Policies

Purpose

In our dealings with you, we are called upon to process your personal data. The purpose of this Data Protection Notice is to explain to you:

1. Who we are and how we may be contacted;
2. The categories of personal data we collect;
3. The purpose for which we collect your personal data and the lawful basis for such collection;
4. The intended recipients of the personal data;
5. Whether the supply of personal data is voluntary or mandatory;
6. Your rights relating to your personal data being processed by us;
7. The possible existence of automated decision making in respect of your personal data;
8. The period for which we will store your personal data;
9. Whether, and in what circumstances, we may transfer your personal information to another country, and the safeguards we have put in place in relation to such transfer; and
10. How we conduct direct marketing.

Application

This Data Protection Notice applies to any processing of your personal information by us, whether such information is provided to us through our website, by email, through the filling of forms (including employment-related ones), through the exchange of contractual documents, by letter or fax, verbally, or through any other means.

By entering into a business relationship with us, or by providing your personal data to us, you confirm that you are agreeable to the processing of your personal data in accordance with the terms of this Data Protection Notice.

Technical terms

We have tried to use simple and plain English as far as possible in this Data Protection Notice. However, data protection is a complex subject and the use of technical terms from time to time is inevitable. We have therefore set out below definitions of the technical terms we have used in this document:

Personal data: Any data which allows or could allow us to identify you.

Processing: Any manipulation of personal data, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

1.  Who we are and how we may be contacted

Details about us and how we may be contacted are set out in the table found in the schedule of this Data Protection Notice (the “Information Table”).

We have appointed a Data Protection Officer to monitor the adherence to data protection principles within our organisation. His name and contact details are also set out in the Information Table. You may wish to contact him if you have any query regarding this Data Protection Notice or any other matter relating to your personal data.

2. The categories of personal data we collect

2.1. Categories

The categories of personal data we collect are set out in the Information Table.

While we have attempted to make the list as exhaustive as possible, there is a possibility we may have omitted come categories due to the complexity of our organisation and the intricacies of our operations.

We encourage you to get in touch with our Data Protection Officer if you find that any of your personal data which we collect is not listed in this Data Protection Notice. We will then endeavour to promptly amend this Data Protection Notice accordingly.

2.2. Personal data of children

We do not knowingly process data relating to a child under the age of 16, without the consent of his parents or guardians. If you are a child under the age of 16, please ensure that you (a) obtain the consent of your parents or guardians before providing such data to us; and (b) provide a record of such consent to us.

If you provide us with the personal data of another person, you are responsible for ensuring that such person is made aware of the information contained in this Data Protection Notice and that the person has given you his consent for sharing his personal data with us.

2.3. Special categories of personal data

Special categories of personal data are data pertaining to racial or ethnic origin, political opinion or adherence, his religious or philosophical beliefs, membership of a trade union, physical or mental health or condition, sexual orientation, practices or preferences, genetic data or biometric data uniquely identifying someone or data relating to the commission or alleged commission of an offence.

We do not collect any of your personal data which falls within the special categories of personal data, unless:

1. 1. you have consented to the processing for one or more specified purposes;
   2. the processing is necessary:
      1. for the performance of a contract to which you are a party or in order to take steps at your request before entering into a contract;
      2. for compliance with any legal obligation to which we are subject;
      3. for the purpose of historical, statistical or scientific research; or
      4. for such other legitimate purposes as may be authorised by law.

The special categories of data which we may collect, in accordance with the above terms, are set out in the Information Table.

2.4. Cookies

Please note that we collect information via cookies and other similar technologies (such as web beacons).

Cookies are small text files that are automatically placed on your computer or mobile device when you visit a website. They are stored by your internet browser. Cookies contain basic information about your use of the internet. Your browser sends these cookies back to our website every time you visit it, so it can recognise your computer or mobile device and personalise and enhance your browsing experience.

3. The purpose for which we collect personal data and the lawful basis for such collection

3.1. Purpose

We collect personal data for a number of purposes, including:

1. 1. to provide services to our clients. You will find a brief description of the services we provide in the Information Table;
   2. to enter into contractual relationships with suppliers and service providers and execute such contracts;
   3. to keep a database of clients and potential clients to communicate with in respect of our services and matters related thereto;
   4. to comply with our legal obligations towards authorities, including the Mauritius Revenue Authority, the Registrar of Companies and the regulators;
   5. to keep a database of candidates who have sent CVs to us, for potential future use;
   6. to keep appropriate employment-related information on employees;
   7. to provide facilities and benefits to our employees;
   8. for security purposes;
   9. to generate statistics and reports on different aspects of our business; and
   10. for such other purposes as may be related, directly or indirectly, to our business activities.

3.2. Lawful basis

The law (a) provides that we cannot process personal data unless we have a lawful basis for such processing; and (b) lists a number of lawful bases for the processing of data.

The lawful bases which apply to our processing of your personal data are as follows:

1. 1. your consent having been obtained; and/or
   2. the processing being necessary:
      1. for the performance of a contract to which you are a party or in order to take steps at your request before entering into a contract with you; and/or
      2. for compliance with any legal obligation to which we are subject; and/or
      3. for the purpose of historical, statistical or scientific research; and/or
      4. for the legitimate interests pursued by us (except if the processing is unwarranted in any particular case having regard to the harm and prejudice to your rights and freedoms or legitimate interests).

4. The intended recipients of the personal data

The primary purpose of collecting your personal data is for our own uses, in connection with our business relationship with you. In this context, we may disclose your personal information to our collaborators, including our employees, consultants, advisors, directors and service providers who need to access the personal data.

However, we may also be required to disclose your personal data to third parties to comply with our legal obligations. Such third parties may include the Registrar of Companies, the Mauritius Revenue Authority, the Stock Exchange of Mauritius Ltd, the Financial Services Commission and other government authorities.

As you are aware, we form part of the Rogers Group. In this context, we may, from time to time, disclose your personal information to other companies forming part of the Rogers Group. The objective of this disclosure is to develop a centralised database of clients, which would help the Rogers Group better identify your needs and provide tailor-made packages and services to you. If you do not wish that your personal data be communicated to other companies within the Rogers Group, we encourage you to notify our Data Protection Officer as soon as possible.

5. Whether the supply of personal data is voluntary or mandatory

The provision of personal data is of course entirely voluntary. You are free to choose whether to provide your personal data to us or not. Please note however that if you choose not to provide your personal data to us, we may not be able to provide certain services to you or enter into a contractual relationship with you.

6. Your rights relating to your personal data being processed by us

The law confers upon you a number of rights relating to the personal data being processed by us. These rights are set out below. If you wish to exercise any of the said rights, we encourage you to contact our Data Protection Officer.

6.1. Right to withdraw consent at any time

Where we process your personal data on the basis of your consent, you may withdraw such consent at any time. The withdrawal of your consent will not affect the lawfulness of any processing done by us prior to such withdrawal.

Please note that withdrawing your consent may result in us not being able to provide certain services to you or enter into a contractual relationship with you.

6.2. Right of access

You may request a copy of the personal data we hold about you. Kindly ensure that such request is made in writing to our Data Protection Officer.

Please note that if, in our opinion, your request is manifestly excessive, we may either not attend to your request or charge a fee for attending to same.

6.3. Rectification, erasure or restriction of processing

You may also, at any time, request:

1. 1. to have any inaccurate personal data we hold on you corrected. This includes the right to supplement and/or update existing personal data provided to us;
   2. that we erase any personal data we hold on you where

1. 1. 1. such data is no longer necessary in relation to the purpose for which it was collected or otherwise processed;
      2. you have withdrawn your consent to us holding and processing such data and there are no overriding legitimate grounds for the continued processing; or
      3. your personal data has been unlawfully processed.

You will understand that this right is not absolute and that it will not be applicable where the exceptions provided for by law apply, including where our processing of your personal data is necessary for the purpose of historical, statistical or scientific research or for compliance with a legal obligation or for the establishment, exercise or defence of a legal claim

 c. us to restrict processing of your personal data where

1. 1. 1. the accuracy of your personal data is contested by you. This restriction will apply for such period as may be necessary to enable us to verify the accuracy of the data;
      2. we no longer need the personal data for the purpose of processing;
      3. you deem the processing of your personal data to be unlawful, but do not wish us to erase it; or
      4. you have objected to the processing of your data. Such restriction will apply pending verification as to our legitimate grounds to keep processing the personal data, despite your objection.

6.4. Right to object

You have the right to object to our processing of your personal data at any time. Upon receiving such objection, we will stop processing your personal data, except where there are compelling legitimate grounds to continue such processing;

6.5.Right to lodge a complaint

If you feel that we have not processed your personal data lawfully, please do feel free to contact us through our Data Protection Officer.

If you remain unsatisfied, you may lodge a complaint with the Data Protection Commissioner in Mauritius. Her contact details are as follows:

Address: 5th Floor, SICOM Tower, Wall Street, Ebène

Email address: dpo@govmu.org

Phone number: + (230) 460-0253

Fax: + (230) 489-7346

7. The possible existence of automated decision making in respect of your personal data

Unless one of the following exceptions apply, we will not process your personal data in such as way to subject you to a decision which produces legal effects concerning you or which significantly affects, you, based solely on automated processing, including profiling:

1. 1. where the decision is necessary for entering into, or performing, a contract between us;
   2. where the decision is authorised by a law to which we are subject and which lays down suitable measures to safeguard your rights, freedoms and legitimate interests; or
   3. where the decision is based on your explicit consent.

8. The period for which we will store your personal data

The law provides that where the purpose for keeping any personal data has lapsed, we should destroy the data as soon as reasonably practicable.

We will keep storing your data for as long as is necessary:

1. 1. for us to fulfil the purposes we collected it for;
   2. for the performance of any contract which may exist between us;
   3. for us to share with you the latest news regarding our organisation and our services;
   4. for us to keep a record of your preferences in order to service you again on future occasions;
   5. for us to satisfy any legal requirement, including statutory reporting obligations;
   6. for the keeping of adequate records for historical, financial or statistical purposes;
   7. for security purposes;
   8. for the prevention of fraud and abuse; and
   9. for us to defend or enforce our rights.

We wish to draw your attention to the fact that the legal prescription period in Mauritius (i.e. the period during which one party may sue another after the happening of an event) is 10 years for non-immovable-property-related matters. Depending on the nature of our relationship with you, we may, in this context, also choose to keep your personal data for at least the legal prescription period in order to be able to defend or enforce our rights.

In some circumstances, we may anonymise your personal data by pseudonymisation or encryption, such that the personal data can no longer be associated with you, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Whether, and in what circumstances, we may transfer your personal information to another country, and the safeguards we have put in place in relation to such transfer

Please refer to the Information Table.

10. How we conduct direct marketing

You may from time to time receive communication of advertising or marketing material from us (“Direct Marketing”) if:

1. you have given your consent;
2. you asked for a quote or other information on us;
3. you have, at any time, purchased goods or services from us and have not opted out of receiving advertising or marketing material;
4. you have entered into a contractual relationship with us; or
5. you have provided us with your personal data when you entered a competition or registered for a promotion.

You have the right, at any time, to object to the processing of your personal data for direct marketing purposes. Where we receive such an objection from you, we will stop processing your data for direct marketing purposes.

11. Queries

If you have any queries on this Data Protection Notice, we encourage you to get in touch with us through our Data Protection Officer.

Schedule

The Information Table

Annex A

The List of entities that form part of the enterprise

Annex B

The categories of personal data we hold

Introduction

1. Purpose

The purpose of the Code of Ethics (the ‘Code’) is, amongst others, to:

1. 1. provide clarity on the values of the organisation and reflect them in expected standards of professional conduct;
   2. provide guidance and a set of common ethical values to promote consistency in behaviour throughout the Group; and
   3. be a central guide for employees to support their day-to-day work and decision-making.

2. Our Values act as the rudder which steers the organisation forward in the right

The Rogers values are:

Agility

Our ability to anticipate changes and act together in a coordinated manner.
Agility in Rogers is about:

1. Being aware of our environment and of our actions e. be conscious of the changes in our internal and external environment and mindful of the impact and outcome of our actions.
2. Being ready to learn, change and grow e. as humans, agility is in our ‘DNA’ and we have the innate ability to adapt and evolve, which allows us to embrace and drive change.
3. Collaborating and acting together for the good of the business e. share ideas, encourage frank discussions to generate clarity & conviction and take accountability for actions.

Dynamism

The focused energy of our people which drives Rogers forward.
Dynamism in Rogers is about:

1. Energy flows where attention goes as directed by intention e. having a clear intention in mind in whatever we undertake allows us to focus our energy and create impactful results.
2. Challenging the status quo to enable progress e. every challenge involves confronting our habits and routines; asking questions to clarify and to push our limits to keep moving forward.
3. Working hard and playing hard e. be outcome focused and ready to put in the extra effort while having fun and celebrating our success and achievements regularly together.

Leadership

The audacity and engagement of our people to create purposeful impact with others.
Leadership in Rogers is about:

1. Being daring and authentic to yourself e. be ambitious, adventurous and open to opportunities and yet be grounded and modest.
2. Building truthful and trustworthy relationships through open and direct communication e. ask and encourage questions; promote face to face interaction; and constantly build trust with people.
3. Encouraging and embracing diversity e. be open-minded and open to work with a varietyof people, ideas and differences.
4. Taking initiatives to make a meaningful impact for people e. be a self-starter and go the extra mile to take positive action to satisfy our clients, partners and stakeholders.

3. Relevance of the Code to the organisation

This Code does not aim to summarise all laws, rules and regulations that govern our business, or capture all of Rogers’ policies. It is a guidance on the behaviour expected of all employees and directors.

To whom does the code apply ?

The Code applies to all directors and full-time, part-time and temporary employees throughout Rogers and all its subsidiaries and jointly-controlled entities operating in Mauritius and overseas (the ‘Group’).

Management will ensure that appropriate tools are implemented and adequate communication put in place to circulate the Code to all those concerned.

How the code should be used ?

The Code should be read together with other policies and supporting documents adopted by Rogers. As at date, the Group has adopted the following:

• Equal Opportunities Policy (‘EOP’)
• Malpractice Reporting Policy
• Health and Safety Policy
• Overview on Information, Information Security and Information Technology Policy
• Data Protection Policy
• Nomination process and Appointment of directors
• Related Party Transactions approval process

Personal Conduct

1. We must observe the laws of Mauritius or of the country where we are working, in everything we do.

Bribery and facilitation payments

2. Corruption is encouraging somebody, either by gifts, promises, persuasion or threat to act against his/her own conscience or duty. A Rogers employee or a director must not act in a corrupt manner or allow himself/herself to be actively or passively corrupted. An employee should not offer money or favours for any reprehensible purpose, nor accept money or favours in any form in exchange for confidential information or any other purpose which might adversely affect the Group.

3. Our dealings with all those who have contact with us must be straight, fair, honest, courteous and efficient. We should refuse questionable or unlawful behaviours such as fraud, corruption and bribery.

Dealings in shares and close-periods

4. Can employee or a director should not deal in the shares of the company at any time when he/she is in possession of unpublished price-sensitive information in relation to those shares.

5. Rogers also prohibits dealing, by directors and the Rogers Leadership Team (RX, R1-R3), in its shares and those of its listed subsidiaries during close periods (as defined in the Listing Rules issued by The Stock Exchange of Mauritius Ltd.).

Gifts and entertainment policy

6. We, as employees of the Group, must not solicit any favours in the form of gifts or benefits from anyone if that favour could impact negatively on the way in which we as an employee do our job.

7. We should not accept gifts or entertainment if we believe that such favours may impair our professional judgement.

8. We should not offer gifts or entertainment if this could lead us obtaining an unfair business advantage.

9. Rogers is aware that it can be difficult to draw a dividing line for gifts as well as hospitality. Therefore, Rogers expects that:

• its employees will use prudence and discernment in its relations with suppliers of goods and services;
• its employees will ensure that their independent judgement will not be influenced or impaired in any way by the acceptance or grant of whatever benefit; and
• the acceptance of any benefit does not, in any way, create an unfavourable impression.

10. Only gifts that are customarily given or accepted in the relevant industry may be accepted or given. Such gifts should be reasonable in value or quantity. The employees must at all times advise their immediate superior of any gifts or benefits received or given.

11. We should not offer any gift or favour to anyone in order to influence that person in the way in which he/she does his/her job.

12. While normal business entertaining is acceptable, we must guard against hospitality that appears to be aimed at influencing the way we do our job and take decisions. Whenever possible, hospitality should be reciprocated as soon as possible. An employee, with the consent of his/her Manager, may use the company expense account for entertainment, lunches and dinners with people doing or desiring to do business with the company. The frequency and amount of this entertaining should not go beyond the common courtesy usually associated with reasonable business practice and should not constitute lavish expenditure.

Confidential Information

13. We generate, receive and store much information that is valuable to outsiders. We must not disclose, either verbally, in writing or electronically, such information without permission. We each have a responsibility to ensure that such information under our control, or to which we have access, is properly safeguarded. Failure to do so will be considered a serious offence and may result in dismissal and prosecution.

14. None of us must ever make use of insider information, namely information that has not been made public, for our personal advantage.

15. Employees should also refrain from tipping off and should not disclose confidential information to other persons otherwise than in the proper performance of their employment and/or duties as a director of Rogers.

Conflict of Interest

16. We must not allow our personal interests to conflict with our duties in the company. If any of us has a personal interest that may influence, or appear to influence, the way we do our job, we must declare that interest to our immediate superior and take appropriate steps to resolve the conflict of interest. The conflict shall be recorded in the conflict of interest registers of Rogers Group. We must each make sure that our dealings with customers, suppliers, contractors and colleagues do not place us in a position of obligation that may lead to a conflict of interest.
Rogers Legal shall be responsible for reviewing any conflict of interest.

Use of company assets

17. The company’s property and products belong only to the company. They do not belong to us. They should only be used for the benefit of the company and its business. If any employee takes company property or products for his/her own use or to give, sell, rent, or dispose of, he/she commits a serious offence and is liable to dismissal and prosecution. The company’s services and facilities are not to be used for private purposes except with prior permission.

Use of IT and communication systems

18. IT and communication resources are provided to employees for work-related purposes and are monitored regularly to prevent cyber-attacks and malicious activities. Personal use may be accepted if in line with applicable rules. We should always be vigilant to scams like phishing and should immediately report any incidents including loss of information on equipment provided to us. We have a duty to ensure that usernames and passwords issued to us are securely kept. Employees and directors are also encouraged to consult the Information, Information Security and Information Technology Policy of Rogers.

Secondary employment

19. A secondary employment, or involvement, paid or unpaid, regular or casual must not be undertaken without prior written permission of your immediate superior and should in no way conflict with your current employment.

RELATIONS WITH SUPPLIERS AND CONTRACTORS

20. We believe in fair and open competition. We treat our competitors honourably and we aim to develop and maintain long term relationships with suppliers and contractors based on mutual trust. Agreed terms and conditions should always be respected and bills should be settled promptly

21. Our procurement of supplies and services should always be done according to ethical standards that assure a quality end product and the continued confidence of customers, suppliers and the public.

RESPONSIBILITIES TO SHAREHOLDERS AND THE FINANCIAL COMMUNITY

22. The Group aims to generate sustainable return on investments and long-term value.

23. Rogers respects the rights of shareholders and potential shareholders to know such trustworthy and accurate information as appropriate to evaluate how their investments are being managed.

24. It is the policy of the company to maintain complete and accurate records and accounts and to present them in accordance with all applicable laws and professional accounting standards. We do not tolerate any false or misleading entries in the books, accounts, records, documents or financial statements

RELATIONS WITH CUSTOMERS

25. We shall provide efficient and courteous services to our customers and the public at large. We shall keep our customers truthfully informed about the company’s capabilities.

26. Rogers will always put customers first by providing them with good quality products at prices that represent good value for money.

27. We shall provide our customers with products and services, including after-sales service, that meet high standards of safety, quality and reliability to retain our customers.

EMPLOYMENT PRACTICES

28. The occupational health, safety and welfare of our employees are a prime concern of the company. It is the responsibility of us all to comply with all occupational health and safety laws, Group policies, and to provide good and safe working conditions.

29. Rogers is an equal opportunity employer and we are committed to attracting and retaining the best people. We aim to achieve equality of opportunity and treatment for all candidates in recruitment, and all employees in training and development, promotion, transfers, benefits, sanctioning and retirement. All employees are treated as individuals according to their ability to meet job requirements. We aim to provide a stimulating and rewarding working environment for our employees and a workplace free of all abuse, harassment and discrimination, particularly with regard to age, caste, colour, creed, ethnic origin, impairment, marital status, place of origin, political opinion, race, sex or sexual orientation.

30. The privacy and confidentiality of employee records will be processed and safeguarded in line with Data Protection Act 2017 (as it may be amended from time to time) and any other Group/company policies.

31. Employees are kept informed of company matters affecting them, including Rogers Strategy, Objectives, Values and performance. The Group encourages open channels of
communication that foster an atmosphere of mutual trust and respect within the company.

RESPONSIBILITIES TO THE COMMUNITY

32. Care for the environment is one of the Group’s concerns. The Group is committed to respect and protect the environment and encourages all its employees to do the same. We aim to manufacture, handle and dispose of all materials in compliance with the law and in a responsible
manner without creating risk to health or the environment.

33. Participation by directors and employees in community activities and civic affairs is encouraged.

34. Participation in political and religious activity is entirely personal and voluntary, but should not impinge in any way on performance at work.

35. Rogers supports NGOs’, charitable and similar organisations and encourages employees to do likewise.

36. Rogers endorses the democratic principles of Mauritius. Contributions by the Group to political organisations or electoral candidates are specifically recorded in the company’s accounts and are made in accordance with all the applicable laws.

COMPLIANCE AND ENFORCEMENT

38. It is the personal responsibility of every employee to understand and comply with this Code. Managers and supervisors are also responsible for ensuring that those they supervise are made aware, understand and comply with the Code.

39. An employee who has knowledge or good reason to believe that he or she is being required to act in a way that is inconsistent with the standards in this Code, or who has knowledge that others are or may be breaching the Code, should report the matter to his/her immediate superior or an appropriate senior manager. Rogers undertakes to ensure that no prejudice whatsoever results to an employee who makes such a report on reasonable grounds.

40. Problems encountered in complying with the Code, suggestions for improving it and breaches of the Code should be referred to the Chief Legal and Compliance Executive of Rogers, unless she/he is conflicted in the matter, in which case it should be referred to the Chief Finance Executive of Rogers. If the Chief Finance Executive of Rogers is equally conflicted in the matter, it should then be referred to the Chief Human Resources Executive of Rogers. Management will thereafter set up the necessary forum depending on the nature of the matter concerned to investigate, make necessary recommendation and apply sanction if need be.

41. Channels of complaint are open to shareholders and potential shareholders, customers and consumers, suppliers, contractors, directors and employees of the company. All complaints will be considered impartially and promptly by Management. Anonymous representations will not be considered.

APPROVAL, MONITORING AND REVIEW PROCESSES

37. The Rogers Corporate Governance Committee (‘RCGC’) shall regularly monitor compliance with this Code which shall be reviewed at the end of each financial year. Any comments or proposed amendments shall be tabled before the RCGC for recommendation to the Board for
approval.

Introduction:

The Rogers Group is committed to safeguarding the confidentiality, integrity and availability of all its information systems and information assets, in order to ensure that regulatory, operational and contractual requirements are fulfilled. The Group has issued a set of Policies and Guidelines, to provide references and guidance to all employees in respect of the protection of all Information systems and Information assets. The related policies are obtainable through the Company website.

Objectives:

The overall objectives for this policy are as follows:

Compliance: Ensure compliance with the current laws, regulations and employee guidelines;

Security: Establish an acceptable level of security for accessing information systems;

Control: Maintain controls for protecting the Groups Information Systems and Information assets against theft, abuse and other forms of harm or loss;

Responsibility & Ownership: Motivate employees to maintain the responsibility for ownership of and knowledge about information security, in order to minimize the risk of security incidents;

Business Continuity: Ensure that companies within the group are capable of continuing their services even if major security incidents occur;

3rd party Confidentiality: Certify that external service providers comply with our information security requirements;

Accessibility: Ensures that all the policies are accessible to all employees, business consultants and third party contractor

Rogers and Company Limited (the ‘Company’ or ‘Rogers’) is an equal opportunities employer whose policies and practices aim to create an environment that promotes equal opportunities for its employees and potential employees. Rogers is committed to being a responsible employer.

Having taken cognizance of its obligations under the Equal Opportunities Act 2008, Rogers endeavours to follow the recommendations of the Equal Opportunities Commission (the ‘Commission’) as set forth in its Guidelines on Application of an Equal Opportunity Policy at work including:

• Selection
• Recruitment
• Employment
• Promotion
• Learning and development
• Termination and dismissal

Rogers shall ensure that its employees or potential employees are not treated less favourably and/or harassed on grounds of:

• Age
• Race (including ethnic origin, colour, caste, creed, nationality and national origin)
• Gender (including sex, pregnancy and maternity, marital, partnership and family status);
• Sexual orientation
• Impairment (physical and/or mental impairment, and diseases including AIDS) ;
• Religion/ belief or non-belief
• Political opinion

Rogers recognises that the above list is non-exhaustive and will review its criteria and procedures periodically to ensure that employees are selected, promoted and treated on the basis of their relevant performance, merits and abilities whilst taking into account special consideration for candidates with an impairment or disability.

Rogers ensures adherence to the Policy in the following manner:

• The Human Resource function endorses these practices in its daily operation.
• Rogers purports that the above implied practices are in place and consequently known to its employees and prospective recruits.
• The existing HR procedures cater for proper communication and feedback mechanism including purported discrimination against any individual or group of individuals.
• In the event of complaints and grievances, the usual corporate process will be triggered and the matter dealt with accordingly.

Introduction:

Rogers is committed to high standards of openness and strongly believes that all reasonable and valid concerns of employees, questionable practices, or potential wrongdoing must be considered within a defined process.

Definition:

“Malpractice reporting is a process whereby information relating to questionable practices within an organization is disclosed in good faith by employees”

Examples of such malpractice matters typically relate to:

• A criminal offence (including Fraud and Theft)
• Incorrect financial reporting and internal control breakdowns
• Non-compliance with regulations and laws
• Non-compliance with policies and procedures
• Non compliance with corporate behaviour
• Health and Safety danger
• Damage to the environment
• Deliberate concealment of information.

Note:

• Employment related concerns and individual grievances do not form part of the malpractice matters. These should continue to be reported through the normal channels such as the Human Resources Department in line with the Grievance procedure.
• Anonymous letters will not be entertained and do not qualify for the process.

Authority:

Pursuant to section 4.7 of the Rogers Risk Management Audit Committee (RMAC) Charter, the RMAC has been vested with the responsibility to establish procedures for the receipt, retention, and treatment of complaints received by the Company. Management has a specific responsibility to facilitate the operation of this policy and to ensure that employees feel able to raise concerns, without fear of reprisals, in accordance with the procedure set down below.

Employees are responsible for the success of this policy and should apply the appropriate level of discernment and objectivity in triggering the policy.

Purpose:

The purpose of this policy is to provide a channel of effective communication of employee concerns so as to facilitate the disclosure of any malpractice of which they become aware and to provide protection for employees who report allegations. It further outlines the process on how reported concerns will be handled and investigated.

Note:

The aim of the malpractice reporting policy is to promote transparency to underpin the risk management systems, to ensure fair and ethical practices are maintained, and to help protect the reputation of the organisation. It provides employees with a mechanism to report suspicious concerns that contravene the Rogers code of ethics.

The reported malpractice, where applicable, is thoroughly investigated and suitable action taken where necessary. The employee who discloses such a malpractice will be protected against adverse employment actions (discharge, suspension, harassment, and other forms of discrimination) if the reported allegations of business malpractice are substantiated. Employees who participate or assist in an investigation will also be protected. Every effort will be made to protect the anonymity of the person reporting such a malpractice; however there may be situations where it cannot be guaranteed.

Employees participating in such a process should not discuss reported concerns with colleagues or third parties. Such reports will be treated equally seriously to the primary allegation under investigation.

Scope:

The policy applies to all employees throughout the Group, including full-time, part-time and temporaries, found in subsidiary and joint venture Companies operating in Mauritius and overseas.

Reporting:

An employee who reasonably believes that inappropriate business conduct is occurring should raise the issue with his/her direct reporting manager or if this is considered inappropriate, the issue should be raised with the Chief Human Resource Executive at Corporate office . The latter will consequently report to the Chief Executive Officer of Rogers Group.

Investigation:

Once the claim of malpractice is made, the direct reporting manager will respond within 15 working days setting out the intended investigation plan (if any) .

Preliminary Inquiries – No investigation will be carried out prior to the approval of the Chief Executive Officer of Rogers Group. Some concerns may be resolved without the need for investigation.

An investigation may include internal reviews, reviews by the internal and external auditors or lawyers or some other external body.

Once the investigation is complete, the appropriate Company representative will communicate the results of the investigation as well as any corrective steps that are being taken.

Employees who believe they are being penalised for malpractice reporting or who do not consider that they have had a satisfactory response to their disclosure should write to the Chairman of the Corporate Governance Committee with the facts.

Safeguards:

Harassment or Victimization – Harassment or victimization for reporting concerns under this policy will not be tolerated.

Confidentiality – Every effort will be made to treat the reporter’s identity with appropriate regard for confidentiality. However under certain circumstances to assist with the investigation the individual’s identity may become known or needs to be revealed.

Anonymous Allegations – This policy encourages employees to put their names to allegations of malpractice as and investigation may not be possible unless the source of the information is identified. Concerns expressed anonymously will not be entertained.

Bad Faith Allegations – Allegations proven to have been made in bad faith or solely for personal interests will result in disciplinary action.

Media communication – Allegations should not be subject to any communication with the media by all parties. Such communications, if any, shall be handled by the Communication department of the Corporate Office of Rogers.

Disciplinary Action:

If the claim of questionable practice is substantiated and proved, appropriate disciplinary action will be taken against the responsible individual(s) (i.e. contravenants) up to and including termination of employment.

Review:

This document may be changed from time to time in line with current best practice statutory requirements, and to ensure that organizational needs are met. The latest version may be found on Rogers intranet.