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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 Contractor Code of Conduct

Note: This amended Code is not intended to create new and additional third party rights, including for employees.

1.0    Scope

This policy establishes the requirements of Rogers and its Affiliates for, and sets out Contractor’s obligations in relation to, labour, social, environmental and ethical compliance. Rogers Contractor 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 Contractor Code of Conduct.

2.0  Labour

Contractors 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, Contractor 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) Non-Discrimination

Contractor shall be committed to a workforce free of harassment and unlawful discrimination. Contractor 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.


(vii)  Freedom of Association

Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Contractor 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.


3.0    Health and Safety

Contractor recognises that the quality of products and services, consistency of production, and workers’ morale, are enhanced by a safe and healthy work environment. Contractor 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 d) 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 Contractor or a labour agent will be clean and safe, and will provide emergency egress, adequate heat and ventilation and reasonable personal space.

4.0    Environmental

Contractor 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

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

5.0    Management System

Contractor 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 the Contractor’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 Contractor’s commitment to compliance and continual improvement.


(ii)   Management Accountability and Responsibility

Clearly identified company 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.


(iv) Risk Assessment and Risk Management

Process to identify the environmental, health and safety and labour practice risks associated with Contractor’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 Contractor’s performance against those objectives.


(vi) Training

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


(vii) Communication

Process for communicating clear and accurate information about Contractor’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.

6.0    Ethics

To meet social responsibilities and to achieve success in the marketplace, Contractor, its personnel and sub-contractors are to uphold the highest standards of ethics including:


(i)     Business Integrity

The highest standards of integrity are to be expected in all business interactions. 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.


(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 and competition are to be upheld. The means to safeguard Rogers’ information should be available.


(vi) Protection of Identity

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


(vii) Community Engagement

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


(viii)    Conflict Minerals

Contractor shall evaluate the origin or source of its materials to verify that they have not been mined from any conflict zone. Contractor 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, Contractor commits that it will work to develop and implement processes and control mechanisms to avoid conflict minerals in future.


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