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POLICY for HUMAN RIGHTS

MODEC believes that respect for human rights is essential in all our global operations. MODEC values international human rights standards throughout the world. As one of a global company’s responsibilities and to ensure its continuity, we seek to develop diverse human resources with shared values. Through establishing labor standards, MODEC promotes a working environment in which every individual can achieve their full capability regardless of their race, national origin, religion, disability, color, pregnancy, age, military status, sex, or any other characteristic protected by applicable international/local law.

As applicable to our global business, MODEC respects human rights principles as established in the United Nations Universal Declaration of Human Rights and accompanying Covenants, the International Labor Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work, International Bill of Human Rights, Guiding Principles on Business and Human Rights, Children Rights and Business Principles and all other applicable international and local human rights standards, laws and regulations.

As MODEC fulfills our obligations to stakeholders, including customers, business partners, local communities where we conduct business, and our employees, shareholders, suppliers, and subcontractors, MODEC is dedicated to promoting respect for all people, safeguarding human rights, adhering to established labor and workplace practices and acting responsibly toward the environments in which operate. MODEC recognizes and promotes universal human rights protection and conducts our global operations under the belief that all human beings are born free and are equal in dignity and rights.

MODEC expects employees to act in a manner that respects the rights and dignity of all people, complying with all applicable international human rights laws and regulations.

Our Code of Business Conduct and Ethics stipulates the prohibition of child labor and forced labor and respect for individual human rights. Every employee must comply with our code of conduct as a member of local communities. This foundation stipulates the prohibition of any form of discrimination based on gender or nationality, as well as prohibiting child labor and forced labor (Forced labor is involuntary labor of any kind, including prison labor, debt bondage, or forced labor by the government).

No Use or Support of Child Labor

    MODEC does not:

  • Engage in or support the use of persons below 15 years of age or, if higher, the legally prescribed minimum age.
  • Expose persons under the age of 18 to any situations, in or outside of the workplace, that are hazardous or unsafe to their physical and mental health and development.
  • Interfere with mandatory schooling of children.
No Use or Support of Forced or Compulsory Labor

    MODEC does not:

  • Engage in or support the use of forced or compulsory labor, including prison labor.
  • Require ‘recruitment fees’ or ‘deposits’ from workers - financial or otherwise.
  • Withhold salary, benefits, property, or documents to force personnel to continue work.
  • Engage in or support human trafficking in any form.
Provide a Safe and Healthy Workplace

    MODEC does:

  • Provide a safe and healthy workplace and prevent potential occupational accidents.
  • Appoint senior management to ensure health and safety and provide instructions on health and safety for all personnel.
  • Implement robust systems to detect, avoid, and respond to risks and to record all accidents.
  • Provide required personal protection equipment and medical attention in the event of a work-related injury.
Respect Freedom of Association and Right to Collective Bargaining
  • MODEC respects the right to form and join a trade union(s) and bargain collectively or to have recognized employee representation by local law. Where local law restricts such rights, MODEC allows workers to elect their representatives freely.
  • MODEC ensures that there is no discrimination against trade union members, workers’ representatives, or personnel engaged in workers’ organizations.
  • MODEC respects employees’ "freedom of association" and "the rights of collective bargaining" through explicit adoption of the International Labor Standards set by the International Labor Organization (ILO) and compliance with applicable local laws and regulations.
No Discrimination

    MODEC does not:

  • Discriminate based on race, national or territorial or social origin, caste, birth, religion, disability, gender, sexual orientation, family responsibilities, marital status, union membership, political opinions, age, or any other condition that could give rise to discrimination.
  • Discriminate regarding hiring, setting remuneration, access to training, promotions, termination decisions, and retirement.
  • Tolerate discrimination based on the above-mentioned or any other legally protected categories.
  • Interfere with the exercise of its employees’ tenets or practices.
  • Tolerate threatening, abusive, exploitative, and coercive behavior at the workplace or MODEC facilities.
Reasonable and Fair Disciplinary Practices

    MODEC treats all personnel with dignity and respect.
    MODEC does not engage in or tolerate:

  • The use of corporal punishment.
  • Mental or physical coercion.
  • Verbal abuse of personnel.
  • Harsh or inhumane treatment of personnel.
Reasonable and Fair Working Hours
  • MODEC complies with applicable laws, collective bargaining agreements (where applicable), and industry standards on working hours and public holidays.
  • MODEC endeavors to ensure that employees’ working hours and use of leave entitlements are appropriately managed, and excessive overtime work is prohibited by following local legislation.
Reasonable and Fair Compensation
  • MODEC complies with all applicable laws and regulations regarding pay practices and employment classification according to job level and status.
  • MODEC endeavors to ensure statutory minimum wages at least the living wage for employees and shall not unreasonably reduce wages.
Diversity, Equity, and Inclusion
  • MODEC is dedicated to nurturing, promoting, and upholding a culture centered around diversity, equity, and inclusion.
  • MODEC values and honors the diverse attributes that make each of our employees unique, including but not limited to age, ethnicity, gender identity, physical and mental abilities, political beliefs, religion, sexual orientation, and socioeconomic background.
Brazil Pay Equality and Transparency Report

Reinforcing our commitment to transparency and in compliance with Law No. 14,611/2023, known as the Brazilian Equal Pay Law, and the Brazilian Ministry of Labor’s Ordinance No. 3,714 to Decree No.11,795 of 2023, we publish the salary equality reports of MODEC Serviços de Petróleo do Brasil Ltda offices with more than 100 employees: Rio de Janeiro, Santos and Macaé (including the office, base and all offshore units).

MODEC emphasizes that the documents were prepared directly by the Ministry with data from 2022 and the methodology used may not reflect the most recent dynamics of the company.


MODEC promotes diversity and inclusion initiatives in the job market and reinforces that the topic is part of the company's business strategy through the Mid-term Business Plan 2024-2026.

Labor Standards

As one of a global company's responsibilities and to ensure its continuity, the MODEC Group seeks to develop diverse human resources with shared values. Through establishing labor standards, we promote a working environment in which every individual can achieve their full potential regardless of their nationality or sexuality.

Policy on Labor Standards

We believe that respect for human rights is essential in the course of undertaking projects all over the world. Based on this belief, we establish our "MODEC Human Rights Policy". The policy stipulates prohibition in any form of discrimination based on gender or nationality, as well as it prohibits child labor and forced labor.

Additionally, we respect employees' "freedom of association" and "the rights of collective bargaining" through explicit adoption of the International Labor Standards set by International Labor Organization (ILO) and comply with applicable local laws and regulations. We endeavor to ensure that employees' working hours and use of leave entitlements are appropriately managed and excessive overtime work is prohibited by following local legislations.

In addition, we endeavor to ensure statutory minimum wages at least the living wage for employees and shall not unreasonably reduce wages.

Participation in the UN Global Compact

We joined the UN Global Compact in January 2020, declaring our commitment to the universal ten principles in the four fields (human rights, labor, environment and anti-corruption). Guided by our "Code of Business Conduct and Ethics", we prevent any form of discrimination and harassment, and promote actions under each principle of the "UN Global Compact".

MODEC as a Corporate Citizen

MODEC has actively engaged in the contributions to the communities in the regions where there are shipyards working with us and where we have vessels in operation in the countries.

MODEC as a Corporate Citizen