Code of Ethics

This statement of our anti-corruption policy has been drafted to underline MODUS SA’s position on corruption and to provide information and guidance on identifying and addressing such phenomena. Corruption can be defined as a misappropriation of cranked power for personal gain. Benefits may be money and / or non-cash. It can take many forms. Finding such incidents is not always easy. It is essential that everyone contributes to the fight against such phenomena.

This policy is not intended to prohibit hospitality and / or entertainment practices that are proportionate, properly recorded and legal in the jurisdiction in which they take place. Practices that aim to create and / or strengthen relationships and promote the goals of MODUS SA must be transparent and do not create any expectation for the recipient to repay, either through the act or the omission of acts, any another action in return.

Each member of the Board, each MODUS SA employee and partner must oppose bribery and corruption and inform the administration of suspicious occurrences of such phenomena. Our partners and third parties can frankly report, without causing any adverse consequences for them, bribery and corruption incidents related to MODUS SA’s action in its administration.

The purpose of MODUS SA is to enhance transparency and for this reason management will investigate all reports. Petitions should be conducted honestly and in good faith under this policy on suspicious occurrences, even if these suspicions eventually prove to be false.

MODUS SA reserves the right to legal action, claiming any positive and consequential damages and non-material damage that may be caused to it due to fraudulent, false and misleading reporting of bribery and corruption cases.