Code of Business Conduct:

At Modis, we strive every day to earn the trust and loyalty of our associates,

customers, suppliers, colleagues, investors, governments and the communities in which

we work by bringing our Core Values of Team Spirit, Customer Focus, Passion,

Responsibility and Entrepreneurship.

Maintaining our strong reputation requires a clear communication of policy, effective

ways to detect potential violations, good leadership and personal responsibility.

The Modis Code of Business Conduct emphasizes both the individual’s responsibility

to act with integrity and Modis leaders’ responsibility to create a culture of compliance

in which employees and others can exercise sound judgment and feel comfortable

about raising concerns without fear of retaliation.

Integrity and compliance are core principles at Modis. How we conduct ourselves day

to day – with each other, our clients and our competitors – is the foundation of our

reputation as an ethical company. That’s why we do everything we can to protect our

reputation by making sure our actions and policies are not only legal, but in line with the

highest levels of business ethics and personal integrity.

Modis's Office of Compliance & Business Ethics implements and oversees legal

compliance and comprehensive business ethics programs to assure that Modis's

commitment to legal Compliance and Business Ethics is fully understood and embraced

by all Modis colleagues.

We foster an environment of open, honest communication, and we encourage all

employees to raise their questions or concerns and to report suspected violations of law

or company policy without fear of retaliation. We encourage you to contact us

because no one has better insight into what is happening within Modis than our

people.