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 data subjects are informed of the fact that personal data is being collected and the purpose(s) for which such data is being collected.

    • take all reasonable steps to ensure that personal data within our possession is accurate and kept up to date where such data requires regular updating.

    • take appropriate security and organisational measures for the prevention of unauthorised access to, alteration of, disclosure of, accidental loss and destruction of the data in our control.

    • take all reasonable steps to ensure that any person employed by us is aware of and complies with the relevant security and organisational measures.

    • destroy, where the purpose for keeping personal data has lapsed, such data as soon as reasonably practicable.

    • erase or stop processing data kept for direct marketing at the request of the data subject.


    Shall endeavour not to:
     

    • collect personal data unless it is collected for a lawful purpose connected with our functions or activities.

    • process personal data unless we have obtained the express consent of the data subject.

    • process sensitive personal data unless the data subject has given his express consent to the processing of the personal data or has made the data public.

    • disclose personal data in any manner that is incompatible with the purposes for which such data has been collected.

    • transfer personal data to another country except with the written authorisation of the Data Protection Commissioner.

    • carry out a data matching procedure unless the data subject and the Commissioner have consented to the procedure being carried out.


    Approved by the Board of Rogers and Company Limited on 03 December 2010.
     

    For the purposes of this Data Protection Policy:
     

    • “Data controllers” and “data processors” refer to any entity which processes personal data;

    • "data subject" means a living individual who is the subject of personal data;

    • “Personal data” means data which relate to an individual who can be identified from such data, including the name, address, telephone number and email address of such individual;

    • “Processing” means any operation which is performed on data, including the collecting, using, storing or destroying of such data; and

    • “Sensitive personal data” means information concerning racial or ethnic origin, political opinion or adherence, religious belief, membership to a trade union, physical or mental health, sexual preferences or practices, or the commission or alleged commission of an offence or any proceedings related thereto.