Governance, Ethics and Compliance

At Modine, strong corporate governance and a companywide commitment to integrity, honesty and transparency set the foundation for our success. Our Board of Directors and management team champion accountability in overseeing our organizational structure and operations. Together, we hold ourselves to the highest ethical standards and continuously improve our processes and programs to address ever-evolving issues, regulations and best practices.

Code of Conduct and Global Policies

We pride ourselves on operating professionally, with respect and integrity, and in full compliance with the law. That begins with living up to the standards set forth in our Code of Conduct. The Code is our commitment to conducting ourselves in an ethical manner and promptly raising and reporting suspected ethical concerns so that we can maintain our culture of compliance. To reinforce the importance of always operating in an ethical manner, Modine requires each salaried employee to review and acknowledge our Code of Conduct on an annual basis.

To supplement our Code of Conduct, we maintain additional Global Policies covering topics such as anti-corruption, anti-fraud, conflicts of interest, data protection, fair competition, gifts and entertainment, insider trading and trade compliance. All Global Policies are publicly available in 11 languages.

Encouraging a Speak-Up Culture

We partner with an independent company, NAVEX Global Inc., to operate our Helpline through their EthicsPoint incident management platform. Modine employees, customers, suppliers and other stakeholders can use the Helpline to anonymously disclose ethical or legal violations or concerns to a third party without fear of identification or retribution. NAVEX Global then collects and reports this information directly to our Business Ethics Committee. Through the operation of the Modine Helpline, we align our protocols with the U.S. Department of Justice (DOJ) guidance and the E.U. Whistleblower Directive on ethics and compliance whistleblower reporting.

Training Reinforces Accountability and Integrity

A robust training program supports effective awareness and understanding of our Code of Conduct and Global Policies. We offer annual Code of Conduct training for all employees, and our Business Ethics Committee also develops a revolving curriculum of four courses on various ethics-related content. Through our reminders and escalation process, we consistently achieve a nearly 100% completion rate for our courses. At our manufacturing sites, plant managers lead ethics training courses with frontline staff to ensure our messaging is disseminated to all employees whether or not they have computer access at work.