Rogers Contractor Code of Conduct
Note: This amended Code is not intended to create new
and additional third party rights, including for employees.
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.
Contractors are committed to uphold the human rights of workers, and to
treat them with dignity and respect as understood by the international
The labour standards to be adhered to are as follows:
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
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
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
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.
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
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
Health and Safety
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:
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.
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.
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.
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.
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.
Physical guards, interlocks and barriers will be provided and properly
maintained for machinery used by workers.
(vii) Dormitory and
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.
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.
environmental standards are as follows:
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.
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.
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
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.
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.
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.
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.
system should contain the following elements:
Corporate social and environmental responsibility
statements affirming Contractor’s commitment to compliance and continual
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’
Identification, monitoring and understanding of
applicable laws, regulations and Rogers’ requirements.
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
Objectives with Implementation Plan and Measures
Written standards, performance objectives, targets and implementation
plans including a periodic assessment of Contractor’s performance against those
Programmes for training managers and workers to
implement Contractor’s policies, procedures and improvement objectives.
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
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
(ix) Audits and
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.
Process for timely correction of deficiencies
identified by internal or external assessments, inspections, investigations and
Creation of documents and records to ensure regulatory compliance and
conformity to Rogers requirements along with
appropriate confidentiality to protect privacy.
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
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.
No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not
to be offered or accepted.
(iii) Disclosure of
regarding business activities, structure, financial situation and performance
is to be disclosed in accordance with applicable regulations and prevailing
Intellectual property rights are to be respected; transfer of technology
and know-how is to be done in a manner that protects intellectual property
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
Programmes that ensure the protection of supplier and employee
whistleblower confidentiality will be maintained.
Community engagement is encouraged to help foster social and economic
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.