Business Conduct Ethics - modec

Accurate Books and RecordsOur StandardMODEC prepares financial statements thataccurately reflect the status of its operatingactivities. Investors, government authorities,and others need to be able to rely on theaccuracy and completeness of our businessrecords. Accurate information is alsoessential within MODEC so that we can makegood decisions.We are committed to transparency andto making full, accurate, timely, andunderstandable disclosure on all aspects of ourbusiness, including financial reports that arefiled with or submitted to regulatory authorities.Employees with a role in the preparation of ourpublic, financial, and regulatory disclosures havea special responsibility in this area, but all of uscontribute to the process of recording businessresults and maintaining documents. Each ofus is responsible for helping to ensure theinformation we record is accurate and completeand maintained consistent with our system ofinternal controls.MODEC’s corporate records, including paperdocuments, computer files, electronicinformation, and any other records, areimportant MODEC assets. MODEC is requiredby law in many jurisdictions to maintaincertain types of corporate records for aspecified period of time.Our ResponsibilitiesNever make false claims on an expensereport or time sheet.Always be accurate, complete, andtruthful when submitting financial orenvironmental records and productionand quality reports.Make sure that financial entries are clearand complete. Do not hide or disguise thetrue nature of any transaction.Be as clear, concise, truthful, andaccurate as possible when recording anyinformation. Avoid exaggeration, colorfullanguage, guesswork, legal conclusions,and derogatory characterizations ofpeople and their motives.Only sign documents, includingcontracts, that you are authorized tosign and that you believe are accurateand truthful.Never record or approve back-dating,false or misleading entries, unrecordedfunds or assets, or payments withoutappropriate supporting documentation.Maintain all corporate records forlegally required minimum periods andin accordance with the Company’sdocument retention procedures.Ensure that all payment arrangementscomply with MODEC’s accountingpolicies and procedures, includingexpense approval procedures.QUESTION: At the end ofthe last quarter reporting period,my supervisor asked me to recordadditional expenses even though Ihadn’t received the invoices from thesupplier and the work hadn’t started. Iagreed to do it, mostly because I didn’tthink it really made a difference sincewe were all sure that the work wouldbe completed in the next quarter. NowI wonder if I did the right thing.ANSWER: No, you did not. Costsmust be recorded in the period in whichthey are incurred. The work was notstarted, and the costs were not incurredby the date you recorded the transaction.It was therefore a misrepresentationand, depending on the circumstances,could amount to fraud.23