Rogers’ Supplier Code of Conduct

1.0    Scope

This policy establishes the requirements of Rogers and its Affiliates (in this Schedule Rogers and its Affiliates are together called “Rogers”) for, and sets out Supplier’s obligations in relation to, labour, social, environmental and ethical compliance. Rogers’ Supplier Code of Conduct is designed to promote safe and fair working conditions and the responsible management of social, ethical and environmental issues within Rogers’ supply chain. Recognized standards such as the Universal Declaration of Human Rights (UDHR), Social Accountability International (SAI) and the Ethical Trading Initiative (ETI), as well as recognized management systems such as The Occupational Health and Safety Assessment Series 18001 (OHSAS 18001), International Organization for Standardization for Environmental Management (ISO 14001), the Eco Management and Audit System (EMAS) and International Labour Organization (ILO) Guidelines on Occupational Safety and Health were used as references in preparing Rogers’ Supplier Code of Conduct.

 

Rogers may Audit Supplier and its subcontractors in accordance with the provisions relating to Audit in this Agreement. Audits will be conducted by an Auditor, and may include the assistance of an industry representative, or relevant non-governmental organization.

 

Supplier, including its personnel and subcontractors, is obligated to report any instances of behaviour which contradict the requirements of this Schedule in confidence using the Rogers STAR Hotline at www.rogersstarhotline.com. Supplier shall promote the Rogers STAR Hotline from time to time to Supplier Representatives and subcontractors working on behalf of Supplier for Rogers.

   

2.0  Policy

The following is the policy of Rogers:

 

(i)    Supplier hereby agrees to Rogers’ Supplier Code of Conduct as a condition of conducting business with Rogers and entering into this Agreement and shall make all reasonable efforts to promote Rogers’ Supplier Code of Conduct to its Supplier Representatives and subcontractors.

 

(ii)    Failure to adhere to Rogers’ Supplier Code of Conduct may result in the termination of this Agreement and/or legal action.

3.0  Labour

Suppliers are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community.

 

The labour standards to be adhered to are as follows:

 

(i)     Freely Chosen Employment

Forced, bonded or indentured labour or involuntary prison labour is not to be used. All work will be voluntary, and workers should be free to leave upon reasonable notice. Workers shall not be required to hand over government-issued identification, passports or work permits as a condition of employment.

 

(ii)   Child Labour Avoidance

Child labour is not to be used in any stage of manufacturing or production. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programmes, which comply with all laws and regulations, is supported. Workers under the age of 18 should not perform hazardous work and may be restricted from night work with consideration given to educational needs.

 

(iii) Working Hours

Workweeks are not to exceed the maximum set by local law. In the event that there are no local laws regulating workweeks, Supplier will not require, except in emergency or unusual situations, workers to work more than six consecutive days without at least one rest day.

 

(iv) Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.

 

(v)   Humane Treatment

There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers, nor is there to be the threat of any such treatment.

 

(vi) Respect, Dignity, Diversity and Inclusivity in the Workplace

Supplier shall be committed to a workforce free of harassment and unlawful discrimination. Supplier shall not engage in discrimination based on race, colour, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring, or employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way. Rogers has the right to request that a Supplier Representative be removed from a Rogers project or facility if the conduct of the Supplier Representative requires, and Supplier will fulfil the request IMMEDIATELY after receiving written notification from Rogers.

 

In choosing and evaluating its Suppliers, Rogers will take into account Supplier’s commitment to, and history of, fostering fair and inclusive work environments, as well as the inclusion of minority, women, disabled veterans, and lesbian, gay, bisexual and transgender-owned businesses in the provision of products and services that Rogers buys. Upon Rogers’ request, Supplier will provide Rogers with information concerning its diversity and inclusion policies, programmes and initiatives, workforce, and subcontractors’ representation. Suppliers who do not meet Rogers’ diversity expectations, or that fail to comply with applicable laws regarding diversity, human rights, anti-harassment or non-discrimination, may become ineligible to do business with Rogers.

 

(vii)  Freedom of Association

Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Supplier will respect the rights of workers to associate freely, join or not join labour unions, seek representation, and join workers’ councils in accordance with local laws. Workers shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation or harassment.

 

4.0    Health and Safety

Supplier recognizes that the quality of products and services, consistency of production, and workers’ morale, are enhanced by a safe and healthy work environment. Supplier must also recognize that ongoing worker input and education are key to identifying and solving health and safety issues in the workplace.

 

The health and safety standards to be adhered to are as follows:

 

(i)         Occupational Safety

Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicle, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tag-out). Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate personal protective equipment. Workers shall not be disciplined for raising safety concerns.

 

(ii)       Emergency Preparedness

Emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.

 

(iii)     Occupational Injury and Illness

Procedures and systems are to be in place to manage, track and report occupational injury and illness, including provisions to: (a) encourage worker reporting; (b) classify and record injury and illness cases; (c) provide necessary medical treatment; (d) investigate cases and implement corrective actions to eliminate their causes; and (e) facilitate return of workers to work.

 

(iv)     Industrial Hygiene

Worker exposure to chemical, biological and physical agents will be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, workers are to be provided with appropriate personal protective equipment.

 

(v)       Physically Demanding Work

Worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing and highly repetitive or forceful assembly tasks will be identified, evaluated and controlled.

 

(vi)     Machine Safeguarding

Physical guards, interlocks and barriers will be provided and properly maintained for machinery used by workers.

 

(vii)     Dormitory and Canteen

Workers will be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities. Worker dormitories provided by Supplier or a labour agent will be clean and safe, and will provide emergency egress, adequate heat and ventilation and reasonable personal space.

 

(viii)    Alcohol and Drugs

Supplier and Supplier Representatives shall not possess, consume and/or traffic in alcoholic beverages, illegal drugs or restricted substances while performing Services for Rogers.

5.0    Environmental

Supplier recognizes that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources will be minimized while safeguarding the health and safety of the public.

 

The environmental standards are as follows:

 

(i)         Environmental Permits and Reporting

All required environmental permits (e.g. discharge monitoring) and registrations will be obtained, maintained and kept current and their operational and reporting requirements will be followed.

 

(ii)       Pollution Prevention and Resource Reduction

Waste of all types, including water and energy, will be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.

 

(iii)     Hazardous Substances

Chemical and other materials posing a hazard if released to the environment will be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal and in accordance with local, provincial and/or federal regulations for such management.

 

(iv)     Wastewater and Solid Waste

Wastewater and solid waste generated from operations, industrial processes and sanitation facilities will be monitored, controlled and treated as required prior to discharge or disposal. Appropriate reporting to the Governmental Authorities will be completed as required.

 

(v)       Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations will be characterized, monitored, controlled and treated as required prior to discharge and in accordance with local, provincial and/or federal regulations for such management.

 

(vi)     Product Content Restrictions

Supplier will adhere to all applicable laws and regulations regarding prohibition or restriction of specific substances including labelling laws and regulations for recycling and disposal. Supplier will also adhere to processes to comply with each agreed-upon Rogers-specific restricted and hazardous materials list. Supplier will have proper registrations to dispose of any materials.

6.0    Protection of Data

Supplier and its subcontractors must operate in accordance with the Personal Information and Electronics Documents Act (Canada) and Canada’s Anti-Spam Legislation. Supplier and its subcontractors shall employ the following principles to ensure secure and responsible collection, use and disclosure of Rogers’ Data:

 

 

(i)         Partnership

Supplier will work with subcontractors who share Rogers’ vision for responsible data use, to collaborate on data initiatives that provide value to Rogers’ customers, employees and Rogers’ business.

 

(ii)       Transparency

Supplier will be transparent with Rogers and Rogers’ customers and employees about how their data is managed.

 

(iii)     Control

In accordance with applicable law, Rogers’ customers will be given control and choice over how their Personal Information is used.

 

(iv)     Consideration

Supplier will be respectful in the management of Rogers’ customer and Rogers’ employee data, and guard against bias, discrimination and unjust impacts. The more sensitive the data, the greater scrutiny Supplier will provide around the management of that data.

 

(v)       Security and Protection

Supplier will prioritize the protection of Rogers’ customer and Rogers’ employee data.

 

(vi)     Innovation

Supplier will continually leverage developing technologies and practices to manage and use data in new and thoughtful ways that improve Rogers’ business and to better serve Rogers’ customers and Rogers’ employees.

7.0    Management System

Supplier shall adopt or establish a management system the scope of which is related to the content of this Schedule. The management system shall be designed to ensure (a) compliance with applicable laws, regulations and Rogers’ requirements related to Supplier’s operations and products; (b) conformance with this Schedule; and (c) identification and mitigation of operational risks related to this Schedule.

 

The management system should contain the following elements:

 

(i)         Corporate Commitment

Corporate social and environmental responsibility statements affirming Supplier’s commitment to compliance, continual improvement, and the avoidance of damage to any protected biodiversity environments.

 

(ii)       Management Accountability and Responsibility

Clearly identified Supplier representative[s] responsible for ensuring implementation and periodic review of the status of the management systems.

 

(iii)     Legal and Rogers’ Requirements

Identification, monitoring and understanding of applicable laws, regulations and Rogers’ requirements and compliance with laws applicable to Rogers and Supplier.

 

(iv)     Risk Assessment and Risk Management

Process to identify the environmental, health and safety and labour practice risks associated with Supplier’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks.

 

(v)       Performance Objectives with Implementation Plan and Measures

Written standards, performance objectives, targets and implementation plans including a periodic assessment of Supplier’s performance against those objectives.

 

(vi)     Training

Programmes for training managers and workers to implement Supplier’s policies, procedures and improvement objectives.

 

(vii)    Communication

Process for communicating clear and accurate information about Supplier’s performance, practices and expectations to workers, suppliers and customers. Areas to be included in a risk assessment for health and safety are warehouse and storage facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker housing /dormitories.

 

(viii)     Worker Feedback and Participation

Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Schedule and to foster continuous improvement.

 

(ix)     Audits and Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Schedule, and Rogers’ contractual requirements related to social and environmental responsibility.

 

(x)       Corrective Action Process

Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews all in keeping with all local, provincial and/or federal regulations or guidelines.

 

(xi)     Documentation and Records

Creation of documents and records to ensure regulatory compliance and conformity to Rogers’ requirements along with appropriate confidentiality to protect privacy.

 

(xii)     Supplier Diversity Reports

Supplier will provide Rogers with reports listing Supplier subcontractors who provide goods and/or services to Rogers on behalf of Supplier. The first report will be due on January 15 covering the previous calendar year. The second report is due July 15, covering the previous calendar year plus the first six months of the current year. Thereafter, reports will be provided annually on July 15 covering the previous 12-month period, ending on June 30 of the calendar year (i.e. July 1 to June 30). If Supplier is aware that any Supplier subcontractors are certified diverse suppliers, Supplier shall use best efforts to identify these particular Supplier subcontractors in each of the reports provided to Rogers by identifying them as certified diverse, identifying the certifying organization, if known, such as but not limited to Canadian Aboriginal and Minority Supplier Council (CAMSC), Canadian Council for Aboriginal Business (CCAB), Canadian Gay and Lesbian Chamber of Commerce (CGLCC) and Women Business Enterprise (WBE) and or their affiliates and listing the country in which Supplier subcontractors are certified as diverse.

8.0    Ethics

To meet social responsibilities and to achieve success in the marketplace, Supplier, Supplier Representatives, and Supplier’s subcontractors will uphold the highest standards of ethics including:

 

(i)         Business Integrity

The highest standards of integrity are to be expected in all business interactions, including with employees, customers, suppliers and the communities in which we operate. Any and all forms of corruption, extortion and embezzlement are strictly prohibited and may result in immediate termination and legal action.

 

(ii)       No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.

 

(iii)     Disclosure of Information

Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices, including restrictions on the communication of material non-public information and on the purchase and sale of securities under securities laws.

 

(iv)     Intellectual Property

Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.

 

(v)      Fair Business, Advertising and Competition

Standards of fair business, advertising, sales and competition practices are to be upheld through compliance with all applicable laws relating to competition standards, advertising and sales practices. The means to safeguard Rogers’ information must be available.

 

(vi)    Fair Dealing

Supplier is required to act honestly, in good faith, and with professionalism. Supplier shall not take unfair advantage of a customer through unethical behaviour such as harassment, manipulation, abuse of privileged information, misrepresentation of material facts, or any other unfair practice.

 

(vii)    Protection of Identity

Programmes that ensure the protection of Supplier and employee whistleblower confidentiality will be maintained.

 

(viii)    Community Engagement

Community engagement is encouraged to help foster social and economic development.

 

(ix)    Conflict Minerals

Supplier shall evaluate the origin or source of its materials to verify that they have not been mined from any conflict zone. Supplier shall disclose whether any of its products contain minerals that have been mined in conditions of armed conflict and human rights abuses or that are from any conflict zones. Where conflict minerals are found in a product or during manufacturing, Supplier commits that it will work to develop and implement processes and control mechanisms to avoid conflict minerals in future.

9.0    Conflict of Interest

A “conflict of interest” occurs when Supplier’s interests interfere, or may appear to interfere, with the interests of Rogers. A conflict of interest can arise when Supplier or a Supplier Representative takes actions or has interests that may make it difficult for Supplier to perform the Services objectively and effectively. Supplier and Supplier Representatives must: (i) avoid activities or situations that involve real or perceived conflicts of interest which would interfere with the interests of Rogers, and (ii) disclose potential conflicts of interest or any relationships that could reasonably be expected to give rise to a conflict of interest.

 

Any entertainment, hospitality, gift or favour made or received by Supplier or a Supplier Representative while performing the Services to procure an action or decision, or to recognize or reward an action or decision, is a conflict of interest and is prohibited. Supplier and Supplier Representatives transacting business for Rogers should act and should be perceived by others to act, in Rogers’ best interest and free of any conflicts of interest. The total value of (a) favours and gifts received by a Rogers employee from Supplier shall not exceed $100 annually; and (b) entertainment and/or hospitality received by a Rogers employee from Supplier shall not exceed $500 quarterly, all provided that the following criteria are met:

 

(i)    they are in the course of a normal business relationship and are consistent with accepted business practice, except during a Request for Proposal event such as a competitive bid and/or during contract negotiation;

(ii)    they are not in cash, cash equivalents or securities;

(iii)    they are of sufficiently limited value so as not to be capable of being perceived or construed as an inducement, bribe, pay-off or other improper payment or endorsement;

(iv)    they are not repetitive or frequent; and

(v)    they do not contravene any law and are made in accordance with generally accepted ethical standards and behaviour.

 

10.0    Supplier Representatives

Rogers reserves the right to interview and approve or reject any or all prospective new Supplier Representatives on Rogers’ projects prior to their being hired or engaged by Supplier. Supplier must (i) perform background checks, and (ii) verify all credentials and at least two references, for each prospective Supplier Representative prior to hiring or engagement. Supplier will maintain all interview notes of each Supplier Representative. Rogers reserves the right to audit and receive confirmation of all documentation regarding all of the above requirements for prospective or hired Supplier Representatives who may provide Services to or on behalf of Rogers. Rogers reserves the right to require Supplier to remove specified personnel from any Rogers’ project(s) or facility at no additional cost to Rogers.

 

Supplier and Supplier Representatives will adhere to applicable Rogers policies and processes including but not limited to: security and access control at Rogers’ facilities; performing Services in the field on behalf of Rogers and when working with a Rogers customer; health and safety procedures including pre-screening assessments regarding travel history and exposure to health risks; business travel and expense reimbursement practices.