGERS CORPORATION

27

Our Cultural Behaviors

Live Safely

Trust

I actively prevent injuries for everyone, everywhere, every day.

I respect people and trust them to do the right thing.

Just Decide

Speak Openly

I make informed decisions rapidly to drive progress.

Simply Improve

I continuously simplify how I do things to achieve excellence.

I courageously seek and speak the truth.

Innovate

I create market-driven solutions that lead to customer success.

Deliver Results

I align and achieve my goals to deliver our “Must-Do” results.

CODE OF BUSINESS ETHICS

2

Our 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. 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.