Business Conduct Ethics - modec

Any person exercising legislative,administrative, judicial, executive, orregulatory functions for or pertaining togovernment (including any independentregulator);Any political party official, officer,employee, or other person acting for oron behalf of a political party; andAny candidate for public office (even ifnot currently in office).Employees and third parties acting onMODEC’s behalf are also prohibited fromsoliciting, demanding, requesting, agreeing toreceive, or accepting anything of value withthe intent of being influenced or rewarded inconnection with MODEC’s business.Third Party Intermediaries andBusiness PartnersMODEC may be liable for corrupt activitiesof third parties –such as agents, consultants,intermediaries, and business partners – ifthey act improperly on MODEC’s behalf.Employees must ensure that MODEC’s thirdparties do not make illegal or improperbribes. Employees must not deliberatelyignore circumstances that should reasonablyalert them to a high probability of improperconduct or unlawful actions and should notpay any third party knowing that the fundswill be used improperly.We will only pay third parties with whomMODEC has a formal written agreement andfrom whom MODEC has an invoice detailingthe amount to be paid. Employees mustensure that such invoices properly identifycommissions. Third parties may only be paidfair market value for services provided.Bribes of any kind given to any person arestrictly prohibited. This includes paymentsor offers to assist MODEC in obtainingor retaining business, to influence anyofficial act or decision, or to secure anyimproper business advantage. We mustbe careful to avoid even the appearanceof offering or accepting an improperpayment, bribe, or kickback.Facilitating PaymentsMODEC prohibits facilitating payments tobe made in connection with its operations. 1Facilitating payments, sometimes known as“grease payments”, are typically small, customarypayments to lower-level Public Officials toexpedite or secure the performance of certainnon-discretionary, routine, governmentaladministrative actions.Our ResponsibilitiesDo not offer, give, make payment,promise to pay, or authorize bribesor kickbacks directly or indirectly toanyone to get or keep business orto influence a business decision onMODEC’s behalf. This includes anyPublic Official, government entity, orprivate person with the intention ofcorrupt influence.Never maintain “off-book” accounts inorder to facilitate or conceal improperpayments. All expenditures and anyother payments must be accuratelypresented in our books and records.Payments that are intended to improperlyinfluence anyone, including a PublicOfficial, must never be made. Remember,Public Official includes employees oforganizations that are owned in whole orin part by a government.1See Group Anti-Corruption Compliance Policy for exceptional circumstances when a facilitation payment ismade under duress, such as when your health or safety is at risk.31