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Rogers Communications Inc. Business Conduct Policy

Rogers Communications Inc. has a Business Conduct Policy to which all employees adhere. As a Rogers supplier, your company and its employees are expected to adhere to the Rogers Supplier Business Conduct Statement.
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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. Recognised standards such as the Universal Declaration of Human Rights (UDHR), Social Accountability International (SAI) and the Ethical Trading Initiative (ETI), as well as recognised management systems such as The Occupational Health and Safety Assessment Series 18001 (OHSAS 18001), International Organisation for Standardisation (ISO 14001), the Eco Management and Audit System (EMAS) and International Labour Organisation (ILO) Guidelines on Occupational Safety and Health were used as references in preparing the Rogers Supplier Code of Conduct.


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


Supplier, including its personnel and sub-contractors, is obligated to report any instances of behaviour which contradict the requirements of this Schedule in confidence using the Rogers STAR Hotline details as found below (which may be amended at Rogers’ discretion). Supplier shall promote these Rogers STAR Hotline details from time to time and have them readily available within Supplier’s organisation and to any sub-contractors working on behalf of Supplier for Rogers.


Call toll-free at 1 877 355 STAR (7827)





User name rogers4u

Password rogers1


2.0  Policy

The following is the policy of Rogers:


(i)    Supplier hereby agrees to the Rogers Supplier Code of Conduct as a condition of conducting business with Rogers and entering into the Agreement and shall make all reasonable efforts to promote the Rogers Supplier Code of Conduct to its personnel and sub-contractors.


(ii)    Failure to adhere to the Rogers Supplier Code of Conduct may result in the termination of the 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 the 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 sub-contractors’ 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 recognises 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 recognise 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 minimised 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 the 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 recognises that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources will be minimised 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.


(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.


(v)       Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations will be characterised, monitored, controlled and treated as required prior to discharge.


(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.

6.0    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. It should also facilitate continual improvement.


The management system should contain the following elements:


(i)         Corporate Commitment

Corporate social and environmental responsibility statements affirming Supplier’s commitment to compliance and continual improvement.


(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.


(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 sub-contractors who provide goods and/or services to Rogers on behalf of Supplier and who are certified by the Canadian Aboriginal and Minority Supplier Council (CAMSC), Women Business Enterprise (WBE) and Canadian Gay and Lesbian Chamber of Commerce (CGLCC) or their affiliates. 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).

7.0    Ethics

To meet social responsibilities and to achieve success in the marketplace, Supplier, Supplier Representatives, and Supplier’s sub-contractors 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.

8.0    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 the 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 recognise or reward an action or decision, is a conflict of interest and is prohibited. Supplier and the 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. Modest favours, gifts, entertainment or hospitality may be furnished or accepted by Supplier and the Supplier Representatives in connection with providing the Services 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;

(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.



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