Business Conduct Ethics - modec

Legal HoldsDocuments should only be destroyed inaccordance with the applicable MODECdocument retention procedures andnever in response to or in anticipationof an investigation or audit. Contact yoursupervisor if there is any doubt about theappropriateness of document destructionor the content of the applicable documentretention policy.A legal hold suspends all documentdestruction procedures in order topreserve appropriate records underspecial circumstances, such as litigationor government investigations. MODEC willdetermine and identify what types of recordsor documents are required to be placedunder a legal hold. Every Employee, agent,and contractor must comply with this policy.If there is any question as to whether arecord pertains to an investigation or legalproceeding or may be responsive to asubpoena, contact the Chief ComplianceOfficer before disposing of the potentiallyresponsive document. Note that recordsinclude not just documents, but also includetapes, photographs, computer files, andrecords in any other form.Additional Resourcesfor More InformationFor more information on accurate books andrecords, refer to MODEC accounting policiesand procedures or talk to your accounting/finance controller.Communicating withthe PublicOur StandardWe are committed to transparency in ourdisclosures and public communications.As a company, we need a clear, consistentvoice when providing information to thepublic and the media. For this reason, itis important that only authorized personsspeak on behalf of MODEC. Never give theimpression that you are speaking on behalfof MODEC in any communication that maybecome public if you are not authorized todo so.Requests for information from any memberof the press or other news media (includingbloggers) must be referred immediately tothe appropriate member of management.Our ResponsibilitiesOnly Employees specifically authorizedto communicate with investors, analysts,or the media may respond to or engagewith these parties.If you receive an inquiry regardingMODEC’s activities, results, plans, or itsposition on public issues and are notspecifically authorized to respond, referthe request to the appropriate memberof management.If you intend to write or publish abook, article, or manuscript or deliver apresentation which relates in any wayto our business, you must receive priorapproval of your supervisor and theGeneral Affairs Department of MODEC,Inc. If the publication or presentationidentifies you as an Employee, it muststate that: ‘The views expressed in thisarticle/presentation are mine and do notnecessarily reflect the views of MODEC.24