Business Conduct Guidelines

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CEO message to employees

Dear fellow employees:

The Rogers Group of Companies is firmly committed to maintaining its long-standing reputation for the highest standards of integrity, ethical behaviour and good corporate citizenship. It is a reputation each of you has helped to build and for which we can all be very proud.

Safeguarding our reputation requires steadfast compliance with the highest standards of business conduct and all applicable laws and regulations, on the part of all Rogers employees, in everything we do. The Rogers Business Conduct Policy (HR 1.1) is an important document in helping to define those standards. Accordingly, you should consult the Rogers Business Conduct Policy whenever you need direction on issues of business conduct or ethical behaviour.

This policy, however, is not intended to substitute for your responsibility to exercise good judgment. Nor is it designed to address every situation, or serve as the sole guideline on matters of business conduct. Your Manager/Supervisor and/or local Human Resources representative should also be consulted, as appropriate.

Furthermore, there are several other Rogers policies, practices, instructions and legal standards of conduct to which employees are also expected to adhere, many of which are listed for your reference, in this policy.

On behalf of the Rogers Board of Directors and the Presidents of the Rogers Group of Companies, I would like to thank you for your commitment to maintaining the highest standards of integrity and ethical behaviour at Rogers. It is both appreciated and expected of all Rogers employees.

Nadir Mohamed
President and Chief Executive Officer
Rogers Communications Inc.

SCOPE

This Policy establishes the position of Rogers Communications Inc. ("RCI") and its subsidiaries (collectively referred to as "Rogers" or the "Company") with respect to business conduct. This Policy has been adopted to:

• Endorse and promote the Company's commitment to honest and ethical behaviour, including fair dealing and ethical handling of potential and actual conflicts of interest;
• Promote full, fair, accurate, timely and understandable disclosure;
• Promote compliance with applicable laws and governmental rules and regulations;
• Ensure the protection of the Company's legitimate business interests, including corporate opportunities, use of corporate assets and confidential information; and
• Deter wrongdoing.

The Company is dedicated to maintaining its reputation for integrity, ethical behaviour and good corporate citizenship, and expects all employees to abide by basic principles of ethical and lawful business conduct. The Business Conduct Policy outlines the standards expected of Company employees (see Policy HR 2.2 - Employment Classification for definition of employees) in their dealings with the Company, customers, clients, vendors, contractors, volunteers, the public and fellow employees. Employees are expected to be familiar with the Policy and to adhere to those principles and procedures set out in the Policy.

Business groups or departments sometimes adopt policies or guidelines that apply only to employees in their specific area of work. Should these policies conflict in any way with the Business Conduct Policy, this Policy's requirements should be followed. However, the Business Conduct Policy is not intended to describe every law or policy that may apply to an employee.

If there is any conflict between this Policy and a collective agreement, the terms and provisions of the collective agreement shall apply to those employees who are included in the collective agreement.

If faced with a situation or ethical issue not explicitly covered in the Policy, it may help to ask the following questions:

• Is the action legal? Do not do anything illegal. If you are not sure of the answer, ask for help.
• Does the decision violate the letter or the spirit of the Policy? At Rogers, we do what is right.
• If the decision became public, could it be seen as the wrong decision? If you would be embarrassed by having your actions described in the newspaper or talked about on the news, then it's probably not the right choice.
• How would a customer, co-worker, friend and/or family member react if they became aware?

Employees are encouraged to consult with their managers/supervisors for guidance regarding the Business Conduct Policy, and as necessary an employee may also get help or advice from:

• The supervisor's supervisor
• The head of the department
• Your Human Resources Management Representative ("HR Manager")
• the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com (user name: rogers4u and company password: rogers1)

PURPOSE

The purpose of this Policy is to set out the Company's appropriate business conduct and related administrative requirements and procedures.

RESPONSIBILITY

It is the responsibility of:

1. The Chief Human Resources Officer or in his or her absence, the SVP General Counsel and Secretary or the SVP Finance and Chief Financial Officer, to:
   • Interpret this Policy, as required, and to ensure that it is implemented throughout the Company in a fair and even-handed manner;
   • Develop and implement an ongoing program for employee training and communicating to employees their responsibilities under the Business Conduct Policy;
   • Develop and implement a program for annual review and acknowledgement and acceptance of the Business Conduct Policy by employees of the Company;
   • Report individual significant violations of this Policy promptly, and to provide an annual summary of violations and their resolution, to senior management and designated Committees of the RCI Board;
   • Initiate any recommended revisions to this Policy for RCI Board approval.
2. The RCI Chief Executive Officer (or senior officer delegate) to authorize any recommended revisions or specific exceptions to this Policy, subject to submission to the RCI Board of Directors or designated Committees of the Board for its approval.
3. The RCI Board of Directors, or designated Committees of the Board, to consider, and if thought fit, to approve this Policy and any recommended revisions to this Policy, at a minimum annually and any specific exceptions to this Policy submitted by the RCI Chief Executive Officer (or Senior Officer delegate).
4. Management to maintain the Company's reputation for integrity, ethical behaviour and good corporate citizenship, and:
   • To ensure that employees receive the Business Conduct Policy when being offered a position with the Company and that employees endorse their understanding and acceptance of the Business Conduct Policy by signing the Non-Disclosure/Non-Solicitation and Intellectual Property Assignment Agreement (the "Agreement") (see Exhibit A) in duplicate at the time of hire, with the exception of Game Day Staff, who will be asked to sign the Employee Commitments Document;
   • To ensure that contractors and dealers are required to follow similar business conduct guidelines;
   • To create and maintain a work environment that sets an example of and encourages integrity and ethical behaviour. This includes ensuring that all employees have access to this Policy and that they understand and comply with its provisions and the spirit of the Policy; and
   • To ensure that all employees review the Business Conduct Policy annually and comply with the annual review process.
5. The Human Resources department to ensure the following are retained in each employee's personnel file:
   • One copy of the signed Agreement; and
   • Records of the annual employee review and acknowledgement of the Policy.
6. Employees (see Policy HR 2.2 - Employment Classification for definition of employees) to:
   • Consistently uphold their legal, fiduciary, and ethical responsibilities to act in the best interests of the Company and within the limits of all applicable laws and regulations;
   • As a condition of employment, to read and endorse their understanding and acceptance of the Business Conduct Policy, by signing the Agreement in duplicate at the time of hire, transfer and promotion;
   • Review and acknowledge their acceptance of the Business Conduct Policy on an annual basis, including completion of applicable training programs; and
   • Make prompt and full disclosure of any situation that violates or may be perceived by others, to violate the Business Conduct Policy.

POLICY

It is the policy of the Company that:

1. All employees shall sign the Agreement, as a condition of and prior to commencing employment.
2. All employees, other than designated hourly employees, will review and acknowledge their acceptance of the Business Conduct Policy on an annual basis. Game Day Employees will be asked to sign the Employee Commitments Document.
3. All employees who are transferred or promoted within the Company will be required to re-sign the Agreement as a condition of transfer and/or promotion. The hiring manager will ensure that a newly signed copy of the Agreement is forwarded to Human Resources to be included in the employee's file.
4. All employees shall be familiar with all Rogers policies that are relevant to the performance of their job duties.
5. Failure to adhere to any and all provisions of the Business Conduct Policy shall result in discipline, up to and including termination of employment and/or legal action.
6. All reported business conduct violations will be carefully investigated and handled consistently by management, regardless of the employee's status.

BUSINESS CONDUCT POLICY DETAILS

1. Contract and Commitment Guidelines

   Employees must ensure that all contracts and commitments have proper authorizations and documentation prior to making commitments on behalf of the Company. (Please see PUR 45 - Purchase and Commitment Guidelines).

2. Adherence to the Law

   Employees are personally responsible to comply with all laws and regulations applicable to the Company. Employees who are in doubt as to the legality of a proposed course of action or an action already taken should discuss the activity with their manager/supervisor. The manager/supervisor should consult with the Vice President/Director, Human Resources who, in turn, shall consult the Rogers Legal department (or approved external counsel), as required.

   Employees should not conduct business with suppliers and/or contractors who subscribe to unlawful or unethical business practices or behaviour. Promptly report unethical selling or purchasing practices on the part of a supplier or a Rogers employee to the employee's Manager and to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com.

3. Respect and Dignity in the Workplace

   The Company is committed to ensuring that all employees, vendors, business associates, volunteers, customers and the general public are treated with respect and dignity. The Company will not tolerate harassment and/or discriminatory acts or practices, by any of its employees. Please refer to Policy HR 2.4 - Workplace Harassment & Violence Prevention.

4. Fair Dealings

   The Company does not seek competitive advantages through illegal or unethical business practices or behaviour. Each employee should endeavour to deal fairly and ethically with the Company's customers, service providers, suppliers, competitors and employees. No employee should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any unfair or unethical dealing practice.

   Rules of competitive business conduct are established in the Competition Act and certain sections of the Telecommunications Act and the Broadcasting Act. All applicable practices must be carried out in compliance with these Acts. (Please see Policy LEG 18 - Competition Act).

   Employees must never disclose, communicate or discuss confidential information concerning the Company, including in particular pricing or purchasing policies with competitors. Information about competitors should be gathered in a lawful manner. Employees who previously worked for a competitor will not be requested to provide confidential information about said competitor.

5. Protection and Proper Use of Company Assets

   All employees are responsible for safeguarding, and making proper and efficient use of Company funds and property by following procedures to prevent their loss, theft and unauthorized use. Company funds and property include Company time, cash, cheques, charge cards, land and buildings, proprietary information and records, vehicles, equipment, intellectual property, information systems and all other property.

   Ways to protect Company funds and property include ensuring:

   • expenditures are for legitimate business purposes;
   • computer equipment and systems, and the information that they contain are protected against unauthorized access, use, modification, destruction, theft or loss;
   • use of telephones, email and the internet are only for legitimate business purposes;
   • upon termination of employment, employees must return all Company records and equipment.

   Employees must not borrow or make use of the Company's name, property, goodwill, funds, data or other assets for their personal gain or benefit, or for the gain or benefit of others which is not authorized to be done on behalf of the Company. The Company does not permit notices, messages or postings on behalf of any third parties or outside organizations without written permission from the Human Resources Department.

   The unauthorized connection and/or use of Company products and services are criminal acts. Any employee or contractor found to be connected to, or in possession of, unauthorized Company products and/or services, or to have assisted another to do so, will be subject to legal action.

   In the course of protecting Company assets, it is our duty to promptly report to Corporate Investigations or to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com all acts that may constitute real or suspected breaches of security.

6. Employment Practices

   The Company is committed to ensuring that equal opportunity exists for all employees in all aspects of employment, and the Company will continue to use the merit principle as the basis for all employment and promotion opportunities. (Please see Policy HR 2.1 - Diversity Management and HR 3.1 Recruitment and Selection).

7. Health and Safety

   All employees are responsible for performing their duties in a safe manner and for keeping themselves updated on all Company health and safety policies, procedures and directives. (Please see Policy GEN 25 - Health and Safety and the Health & Safety Standards on the Burbs).

8. Alcohol and Drugs

   The possession, consumption and/or the sale of illegal drugs and restricted substances is prohibited while on duty and/or while occupying any of the Company's premises, including company vehicles.

   Except under special circumstances, such as Company-sanctioned and sponsored events where prior approval has been obtained from the President of the business unit, or from the individual to whom the President has delegated this responsibility, the provision or consumption of alcohol is prohibited on the Company's premises. Approval may be granted taking into consideration the Company's reputation, image, responsibility and potential liability. It is each employee's responsibility to ensure that he or she behaves responsibly during attendance at a Company or vendor-sponsored event. The consumption of alcohol is strictly prohibited in Company vehicles.

   Drug or alcohol impairment while on duty or on the Company's premises or in Company vehicles is improper business conduct and will be treated as an extremely serious matter.

9. Environment

   The Company is committed to being an environmentally responsible corporate citizen. The Company will obey all environmental laws applicable in the jurisdictions in which it operates and each employee is expected to behave accordingly. Any contravention of environmental laws or the Company's environmental policy must be immediately reported to the senior executive of the respective operating company or business unit. An oral report must be promptly followed up with a written report. (Please see Policy GEN 30 - Environmental Policy).

10. Computer Access and Use of Electronic Media

    In order to protect access to systems, applications and data on the Company's computer systems, employees must ensure the protection of their own passwords. Users must not give out their passwords or allow others to use their user ids. (Please see Information Security Policies).

    Users of the Company's computer systems and/or the Internet should be aware that their communications are not protected from third party viewing unless approved encryption is used. Employees should not send information over the Internet if they consider it to be private.

    The Company reserves the right at any time to examine e-mail, computer records, personal file directories and other information stored on or transmitted over Company facilities to ensure compliance with internal policies, to support the performance of internal or external investigations, and to assist with the management of information systems. Employees should be aware that all e-mail is considered Company property and it is archived and can be retrieved for examination at any time, even after it has been deleted.

    Language and conduct during conversations, instant messaging and email exchanges does reflect on the Company. As such, a professional manner must be maintained at all times.

    Use of Company facilities to download, communicate or exchange materials that conflict with the Company's policies is prohibited. Personal use of Company facilities is allowed under certain conditions as outlined in Policy ISEC 2 Acceptable Use of Electronics Communications Policy. Compliance with Policy ISEC 2 is mandatory. Failure to comply may result in disciplinary action being taken, up to and including termination.

    (Please see Policy ISEC 2 Acceptable Use of Electronics Communications Policy for a complete list of unacceptable practices and employee guidelines).

11. Work Performance

    The Company expects all employees to be held accountable for the results of their work, based on the factors of honesty, quality, timeliness, efficiency, safety and continuous improvement. Managers are expected to provide leadership that reinforces these factors, and that ensures that the actions of all employees are in the Company's best interests. Employees are to abide by regular working hours per the applicable operating and/or departmental procedures. (Please see Policy HR 3.4 - Hours of Work, Overtime and Premium Pay for details).

12. Full Commitment to the Company

    Employees must remain free of any outside business interests or relationships that could interfere with the performance of their job duties (including their availability to work overtime, as required).

    Any employee considering serving on a board of directors or an advisory board or similar body of any outside company must obtain approval from the Executive Leadership Team ("ELT") member to whom he/she reports (and only for profit-oriented companies).

    Before accepting any position as a member of a board, advisory council or other similar committee of a profit organization, or major non-profit or charitable organization, senior officers of the Company must obtain advance approval from the Corporate Governance Committee of the RCI Board, unless they are required in their capacity at Rogers to act as a Company representative on that Board for the Company. Refer to Policy LEG 16 Senior Officers of RCI Accepting Directorships with Non-Affiliated Corporations.

    Any employee serving on any board or similar body as a Rogers representative will not receive compensation of any kind, directly or indirectly, for such services. Any employee serving on any board or similar body in a personal capacity will not be reimbursed by Rogers, directly or indirectly, for any expenses related to such activity.

13. Conflict of Interest

    A "conflict of interest" occurs when an individual's private or personal interests interfere, or may appear to interfere, with the interests of the Company. A conflict of interest can arise when an employee takes actions or has interests that may make it difficult to perform his or her Company work objectively and effectively.

    Employees must avoid activities or situations that involve real or perceived conflicts of interest with the Company. Employees must disclose potential conflicts of interest or any relationships that could reasonably be expected to give rise to a conflict of interest to their Manager or to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com.

    Conflicts of interest include but are not limited to the following:

    Personal Financial Interest

    • The transaction of business by the Company with an enterprise where an employee and/or any member of an employee's family together have an ownership interest in the enterprise and/or its affiliates that is material to the employee and/or the employee's family or that is more than a 5% interest in the enterprise and/or its affiliates;
    • An employee having financial interest in, performing services for, or undertaking any activity (whether commercial or non-commercial and/or for which there is no personal financial interest) for a competitor of the Company.

    Entertainment, Hospitality, Gifts, Favours or Bribes

    Accepting or providing entertainment, hospitality, gifts or favours that may reasonably be considered to have an influence on a decision by an individual on behalf of the Company, or that may be outside of the normal course of a business relationship, constitutes a conflict of interest. Any entertainment, hospitality, gift or favour made or received by a Company employee to procure an action or decision, or to recognize or reward an action or decision is prohibited. All employees transacting business for the Company should act and should be perceived by others to act, in the Company's best interest and free of any conflicts of interest. Modest favours, gifts, entertainment or hospitality may be furnished or accepted by employees in connection with their duties provided that the following criteria are met:

    • they are in the course of a normal business relationship and are consistent with accepted business practice;
    • they are not in cash or securities;
    • they are of sufficiently limited value so as not to be capable of being perceived or construed as an inducement, bribe, pay-off or other improper payment or endorsement;
    • they are not repetitive or frequent;
    • they do not contravene any law and are made in accordance with generally accepted ethical standards and behaviour, and;
    • the employee informs his/her manager or supervisor.

    If an employee proposes to undertake personal transactions with a supplier to the Company it must be on the same terms that would be offered to other arm's length customers of the supplier, in order to avoid conflict of interest, and must be approved by the employee's manager or supervisor.

    Expenses incurred by employees for business travel and entertainment while performing their duties on behalf of the Company must be in accordance with Policy GEN 8 Business Travel and Expense Reimbursement.

Employment of Relatives

Relatives of an employee are defined as follows: parents, spouse (including common-law spouse and same-sex partner), grandparents, brothers, sisters, children, nephews, nieces, aunts, uncles and cousins (including foster, step and in-law relations).

Relatives of employees may only be hired through standard recruiting procedures and must meet the qualifications required for the position. Where an employee would directly or indirectly supervise, or be in a position to influence the career or contracted activities and rewards of a relative, such a conflict of interest must be brought to the attention of the Human Resources department immediately, and an appropriate course of action determined, including senior management approvals and by the RCI Board Compensation Committee where required under its policies.

14. Illegal Payment to Public Officials

    It is illegal and not permitted for public officials, at any level of government, to obtain money, property, entertainment, hospitality, gifts or favours from the Company by the wrongful use of their official position or as a condition to perform certain duties they are normally obligated to perform. If it comes to the attention of an employee that such payments were sought or made, this should be immediately reported to employee's supervisor and to the Company's STAR Hotline (1-877-355-STAR) or www.compliance-helpline.com.

15. Proper Maintenance of Records

    All transactions of the Company must be properly recorded and accounted for in the books of the Company. This is essential to the integrity of the Company's governance and financial reporting obligations. All Rogers employees are responsible for ensuring that false, inaccurate, or misleading entries are not made in our Company's accounting records, and full, fair, accurate, timely and understandable disclosure is made in all public communications.

    In preparing and maintaining Rogers books and records, employees should:

    • adhere to all applicable accepted accounting standards and practices, rules, regulations and controls;
    • ensure the accurate and timely recording of costs, sales, shipments, time sheets, vouchers, bills, payroll and benefit records, regulatory data, expense reports and other financial transactions in the proper accounts;
    • record all funds, assets and transactions and not establish any undisclosed or unrecorded fund or assets for any purpose;
    • keep and retain books and records which reflect fairly, accurately and in appropriate detail the Company's transactions, acquisition and disposal of assets and other relevant activities (see Company Policy SEC 4 Retention of Records);
    • sign only those documents that are accurate and truthful;
    • restrict access to sensitive or confidential information (such as financial records and customer information) to ensure the information is not accidentally or intentionally disclosed, modified, misused or destroyed, other than in accordance with the Company's document retention policies.
16. Political and Charitable Contributions

    All employees are encouraged and entitled to make political and charitable contributions from their personal time and funds in the exercise of responsible citizenship. Contributions of any kind to political organizations, made on behalf of the Company, must be approved, in advance, by the Vice President, Government Relations.

17. Confidentiality

    Employees doing work for the Company may have access to information of a confidential or proprietary nature, the improper disclosure of which could have serious consequences for the Company. Employees must maintain the confidentiality of all information entrusted to them, except when the disclosure is authorized or legally mandated.

    Extra sensitivity to security, confidentiality and conflict of interest is required in situations where an employee's spouse, immediate family member or friend is a principal of, or is employed by, a competitor or supplier of the Company.

    Customer Information

    Subject only to certain exceptions, the law requires the Company to provide customers with access to all personal information about them that the Company may hold. This includes records such as customer care logs and notes. Employees should avoid non-factual entries or inappropriate language or comments. All information kept by the Company about its customers is confidential and cannot be divulged or used, directly or indirectly, except for business purposes.

    Unless a customer provides explicit consent, or the Company is required to do so by law, the Company may not disclose a customer's confidential personal and business information to anyone other than:

    • the customer himself;
    • a person whom the Company reasonably believes is acting on behalf of the customer;
    • another company, for the purpose of providing the customer with efficient and cost-effective service, where the information is required only for that purpose and will be kept confidential (for example, the exchange of call detail information for the settlement of usage charges) or where the information is required only for that purpose of supplying telephone or telephone directory related services and will be kept confidential (for example, a firm retained by the Company to do installation work on its behalf);
    • an agent retained by the Company to evaluate the customer's credit worthiness or to collect the customer's account, where the information is required for and will be used only for, that purpose; and
    • a public authority, if there is imminent danger to life or property which could be avoided or minimized by disclosure of the information.

    The unlawful interception of a private communication is a criminal offence. An employee may intercept a private communication only when such interception is necessary for the purpose of providing service, to perform quality control checks in the course of service monitoring, to protect the company's rights or property or when authorized by law.

    Maintaining customer privacy is also crucial when dealing with contracts, proposals and quotations. An employee must be vigilant in ensuring that: unless a customer provides explicit consent, customer information is not shared with other affiliates or partners, agents or subsidiaries of our group, except with those affiliate or partners or agents or subsidiaries of a group, who are directly involved in the specific contract, proposals or quotations.

    Employee Information

    Employees may not release information, related to co-workers or other employees, on personnel matters including private phone numbers and addresses, medical records, or salary information unless required by law or by an authorized representative of the applicable employee.

    When such a request is made, it should be referred to the Human Resources department. No statements, interviews or access to records should be given until the Company or its legal counsel has the opportunity to review the request. The request may be legitimate but the Company has the right to determine the reasonableness of the request and to ensure that all responses are complete and accurate.

18. Intellectual Property Assignment

    From time to time, employees may author, make, create, and conceptualize intellectual property during the course of employment with the Company (whether or not during regular office hours, and whether or not at the employee's place of employment). This information and property is considered to be the exclusive property of the Company, if it arises from or is incidental to performance of duties as a Rogers employee, and must be treated as confidential information.

    For greater certainty, the foregoing shall not apply to freelance work and/or independent productions authored, created, conceptualized or made by employees entirely outside of the scope and mandate of the employee's employment and which do not relate in any way to the responsibilities and duties of employment with the Company.

    Please refer to Section B of Exhibit A.

19. Public Disclosure, Restricted Use of Confidential Information and Insider Trading

    The Company is committed to best practices in making timely and accurate disclosure of all material information. The Company will promptly disclose all material information in a full, fair, accurate, timely and understandable manner in accordance with applicable securities laws and policies, and stock exchange rules. All employees must perform their responsibilities with a view to giving effect to the foregoing commitment of the Company, including by reporting all material information in a timely manner to the appropriate person within the Company in accordance with the Company's disclosure policies and procedures.

    Each officer involved in the Company's disclosure process is required to be familiar with and comply with the Company's disclosure controls and procedures and internal control over financial reporting. In addition, each person having direct or supervisory authority regarding regulatory filings or the Company's other public communications should, to the extent appropriate within his or her area of responsibility, consult with other Company officers and employees. Each officer who is involved in the Company's disclosure process must:

    • familiarize himself or herself with the disclosure requirements applicable to the Company as well as the business and financial operations of the Company;
    • not knowingly misrepresent, or cause others to misrepresent, facts about the Company to others, whether within or outside the Company, including to the Company's independent auditors, government regulators and self-regulatory organizations; and
    • properly review and critically analyse proposed disclosure for accuracy and completeness (or, where appropriate, delegate this task to others).

    Public Statements

    Employees should not discuss prospective changes or developments with people outside the Company before an official announcement has been made. Specifically:

    • information on corporate developments, products and plans, including all financial and material information that may impact the value of Company securities or influence investor's investment decisions, will be released only by authorized Company spokespersons;
    • confidential information on specific operating companies will be released by the management of that business unit;
    • employees expressing opinions beyond the scope of their positions must clearly differentiate between speaking for themselves and speaking for the Company, to ensure that their views are in no way perceived to be associated with the Company. Company stationery must not be used for expressing personal views.

    Employees are not to answer inquiries from the press, legislative bodies or companies and organizations unless specifically authorized to do so. All such inquiries are to be referred to the designated individual within each operating company. The identity and means of referral to the designated spokesperson for each operating company will be communicated by the operating companies to their respective employees. For employees of RCI and Rogers Shared Operations (RSO) inquiries from reporters must be referred to the Vice President, Communications, RCI. (Please see policy LEG 17 - Disclosure and Insider Trading).

    Employees of all Rogers companies and business units are to refer inquiries from the press, media, research and security analysts, brokers, and investors to the Vice-President, Investor Relations, RCI. Unless specifically authorized to do so, employees are not permitted to contact the press, media, research and security analysts, brokers or investors about the Company's business.

    Employees who participate in any public forum as a Company employee must seek approval from the designated Vice President responsible for public relations regarding the content of any commentary or speeches, in order that it may be consistent with Company policy and not contain or refer to confidential information.

    Insider Trading

    Employees with knowledge of material confidential information about the Company are prohibited from trading securities of the Company until the information has been publicly disclosed and at least one trading day has passed. Employees must not inform ("tip") any person of material information before it has been publicly disclosed. Officers of the Company deemed to be insiders are required to file a report for every transaction in securities of the Company at www.sedi.ca. (Please see Policy LEG 17 - Disclosure and Insider Trading).

20. Brand Protection

    Any use of the Company's corporate symbols, signatures or logos must conform with the principles outlined in the Rogers Branding Guideline (or visit the Burbs at www.theburbs.com/brand), including the use of the Company's logo on letter head.

    Before Rogers allows others to use the Rogers name or brand as a trademark or service mark, approval must be obtained. To obtain approval for brand usage or if employees are uncertain about brand usage, consult the contacts at www.theburbs.com/brand.