Business Conduct Ethics - modec

QUESTION: I will be attendinga fund raiser for a candidate for localoffice. Is it OK to list my position atMODEC as long as I don’t use anyMODEC funds or resources?ANSWER: No. You may notreference MODEC in any way withyour personal political activities.Anti-Social ForcesOur StandardIn the countries where MODEC conductsbusiness, certain Anti-Social Forces(“ASFs”), such as gangs and similar groups,may be present. MODEC will never dealwith ASFs or allow them to influenceMODEC’s business or its commitment toethical conduct.QUESTION: I would like toinvite an elected official to speak atan upcoming company event. Wouldthat be a problem?ANSWER: You must get preapprovalfrom the appropriate memberof management before inviting anelected official or other Public Official toattend a company event. If the invitee isin the midst of a re-election campaign,the company event could be viewedas support for the campaign. Any food,drink, or transportation provided tothe invitee could be considered a gift.In either case, there would be limitsand reporting obligations that must becarefully followed.Additional Resourcesfor More InformationFor more information on lobbying and socialand political contributions, refer to the GroupSocial and Political Contributions Policy andthe Group Gifts and Hospitality Policy or talkto the appropriate member of managementor the Chief Compliance Officer.Our ResponsibilitiesAlways refuse requests or demands forhush money, a bodyguard fee, a requestfor negotiations, or any other similardemands from a member of an ASF or acompany closely affiliated with an ASF.Do not make “stop-gap” or one-timepayments as an interim solution tothreats or intimidation by an ASF.Notify your supervisor or theappropriate member of managementif you are intimidated or threatened byany person or group affiliated with anASF or similar group.Additional Resourcesfor More InformationFor more information on Anti-Social Forces,talk to the General Affairs Department ofMODEC, Inc.35