Anti-boycott laws and regulations mayprohibit MODEC or MODEC Employeesfrom participating in or cooperating withcertain boycotts of a party or country.Anti-money LaunderingMoney laundering is a global problem withfar-reaching and serious consequences.It is defined as the process of convertingillegal proceeds so that funds are madeto appear legitimate, and it is not limitedto cash transactions. Involvement in suchactivities undermines our integrity, damagesour reputation, and can expose MODECand individuals to severe sanctions. Manyof these laws and regulations also requirereporting of suspicious transactions andactivities to government agencies.Employees must comply with all applicableanti-money laundering and anti-terrorismrequirements, which prohibit:Engaging in any financial transactionsinvolving property, funds, or monetaryinstruments which, directly or indirectly,promote or result from criminal activity;Receiving, transferring, transporting,retaining, using, structuring, diverting,or hiding the proceeds of any criminalactivity, or aiding or abetting another inany such action; orEngaging or becoming involved infinancing, supporting, or otherwisesponsoring, facilitating, or assisting anyterrorist person, activity, or organization.QUESTION: As part of a bidinvitation, I recently received arequest to support a trade boycott.What should I do?ANSWER: You should contactyour supervisor or your ProcurementManagement Representative.Sometimes such requests are notobvious, but they may, for example,include agreements to refuse to dobusiness with or in a specific countryor with blacklisted companies or tofurnish information about businessrelationships with or in a specificcountry or with blacklisted companies.In other cases, they may includeagreements to discriminate based onrace, religion, sex, national origin, ornationality.Our ResponsibilitiesMaintain appropriate import, export,and customs records at each MODECbusiness location.Seek guidance from your ProcurementManagement Representative toensure that shipments of information,technology, products, or software acrossborders comply with laws governingimports and exports.Additional Resourcesfor More InformationFor more information on internationaltrade and anti-money laundering, talkto your supervisor, your ProcurementManagement Representative, or the ChiefCompliance Officer.38
When all is said and done,it is wr ng to:Falsify recordsEngage in fraudEngage in criminal activityAccept or give a bribeMake a facilitation paymentViolate or abuse employerpoliciesRemove employer propertyfrom the premises withoutauthorizationSteal or attempt to stealemployer or employeepropertyBe habitually tardy or absentBe under the influence ofintoxicating substances onemployer property at anytimeBe insubordinateUse or abuse employertime, property, materialsor equipment withoutauthorizationUse offensive language oncompany premisesHarass or discriminate againstothersBring dangerous orunauthorized weapons ontoemployer premisesBe absent from work withoutauthorization during scheduledwork hoursNeglect job dutiesBring the organization intoserious disreputeFail to report a violation ofcompany policy or lawFail to cooperate with thecompany in an internalinvestigationFail to stop violations by thoseworking under the EmployeessupervisionRetaliate against Employees forreporting actual or suspectedviolations of MODEC policies orthis Code.This is not meant to be an all-inclusive list. For more information,talk to your supervisor or the appropriate member of management.39