Rogers Corporation directors and employees are prohibited from using material, non-public information (“MNPI”) regarding the Company or third parties for their own personal profit or the profit of anyone else. Accordingly, Rogers prohibits insider trading, including the purchase or sale of securities when in possession of material, non-public information. Also prohibited is any communication of material, nonpublic information to another person for purposes of trading on that information. This policy applies not only to insider trading relating to Rogers, but also to its business partners (such as suppliers and customers), since MNPI about these business partners may be obtained during the normal course of employment. In addition, this policy applies to employees even after leaving employment with Rogers for as long as the information remains confidential and non-public.
Directors, officers, and employees should maintain the confidentiality of information entrusted to them by the Company or by its customers, suppliers or partners, except when disclosure is expressly authorized or is required or permitted by law. Confidential information includes all nonpublic information (regardless of its source) that might be of use to the Company’s competitors or harmful to the Company or its customers, suppliers, or partners if disclosed.
Insider trading generally refers to the buying or selling of a security (for example, stocks, debt instruments, or bonds), while in possession of MNPI about the security. Information is “material” if a person would consider the information important in making a decision to buy or sell securities of that company. Material information can include positive or negative information about a company. Non-public information includes proprietary and other information about Rogers or other companies learned through employment with the Company that is not available to those generally outside of the Company. This non-public information may include sales and financial results, strategic plans, research results, introduction of new products, material contracts or new licensing agreements, anticipated government actions, significant personnel changes, and acquisition or divestiture information.
