Recognizing and Avoiding Conflicts of Interest

Rogers Corporation employees must perform their job responsibilities loyally and objectively, without allowing personal, family, or their own financial interests to influence their judgment. Employees must avoid not only actual conflicts of interest, but also the appearance of a conflict of interest. While the Company recognizes that its employees are free to make personal financial investments and to maintain social and business relationships, these relationships must not create any interests that conflict with those of the Company. Any waivers of this requirement must be preapproved by the company’s General Counsel or Director of Global Compliance & Integrity.

What is a conflict of interest?

A conflict of interest occurs when an individual’s private interest (or the interest of a member of their family) interferes, or appears to interfere, with the interests of the Company as a whole.

What is expected of you?

• Understand that your loyalty as an employee is to the legitimate business interests of Rogers and act accordingly.
• Take appropriate precautions to avoid the appearance of impropriety, even if you believe your actions are appropriate.
• Do not seek or accept outside employment with competitors or those who do business with Rogers, such as suppliers.
• Avoid doing business with family members or those with whom you have close personal relationships.
• Refrain from accepting consulting arrangements or serving on boards or other advisory bodies for organizations, including industry trade associations, when related to your work for Rogers.
• Do not obtain ownership in property or other interests which Rogers may seek to acquire, with whom the Company may conduct business, or which may compete with the Company.
• If you have a question about a potential conflict of interest, or become aware of an actual or potential conflict you must discuss the matter with, and seek a determination and prior authorization or approval from, the General Counsel or the Director of Global Compliance & Integrity.
• Directors and executive officers must seek determinations and prior authorizations or approvals of potential conflicts exclusively from the Nominating, Governance and Sustainability Committee of the Board of Directors by notifying the General Counsel pursuant to the Company’s Related Party Transactions Policy.