Business Conduct Ethics - modec

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Code ofBusinessConductandE t h i c sAvoiding Conflicts of InterestConflicts of InterestOur StandardWe do not allow personal interests to affectthe integrity of MODEC, interfere with ourability to exercise independent judgment,or limit our ability to engage in businesson behalf of MODEC. A conflict of interesthappens whenever you have a competinginterest that may interfere with your abilityto make an objective decision for MODEC.For example, personal involvement with asupplier, competitor, or a contractor couldaffect your ability to exercise good judgmenton behalf of MODEC.Each of us is expected to avoid situationsthat can lead to even the appearance of aconflict. Conflicts of interest can underminethe trust others place in us and damage ourreputation. Individuals have a responsibilityto report any potential conflicts of interestto their supervisor.It is impossible to describe every potentialconflict of interest, which is why weemphasize the importance of askingquestions. When in doubt, even if yourparticipation in an activity gives an appearanceof a conflict of interest, you should disclose.Our ResponsibilitiesSelf-Dealing and CorporateOpportunitiesNever take advantage of business orinvestment information that is gainedthrough the course of your business dutieswith MODEC.Outside EmploymentA conflict of interest may arise if outsidework, including self-employment, interfereswith your ability to fulfill your MODECresponsibilities, if there is a risk that theoutside employment may cause you to26
disclose our confidential information, or ifthe activity could adversely affect MODEC’sreputation. You must disclose any outsideemployment you have by a MODEC businesspartner or competitor, including serving as adirector, officer, consultant, or contractor, toyour supervisor or the appropriate memberof management.Investment/Ownership InterestsCertain investments and ownership interestsare restricted. For example, if you or afamily member (i.e. child or relative) has aninvestment in or any financial involvementwith any MODEC business partner, includingcustomers, contractors, suppliers, orcompetitors, unless the business partneris a publicly traded company and theshareholding is less than 2% of theoutstanding shares, it could be a conflict.Such investment or ownership interestmust be reported to your supervisor or theappropriate member of management.Family/Relative BusinessRelationshipsIf you or a family member (i.e. child orrelative) is an employee, contractor, owner,or major shareholder of a competitor,supplier, client, or other third party or entitydoing business with MODEC, you mustdisclose the relationship to your supervisoror the appropriate member of management.Participating in Civic andCharitable OrganizationsParticipation in community activities shouldnot adversely affect your job performance,be detrimental to MODEC’s interests, or placeyou in the position of serving conflictinginterests. Involvement in activities thatconflict with, or appear to conflict with, yourjob or MODEC’s interests must be disclosed.Receipt of Fees or Items fromMODEC Business PartnersReceipt of fees, commissions, gifts,hospitality or other compensation from aMODEC business partner in your personalcapacity or as a MODEC Employee mustbe disclosed. In such instances, you alsomust comply with the requirements ofMODEC policies and restrictions on giftsand hospitality that may be accepted andpre-approval requirements.Public OfficialsBusiness relationships with Public Officialsand government entities must be reviewedwith care and due diligence. If you or afamily member (i.e. child or relative) is orhas been a Public Official, is or has beenemployed by a government entity, or iscurrently running for public office, you mustdisclose this relationship to your supervisoror the appropriate member of management.Circumstances can change and newconflicts can surface over time. It isimportant to reassess your situation fromtime to time and discuss any potentialconflicts with your supervisor or theappropriate member of management.QUESTION: My sister owns a cateringbusiness and would like to submit a bid to MODEC.Is she allowed to do so?ANSWER: Yes, your sister is welcome to submita bid through the usual MODEC channels if shemeets our qualifications, just like any other potentialvendor. However, under no circumstances shouldyou share information with her about the selectionprocess. If your sister submits a bid, you shoulddisclose the situation to your supervisor. If youhave any responsibility in procuring these services,you must excuse yourself and should have noinvolvement in the review or selection processes.27
Page 1 and 2: Code ofBusinessConductandEthicsLead
Page 3 and 4: A Message from OurPresident & CEOSi
Page 5 and 6: Accurate Books and Records 23Legal
Page 7 and 8: and regulations, but also with ethi
Page 9 and 10: Code ofBusinessConductandE t h i c
Page 11 and 12: authority to any individual who you
Page 13 and 14: Code ofBusinessConductandE t h i c
Page 15 and 16: The most common form of harassment
Page 17 and 18: cooperation of all employees. MODEC
Page 19 and 20: Policy, the Global Human ResourcesP
Page 21 and 22: images or text; any materials promo
Page 23 and 24: Intellectual PropertyWe have an obl
Page 25 and 26: Accurate Books and RecordsOur Stand
Page 27: Using social mediaWe must be especi
Page 31 and 32: Insider TradingOur StandardConfiden
Page 33 and 34: Any person exercising legislative,a
Page 35 and 36: or threatened by such a government
Page 37 and 38: QUESTION: I will be attendinga fund
Page 39 and 40: MODEC plans) that might change the
Page 41 and 42: When all is said and done,it is wr

Business Conduct Ethics - modec

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