This trade compliance policy reflects our commitment to operate in accordance with
Modine’s Code of Ethics and Business Conduct. It also recognizes that failure to meet
trade compliance requirements can have serious consequences for Modine, including
damage to the company’s reputation, monetary penalties, and suspension/revocation of the
company’s exporting or importing privileges with a resulting negative impact to our
suppliers and customers. Thus, we are committed to the implementation, maintenance
and continuous improvement of a robust global trade compliance program which integrates
compliance activities into Modine’s business processes.