Business Conduct Ethics - modec

Lobbying and ContributionsOur StandardAs a responsible corporate citizen, werespect your right to voluntarily participatein your community and in the politicalprocess, including making your ownpersonal social and political contributions.However, due to complex finance and ethicslaws, there are specific guidelines thatmust be followed before lobbying, makingcontributions on behalf of MODEC, orcampaigning for or holding public office.Social ContributionsSocial contributions means anythingof value that is provided to supportcharitable activities, including charitabledonations, funding, scholarships,internships, sponsorships, andparticipation in social programs.Political ContributionsPolitical contributions means anythingof value provided to any individual ororganization for the purpose of promoting,supporting, or influencing any politicalprocess, political organization, or electionfor public office at any level.MODEC generally prohibits the use ofMODEC corporate funds or resources forlobbying or political contributions. MODECprohibits social and political contributionsfrom being made for the improper purposeof obtaining or retaining business orotherwise securing a business advantagefor MODEC. All social and politicalcontributions must comply with applicablelaws and regulations and MODEC policiesand procedures.Employees may participate in politicalactivities in their personal time and at theirown expense. You must always make it clearthat your views and actions are your ownand not those of MODEC.Our ResponsibilitiesTake steps to ensure that your individualpolitical opinions and activities are notviewed as those of MODEC.Committing to any corporate politicalspending or use of MODEC resources forpolitical purposes is prohibited.Never pressure another Employee,client or business partner to contributeto, support, or oppose any politicalcandidate or party.Prior notice must be given to theappropriate member of managementbefore committing to campaign for, seek,or accept appointment to public office.Holding or campaigning for political officemust not create, or appear to create, aconflict of interest with your duties.Never make a political or charitablecontribution with the intent toimproperly influence someone.34