Rogers Communications Inc. has a Code of Business Conduct (or Code of Conduct) to which all employees adhere.

As a supplier, your company and all employees interacting with Rogers are expected to adhere to the Rogers Supplier Code of Conduct. 

Should you have any questions about the Code of Business Conduct, your Rogers business contact can call the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com. 

Introduction to the Rogers Codes of Business Conduct

Dear suppliers and employees:

The Rogers Group of Companies is committed to maintaining its long-standing reputation for the highest standards of integrity, ethical behaviour and good corporate citizenship. It is a reputation each of you has helped to build and for which we can all be very proud.

Safeguarding our reputation requires steadfast compliance with the highest standards of business conduct and all applicable laws and regulations, in everything we do. The Electronics Industry Code of Conduct is well documented and forms the basis for the Rogers Supplier Code of Conduct. You should consult the Rogers Supplier Code of Conduct whenever you need direction on issues of business conduct or ethical behaviour. The equally rigorous employee Code of Business Conduct is included on this page.

This policy, however, is not intended to substitute for your responsibility to exercise good judgment. Nor is it designed to address every situation, or serve as the sole guideline on matters of business conduct. Your Rogers Contact should also be consulted, as appropriate.

Thank you for your commitment to maintaining the highest standards of integrity and ethical behaviour at Rogers. It is both appreciated and expected of all Rogers suppliers.

Rogers Supplier Code of Conduct

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

A. LABOR

Participants are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. Recognized standards such as the Universal Declaration of Human Rights (UDHR), Social Accountability International (SAI) and the Ethical Trading Initiative (ETI) were used as references in preparing the Code and may be a useful source of additional information.

The labor standards are:

 

1) Freely Chosen Employment

Forced, bonded or indentured labor or involuntary prison labor 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.

 

2) Child Labor Avoidance

Child labor is not to be used in any stage of manufacturing. 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 programs, 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.

 

3) Working Hours

Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60

hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-day week.

 

4) 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.

 

5) 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.

 

6) Non-Discrimination

Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and 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.

 

7) Freedom of Association

Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Participants are to respect the rights of workers to associate freely, join or not join labor unions, seek representation, 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.

B. HEALTH and SAFETY

Participants recognize that the quality of products and services, consistency of production, and workers’ morale, are enhanced by a safe and healthy work environment. Participants also recognize that ongoing worker input and education is key to identifying and solving health and safety issues in the workplace. Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and

may be a useful source of additional information.

The health and safety standards are:

 

1) 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/tagout). 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.

 

2) 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.

 

3) 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.

 

4) Industrial Hygiene

Worker exposure to chemical, biological and physical agents is to 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.

 

5) 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 is to be identified, evaluated and controlled.

 

6) Machine Safeguarding

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

 

7) Dormitory and Canteen

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

C. ENVIRONMENTAL

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

Recognized management systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful source of additional information.

The environmental standards are:

1) Environmental Permits and Reporting

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

 

2) Pollution Prevention and Resource Reduction

Waste of all types, including water and energy, are to 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.

 

3) Hazardous Substances

Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal.

 

4) Wastewater and Solid Waste

Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be monitored, controlled and treated as required prior to discharge or disposal.

 

5) Air Emissions

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

 

6) Product Content Restrictions

Participants are to adhere to all applicable laws and regulations regarding prohibition or restriction of specific substances including labeling laws and regulations for recycling and disposal. Participants are also to adhere to processes to comply with each agreed-upon customer-specific restricted and hazardous materials list.

D. MANAGEMENT SYSTEM

Participants shall adopt or establish a management system whose scope is related to the content of this Code. The management system shall be designed to ensure (a) compliance with applicable laws, regulations and customer requirements related to the Participant’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.

The management system should contain the following elements:

1) Company Commitment

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

 

2) Management Accountability and Responsibility

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

 

3) Legal and Customer Requirements

Identification, monitoring and understanding of applicable laws, regulations and customer requirements.

 

4) Risk Assessment and Risk Management

Process to identify the environmental, health and safety and labor practice risks associated with Participant's operations.  Detmination of the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the indentified risks.

 

5) Performance Objectives with Implementation Plan and Measures

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

 

6) Training

Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives.

 

7) Communication

Process for communicating clear and accurate information about Participant’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.

 

8) Worker Feedback and Participation

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

 

9) Audits and Assessments

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

 

10) Corrective Action Process

Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

 

11) Documentation and Records

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

E. ETHICS

To meet social responsibilities and to achieve success in the marketplace, Participants and their agents are to uphold the highest standards of ethics including:

1) 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 resulting in immediate termination and legal actions.

 

2) No Improper Advantage

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

 

3) 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.

 

4) Intellectual Property

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

 

5) Fair Business, Advertising and Competition

Standards of fair business, advertising and competition are to be upheld. Means to safeguard customer information should be available.

 

6) Protection of Identity

Programs that ensure the protection of supplier and employee whistleblower confidentiality are to be maintained.

 

7) Community Engagement

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

REFERENCES

The following standards were used in preparing this Code and may be a useful source of additional information. The following standards may or may not be endorsed by each Participant.

ILO Code of Practice in Safety and Health  www.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf

National Fire Protection Agency  www.nfpa.org/catalog/home/AboutNFPA/index.asp

ILO International Labor Standards  www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm

OECD Guidelines for Multinational Enterprises  www.oecd.org

United Nations Convention Against Corruption  www.unodc.org/unodc/en/crime_convention_corruption.html

United Nations Global Compact  www.unglobalcompact.org

Universal Declaration of Human Rights  www.un.org/Overview/rights.html

ISO 14001  www.iso.org

SA 8000  www.cepaa.org/

SAI  www.sa-intl.org

Ethical Trading Initiative  www.ethicaltrade.org/

OHSAS 18001  www.bsi-global.com/index.xalter

Eco Management & Audit System  www.quality.co.uk/emas.htm

Comment

The Rogers Supplier Code of Conduct follows the Electronic Industry Code of Conduct was initially developed by a number of companies engaged in the manufacture of electronics products between June and October 2004. This is Version 2.0, October 2005. Participating companies included Celestica, Dell, Flextronics, HP, IBM, Jabil, Sanmina SCI, and Solectron. Companies adopting/endorsing the code and/or joining the Implementation Group include: Celestica, Cisco, Dell, Flextronics, Foxconn, HP, IBM, Intel, Jabil, Lucent, Microsoft, Sanmina SCI, Seagate, Solectron, and Sony. Other companies are invited and encouraged to adopt this code. You may obtain additional information from www.eicc.info

Rogers Employee Code of Business Conduct

1. Contract and Commitment Guidelines

Employees must ensure that all contracts and commitments have proper authorizations and documentation prior to making commitments on behalf of the Company.

2. Adherence to the Law

Employees are personally responsible to comply with all laws and regulations applicable to the Company. Employees who are in doubt as to the legality of a proposed course of action or an action already taken should discuss the activity with their manager/supervisor. The manager/supervisor should consult with the Vice President/Director, Human Resources who, in turn, shall consult the Rogers Legal department (or approved external counsel), as required.

Employees should not conduct business with suppliers and/or contractors who subscribe to unlawful or unethical business practices or behaviour. Promptly report unethical selling or purchasing practices on the part of a supplier or a Rogers employee to the employee's Manager and to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com.

3. Respect and Dignity in the Workplace

The Company is committed to ensuring that all employees, vendors, business associates, volunteers, customers and the general public are treated with respect and dignity. The Company will not tolerate harassment and/or discriminatory acts or practices, by any of its employees. Please refer to policy HR 2.5 - Workplace Harassment.

4. Fair Dealings

The Company does not seek competitive advantages through illegal or unethical business practices or behaviour. Each employee should endeavour to deal fairly and ethically with the Company's customers, service providers, suppliers, competitors and employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any unfair or unethical dealing practice.

Rules of competitive business conduct are established in the Competition Act and certain sections of the Telecommunications Act and the Broadcasting Act. All applicable practices must be carried out in compliance with these Acts. (Please see policy LEG 18 - Competition Act).

Employees must never disclose, communicate or discuss confidential information concerning the Company, including in particular pricing or purchasing policies with competitors. Information about competitors should be gathered in a lawful manner. Employees who previously worked for a competitor will not be requested to provide confidential information about said competitor.

5. Protection and Proper Use of Company Assets

All employees are responsible for safeguarding, and making proper and efficient use of Company funds and property by following procedures to prevent their loss, theft and unauthorized use. Company funds and property include Company time, cash, cheques, charge cards, land and buildings, proprietary information and records, vehicles, equipment, intellectual property, information systems and all other property.

Ways to protect Company funds and property include ensuring:

1. expenditures are for legitimate business purposes;
2. computer equipment and systems, and the information that they contain are protected against unauthorized access, use, modification, destruction, theft or loss;
3. use of telephones, email and the internet are only for legitimate business purposes;
4. upon termination of employment, employees must return all Company records and equipment.

Employees must not borrow or make use of the Company's name, property, goodwill, funds, data or other assets for their personal gain or benefit, or for the gain or benefit of others which is not authorized to be done on behalf of the Company. The Company does not permit notices, messages or postings on behalf of any third parties or outside organizations without written permission from the Human Resources Department.

The unauthorized connection and/or use of Company products and services are criminal acts. Any employee or contractor found to be connected to, or in possession of, unauthorized Company products and/or services, or to have assisted another to do so, will be subject to legal action.

In the course of protecting Company assets, it is our duty to promptly report to Corporate Security or to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com all acts that may constitute real or suspected breaches of security.

6. Employment Practices

The Company is committed to ensuring that equal opportunity exists for all employees in all aspects of employment, and the Company will continue to use the merit principle as the basis for all employment and promotion opportunities. (Please see policy HR 2.1 - Diversity Management).

7. Health and Safety

All employees are responsible for performing their duties in a safe manner and for keeping themselves updated on all Company health and safety policies, procedures and directives. (Please see policy GEN 25 - Health and Safety and the Health & Safety Standards on the Burbs).

8. Alcohol and Drugs

The possession, consumption and/or the sale of illegal drugs and restricted substances is prohibited while on duty and/or while occupying any of the Company's premises, including company vehicles.

Except under special circumstances, such as Company sanctioned and sponsored events where prior approval has been obtained from the President of the business unit, or from the individual to whom the President has delegated this responsibility, the provision or consumption of alcohol is prohibited on the Company's premises and in Company vehicles. Approval may be granted taking into consideration the Company's reputation, image, responsibility and potential liability. It is each employee's responsibility to ensure that he or she behaves responsibly during attendance at a Company or vendor-sponsored event.

Drug or alcohol impairment while on duty or on the Company's premises or in Company vehicles is improper business conduct and will be treated as an extremely serious matter.

9. Environment

The Company is committed to being an environmentally responsible corporate citizen. The Company will obey all environmental laws applicable in the jurisdictions in which it operates and each employee is expected to behave accordingly. Any contravention of environmental laws or the Company's environmental policy must be immediately reported to the senior executive of the respective operating company or business unit. An oral report must be promptly followed up with a written report. (Please see policy GEN 30 - Environmental Audit and Conservation)

10. Computer Access and Use of Electronic Media

In order to protect access to systems, applications and data on the Company's computer systems, employees must ensure the protection of their own passwords. Users must not give out their passwords or allow others to use their user ids. (Please see policy CS 1 - Computer Access).

Users of the Company's computer systems and/or the Internet should be aware that their communications are not protected from third party viewing unless approved encryption is used. Employees should not send information over the Internet if they consider it to be private.

The Company reserves the right at any time to examine e-mail, computer records, personal file directories and other information stored on or transmitted over Company facilities to ensure compliance with internal policies, to support the performance of internal or external investigations, and to assist with the management of information systems. Employees should be aware that all e-mail is considered Company property and it is archived and can be retrieved for examination at any time, even after it has been deleted.

Language and conduct during conversations, instant messaging and email exchanges does reflect on the Company. As such, a professional manner must be maintained at all times.

Use of Company facilities to download, communicate or exchange materials that conflict with the Company's policies is prohibited. Personal use of Company facilities is allowed under certain conditions as outlined in policy CS 3 - Use of Electronic Media. Compliance with policy CS 3 is mandatory. Failure to comply may result in disciplinary action being taken, up to and including termination.

(Please see policy CS 3 - Use of Electronic Media for a complete list of unacceptable practices and employee guidelines).

11. Work Performance

The Company expects all employees to be held accountable for the results of their work, based on the factors of honesty, quality, timeliness, efficiency, safety and continuous improvement. Managers are expected to provide leadership that reinforces these factors, and that ensures that the actions of all employees are in the Company's best interests. Employees are to abide by regular working hours per the applicable operating and/or departmental procedures. (Please see policy HR 1.3 - Hours of Work for details).

12. Full Commitment to the Company

Employees must remain free of any outside business interests or relationships that could interfere with the performance of their job duties (including their availability to work overtime, as required).

Advance approval must be obtained from the Nominating and Corporate Governance Committee of the RCI Board regarding the acceptance of any positions as a member of a board, advisory council or other similar committee of a profit organization, or major non-profit or charitable organization, unless the employee is required in their capacity at Rogers to act as a representative on that board for the Company.

Any employee considering serving on a board of directors or an advisory board or similar body of any outside company or major non-profit or charitable organization must obtain approval from their supervisor. Then the employee must get advance approval by sending a request to the General Counsel of Rogers.

Any employee serving on any board or similar body as a Rogers' representative will not receive compensation of any kind, directly or indirectly, for such services. Any employee serving on any board or similar body in a personal capacity will not be reimbursed by Rogers, directly or indirectly, for any expenses related to such activity.

13. Conflict of Interest

A "conflict of interest" occurs when an individual's private or personal interests interfere, or may appear to interfere, with the interests of the Company. A conflict of interest can arise when an employee takes actions or has interests that may make it difficult to perform his or her Company work objectively and effectively.

Employees must avoid activities or situations that involve real or perceived conflicts of interest with the Company. Employees must disclose potential conflicts of interest or any relationships that could reasonably be expected to give rise to a conflict of interest either to their Manager or to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com.

Conflicts of interest include but are not limited to the following:

Personal Financial Interest 

1. The transaction of business by the Company with an enterprise where an employee and/or any member of an employee's family together have an ownership interest in the enterprise and/or its affiliates that is material to the employee and/or the employee's family or that is more than a 5% interest in the enterprise and/or its affiliates;
2. An employee having financial interest in, performing services for, or undertaking any activity (whether commercial or non-commercial and/or for which there is no personal financial interest) for a competitor of the Company.

Entertainment, Hospitality, Gifts, Favours or Bribes 

Accepting or providing entertainment, hospitality, gifts or favours that may reasonably be considered to have an influence on a decision by an individual on behalf of the Company, or that may be outside of the normal course of a business relationship, constitutes a conflict of interest. Any entertainment, hospitality, gift or favour made or received by a Company employee to procure an action or decision, or to recognize or reward an action or decision, is prohibited. All employees transacting business for the Company should act and should be perceived by others to act, in the Company's best interest and free of any conflicts of interest. Modest favours, gifts, entertainment or hospitality may be furnished or accepted by employees in connection with their duties provided that the following criteria are met:

1. they are in the course of a normal business relationship and are consistent with accepted business practice;
2. they are not in cash or securities; 
3. 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;
4. they are not repetitive or frequent;
5. they do not contravene any law and are made in accordance with generally accepted ethical standards and behaviour, and;
6. the employee informs his/her manager or supervisor.

In cases where an employee travels to the out-of-town office of a supplier or potential supplier, the employee must pay his or her own travel, hospitality and accommodation expenses for reimbursement by the Company, in accordance with policy GEN 9 - Travel Expenses. Payment of such expenses other than reimbursements by the Company is allowed only if approved in writing by the employee's manager or supervisor and if the reimbursement cannot be perceived as a personal gain, or intended to influence the employee's decision or recommendation of the supplier.

If an employee proposes to undertake personal transactions with a supplier to the Company it must be on the same terms that would be offered to other arm's length customers of the supplier, in order to avoid conflict of interest, and must be approved by the employee's manager or supervisor.

Employment of Relatives: 

Relatives of an employee are defined as follows: parents, spouse (including common-law spouse and same-sex partner), grandparents, brothers, sisters, children, nephews, nieces, aunts, uncles and cousins (including adopted, foster, step and in-law relations).

Relatives of employees may only be hired through standard recruiting procedures and must meet the qualifications required for the position. Where an employee would directly or indirectly supervise, or be in a position to influence the career or contracted activities and rewards of a relative, such a conflict of interest must be brought to the attention of the Human Resources department immediately, and an appropriate course of action determined, including senior management approvals and by the RCI Board Compensation Committee where required under its policies.

14. Illegal Payment to Public Officials

It is illegal and not permitted for public officials, at any level of government, to obtain money, property, entertainment, hospitality, gifts or favours from the Company by the wrongful use of their official position or as a condition to perform certain duties they are normally obligated to perform. If it comes to the attention of an employee that such payments were sought or made, this should be immediately reported to employee's supervisor and to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com.

15. Proper Maintenance of Records

All transactions of the Company must be properly recorded and accounted for in the books of the Company. This is essential to the integrity of the Company's governance and financial reporting obligations. All Rogers employees are responsible for ensuring that false, inaccurate, or misleading entries are not made in our Company's accounting records, and full, fair, accurate, timely and understandable disclosure is made in all public communications.

In preparing and maintaining Rogers' books and records, employees should:

1. adhere to all applicable accepted accounting standards and practices, rules, regulations and controls;
2. ensure the accurate and timely recording of costs, sales, shipments, time sheets, vouchers, bills, payroll and benefit records, regulatory data, expense reports and other financial transactions in the proper accounts;
3. record all funds, assets and transactions and not establish any undisclosed or unrecorded fund or assets for any purpose;
4. keep and retain books and records which reflect fairly, accurately and in appropriate detail the Company's transactions, acquisition and disposal of assets and other relevant activities (see Company policy SEC 4 - Retention of Records);
5. sign only those documents that are accurate and truthful;
6. restrict access to sensitive or confidential information (such as financial records and customer information) to ensure the information is not accidentally or intentionally disclosed, modified, misused or destroyed, other than in accordance with the Company's document retention policies.

16. Political and Charitable Contributions

All employees are encouraged and entitled to make political and charitable contributions from their personal time and funds in the exercise of responsible citizenship. Contributions of any kind to political organizations, made on behalf of the Company, must be approved, in advance, by the Vice President of Communications, RCI. Requests by third parties for charitable donations should be forwarded to the VP, Communications, RCI.

17. Confidentiality

Employees doing work for the Company may have access to information of a confidential or proprietary nature, the improper disclosure of which could have serious consequences for the Company. Employees must maintain the confidentiality of all information entrusted to them, except when the disclosure is authorized or legally mandated.

Extra sensitivity to security, confidentiality and conflict of interest is required in situations where an employee's spouse, immediate family member or friend is a principal of, or is employed by, a competitor or supplier of the Company.

Customer Information: 

Subject only to certain exceptions, the law requires the Company to provide customers with access to all personal information about them that the Company may hold. This includes records such as customer care logs and notes. Employees should avoid non-factual entries or inappropriate language or comments. All information kept by the Company about its customers is confidential and cannot be divulged or used, directly or indirectly, except for business purposes.

Unless a customer provides explicit consent, or the Company is required to do so by law, the Company may not disclose a customer's confidential personal and business information to anyone other than:

1. the customer himself;
2. a person whom the Company reasonably believes is acting on behalf of the customer;
3. another company, for the purpose of providing the customer with efficient and cost-effective service, where the information is required only for that purpose and will be kept confidential (for example, the exchange of call detail information for the settlement of usage charges)or where the information is required only for that purpose of supplying telephone or telephone directory related services and will be kept confidential (for example, a firm retained by the Company to do installation work on its behalf);
4. an agent retained by the Company to evaluate the customer's credit worthiness or to collect the customer's account, where the information is required for and will be used only for, that purpose; and
5. a public authority, if there is imminent danger to life or property which could be avoided or minimized by disclosure of the information.

The unlawful interception of a private communication is a criminal offence. An employee may intercept a private communication only when such interception is necessary for the purpose of providing service, to perform quality control checks in the course of service monitoring, to protect the company's rights or property or when authorized by law.

Maintaining customer privacy is also crucial when dealing with contracts, proposals and quotations. An employee must be vigilant in ensuring that: unless a customer provides explicit consent, customer information is not shared with other affiliates or partners, agents or subsidiaries of our group, except with those affiliate or partners or agents or subsidiaries of a group, who are directly involved in the specific contract, proposals or quotations.

Employee Information: 

Employees may not release information, related to co-workers or other employees, on personnel matters including private phone numbers and addresses, medical records, or salary information unless required by law or by an authorized representative of the applicable employee.

When such a request is made, it should be referred to the Human Resources department. No statements, interviews or access to records should be given until the Company or its legal counsel has the opportunity to review the request. The request may be legitimate but the Company has the right to determine the reasonableness of the request and to ensure that all responses are complete and accurate.

18. Intellectual Property Assignment

From time to time, employees may author, make, create, and conceptualize intellectual property during the course of employment with the Company (whether or not during regular office hours, and whether or not at the employee's place of employment). This information and property is considered to be the exclusive property of the Company, if it arises from or is incidental to performance of duties as a Rogers employee, and must be treated as confidential information.

For greater certainty, the foregoing shall not apply to freelance work and/or independent productions authored, created, conceptualized or made by employees entirely outside of the scope and mandate of the employee's employment and which do not relate in any way to the responsibilities and duties of employment with the Company.

Please refer to Section B of Exhibit A.

19. Public Disclosure, Restricted Use of Confidential Information and Insider Trading

The Company is committed to best practices in making timely and accurate disclosure of all material information. The Company will promptly disclose all material information in a full, fair, accurate, timely and understandable manner in accordance with applicable securities laws and policies, and stock exchange rules. All employees must perform their responsibilities with a view to giving effect to the foregoing commitment of the Company, including by reporting all material information in a timely manner to the appropriate person within the Company in accordance with the Company's disclosure policies and procedures.

Each officer involved in the Company's disclosure process is required to be familiar with and comply with the Company's disclosure controls and procedures and internal control over financial reporting. In addition, each person having direct or supervisory authority regarding regulatory filings or the Company's other public communications should, to the extent appropriate within his or her area of responsibility, consult with other Company officers and employees. Each officer who is involved in the Company's disclosure process must:

1. familiarize himself or herself with the disclosure requirements applicable to the Company as well as the business and financial operations of the Company;
2. not knowingly misrepresent, or cause others to misrepresent, facts about the Company to others, whether within or outside the Company, including to the Company's independent auditors, government regulators and self-regulatory organizations; and
3. properly review and critically analyse proposed disclosure for accuracy and completeness (or, where appropriate, delegate this task to others).

Public Statements: 

Employees should not discuss prospective changes or developments with people outside the Company before an official announcement has been made. Specifically:

1. information on corporate developments, products and plans, including all financial and material information that may impact the value of Company securities or influence investor's investment decisions, will be released only by authorized Company spokespersons;
2. confidential information on specific operating companies will be released by the management of that business unit;
3. employees expressing opinions beyond the scope of their positions must clearly differentiate between speaking for themselves and speaking for the Company, to ensure that their views are in no way perceived to be associated with the Company. Company stationery must not be used for expressing personal views.

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2.  Rogers companies and business units are to refer inquiries from the press, media, research and security analysts, brokers, and investors to the Vice-President, Investor Relations, RCI. Unless specifically authorized to do so, employees are not permitted to contact the press, media, research and security analysts, brokers or investors about the Company's business.
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4. Employees who participate in any public forum as a Company employee must seek approval from the designated Vice President responsible for public relations regarding the content of any commentary or speeches, in order that it may be consistent with Company policy and not contain or refer to confidential information.
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6. Insider Trading:
7. Employees with knowledge of material confidential information about the Company are prohibited from trading securities of the Company until the information has been publicly disclosed and at least one trading day has passed. Employees must not inform ("tip") any person of material information before it has been publicly disclosed. Officers of the Company deemed to be insiders are required to file a report for every transaction in securities of the Company at www.sedi.ca. (Please see policy LEG 5 - Insider Trading and the Disclosure and Restricted Use of Confidential Material Information).

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2.  Rogers allows others to use the Rogers name or brand as a trademark or service mark, approval must be obtained. To obtain approval for brand usage or if employees are uncertain about brand usage, consult the contacts at www.theburbs.com/brand.