Yes.
The current rules are very simple and local - if something is marked as pub (like S in the first example), then it's considered public, if something is not marked as pub (like S in the second example), then it's not considered public.
S being "effectively private" due to some intermediate private modules is not taken into account.
RFC 136 is the normative document.
Also see the discussion in [lang-team-minutes] private-in-public rules about tweaking the rules in various backward compatible ways.
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