Policies

  • Equal Opportunities Policy

    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:

    1. Age

    2. Race (including ethnic origin, colour, caste, creed, nationality and national origin)

    3. Gender (including sex, pregnancy and maternity, marital, partnership and family status);

    4. Sexual orientation

    5. Impairment (physical and/or mental impairment, and diseases including AIDS) ;

    6. Religion/ belief or non-belief

    7. 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:

    1. The Human Resource function endorses these practices in its daily operation.

    2. Rogers purports that the above implied practices are in place and consequently known to its employees and prospective recruits.

    3. The existing HR procedures cater for proper communication and feedback mechanism including purported discrimination against any individual or group of individuals.

    4. In the event of complaints and grievances, the usual corporate process will be triggered and the matter dealt with accordingly.


    Approved by the Board of Rogers and Company Limited on 14 May 2014.

  • Malpractice Reporting Policy

    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:

    1. 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.

    2. 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.
     

    Approved by the Board of Rogers and Company Limited on 15 September 2010.

     

  • Data Protection Policy

    We, the data controllers and data processors of the Rogers Group:


    Shall endeavour to:
     

    • Ensure that we are duly registered as controllers and/or processors with the Data Protection Commissioner.

    • Ensure that personal data is:

    1. processed lawfully, fairly and in a transparent manner;

    2. collected for explicit, specified and legitimate purposes;

    3. adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;

    4. accurate and, where necessary, kept up to date;

    5. kept in a form which permits identification of data subjects; and

    6. processed in accordance with the rights of data subjects.

    • Inform data subjects of all relevant matters relating to the collection of their personal data, including the purpose for which the data is being collected and the period for which the data will be stored.

    • Adopt policies and implement appropriate technical and organisational measures so as to ensure that the processing of personal data is performed in accordance applicable data protection legislation.

    • Maintain a record of all processing operations under our responsibility.

    • On the written request of a data subject, provide confirmation to him as to whether or not personal data relating to him is being processed and forward to him a copy of the data.

    • On being informed of the inaccuracy of personal data by a data subject to whom such data pertains, cause the data to be rectified without undue delay.

    • Destroy, as soon as reasonably practicable, personal data where the purpose for which the data was collected has lapsed.

    • Notify the Data Protection Commissioner and the relevant data subjects, where applicable, of any personal data breach in a timely manner.

    • Where processing operations are likely to result in a high risk to the rights and freedoms of data subjects, carry out, prior to the processing, an assessment of the impact of the envisaged processing operations on the protection of personal data.


    Shall endeavour not to:
     

    • Collect personal data unless: (a) it is done for a lawful purpose connected with one of our functions or activities; and (b) the collection of the data is necessary for that purpose.

    • Process personal data unless:

    1. the data subject consents to the processing; or

    2. the processing is necessary:

            (a) for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject before entering into a contract;

            (b) for compliance with any legal obligation to which we are subject;

            (c) 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 the rights and freedoms or legitimate interests of the data subject; or

            (d) for such other purpose as may be authorised by law.

    • Process the personal data of a data subject who has objected in writing to such processing unless we demonstrate compelling legitimate grounds for the processing which override the data subject’s interests, rights and freedoms or for the establishment, exercise or defence of a legal claim.

    • Process the personal data of a child below the age of 16 years unless consent is given by the child’s parent or guardian.

    • Not transfer personal data to another country:

    1. unless we have provided to the Data Protection Commissioner proof of appropriate safeguards with respect to the protection of the personal data;

    2. unless the data subject has given explicit consent to the proposed transfer;

    3. the transfer is necessary for the performance of a contract between us and the data subject or the implementation of pre-contractual measures taken at the data subject’s request; or

    4. in such other circumstances as may be allowed by law.

    • Without lawful excuse, disclose personal data in any manner that is incompatible with the purpose for which such data has been collected.


    Approved by the Board of Rogers and Company Limited on 13 September 2018.
     

     

     

  • The Information, Information Technology & Information Security policy

    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

     

    Approved by the Board of Rogers and Company Limited on 13 September 2018.

     
    Rogers Group Information Security and Technology Policy Manual
  • Code of Ethics

    This Code of Ethics is to guide all our directors and employees on ethical standards.

     

    We are committed to conduct our business according to the highest ethical standards in line with the confidence and trust of our stakeholders.

     

    Our directors and employees shall assume responsibility for their conduct to protect and build Rogers’ reputation, brand image and values.

     

    I am confident that each of us will uphold the engagement embodied in this Code of Ethics. Together, we will all be able to sustain our Group’s growth and values for our shareholders and the community at large.

    Code of Ethics
  • Data Protection Notice
    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.

    Data Protection Notice
  • Board Charter