Business Conduct Ethics - modec

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QUESTION: I have questions about theuse of third parties that may be ‘go-betweens’helping us with local government authorities.What should I do to make sure that they don’tget us into trouble?ANSWER: You’re right to be concerned.Control over intermediaries and other thirdparties who are operating on MODEC’s behalfis important. We must exercise due diligence toensure that their reputation, background, andabilities are appropriate and meet our ethicalstandards. Intermediaries are expected to actin accordance with the requirements set out inthis Code. As a general rule, we must never doanything through a third party that we are notallowed to do ourselves.QUESTION: Sometimes when I’mtravelling, I see practices that I would considerinappropriate, but they are common practicesin the country I’m visiting. Facilitating orgrease payments are an example. What shouldI do if I’m asked to provide what I considerto be a bribe but what the locals think of as acommon business courtesy?ANSWER: You should just say no and informthe person that your company’s policies prohibityou from making such payments. Remember, nomatter where you are, our policies apply. Youmust never provide a payment or anything ofvalue to gain an improper business advantage.QUESTION: What if I am threatened andforced to provide a cash payment to a PublicOfficial before I am allowed to exit the country?ANSWER: When a payment is extorted by aPublic Official by threat of imminent bodily harmto an Employee or member of the Employee’sfamily, the Employee may make the payment thatis demanded. Payment by any Employee of a safetypayment must be reported as soon as possible to theChief Compliance Officer. Without exception, anysuch safety payment must be reflected accurately inthe company’s books and records.Additional Resources forMore InformationFor more information on MODEC’s anti-corruptioncompliance policies and prohibition of bribes andfacilitating payments, refer to the Group Anti-Corruption Compliance Policy, the Group Third PartyIntermediary and <strong>Business</strong> Partner Policy, or talk tothe Chief Compliance Officer.Gifts and HospitalityOur StandardWhen handled properly, appropriate and reasonablegifts and hospitality (including meals,drinks, golf, and travel) can strengthenbusiness relationships. But whenabused, they can damageour reputation, harmour business, and mayeven be illegal. Giftsor hospitality may onlybe given if they arereasonable complements tobusiness relationships, are ofmodest value, and not against the law or the policyof the recipient’s company or country.While this area can be complicated, at MODEC oneprinciple is always clear: we do not give or acceptgifts or hospitality to any person, including any PublicOfficial, government entity, or commercial customer,if the intent is to improperly influence a businessdecision or the recipient. Such activities are prohibitedregardless of the value of the gift or hospitality.Gifts and Hospitality of Public OfficialsExtra care and caution needs to be taken whendealing with Public Officials. No gifts or other benefits,including entertainment, can be offered to PublicOfficials which could be considered as influencing anybusiness decision or to obtain improper advantage.Any request made to a MODEC Employee by a PublicOfficial for an improper payment, or any action taken32
or threatened by such a government official with the intent ofobtaining an improper payment, should be reported immediatelyto the appropriate member of management and the ChiefCompliance Officer.Payment or Reimbursement of TravelExpendituresTravel expenditures include airfare, lodging and associatedmeals, and transportation expenditures. Payment orreimbursement of travel expenditures, including thoseoffered or provided to Public Officials in connection withour operations, must comply with specific guidelines andpre-approval processes.Our ResponsibilitiesReview and understand the Group Gifts andHospitality Policy.Only give or accept modest gifts, hospitality, andentertainment according to the specific limits, guidelines,and pre-approval processes established in the Group Giftsand Hospitality Policy.Be particularly sensitive to gifts to or from individuals orentities that are subject to MODEC purchasing or businessdecisions.Do not request or solicit personal gifts, favors,entertainment, or services in connection with youremployment with MODEC.Never give or accept gifts of cash or cash equivalents.Understand and comply with the policies of the recipient’sorganization and national rules before offering a gift orentertainment.Never aid or abet a third party to give or receiveinappropriate gifts or entertainment.Additional Resources for More InformationFor more information on giving or accepting gifts and hospitality,refer to the Group Anti-Corruption Compliance Policy, the GroupGifts and Hospitality Policy, the Group Third Party Intermediaryand <strong>Business</strong> Partner Policy, or talk to your supervisor or theChief Compliance Officer.QUESTION: When I wastraveling, I received a gift from asupplier that may be consideredexcessive, but I’m not sure. Whatshould I do?ANSWER: If you received anygift which you think may exceedour limits, you should report itimmediately to your supervisor. Adetermination will then be made asto how the gift should be disposedof or used and what furthersteps, if any, are necessary. Thereport, including your supervisor’sdisposition decision, should beforwarded to the Chief ComplianceOfficer for tracking purposes.QUESTION: A businesspartner invited me to attend asporting event with him and sit inhis firm’s suite. Is it acceptable forme to go?ANSWER: It depends. Attendinga sporting event with a businesspartner may be an appropriatebusiness courtesy, as long as thevalue of the tickets is not exorbitant.Such an occasion often serves abusiness purpose by facilitatingwork-related discussions andrelationship building. However, inthis case, the tickets include accessto a restricted area and are likelyto have a high monetary value. Youshould discuss the matter with yoursupervisor and seek pre-approvalbefore accepting the invitation. Alsoremember that if the tickets were foryour personal use and the businesspartner wasn’t attending the eventwith you, in such a case the ticketswould be considered an unacceptablegift since there would be no businesspurpose for you to attend the event.33
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 and 28: Using social mediaWe must be especi
Page 29 and 30: disclose our confidential informati
Page 31 and 32: Insider TradingOur StandardConfiden
Page 33: Any person exercising legislative,a
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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