Anti-corruption management system of MVM Ltd.

The management of MVM Energy Private Limited Liability Company (hereinafter: MVM Ltd.) is committed to fighting corruption in all areas of the activity of the state-owned energy group it controls. It explicitly prohibits and opposes all forms of corruption, therefore takes decisive steps to prevent and deter it, so established, maintains and develops a management system operating in accordance with the MSZ ISO 37001:2019 anti-corruption management systems standard.

MVM Group’s Anti-Corruption Policy

MVM Group is a key actor in the Hungarian and regional energy sector, whose successful and competitive activity has an important role in achieving the energy strategy goals of the country and the region, and whose professional expertise contributes significantly to the security of energy supply in Hungary and Central-Eastern Europe. 

MVM Group’s key role involves great responsibility, including in the fight against corruption.

MVM Group is committed to fighting corruption, and therefore it explicitly opposes and prohibits all forms of corruption, taking definite steps to prevent and combat it. 

Having regard to the foregoing, MVM Group

following the example of management, requires full compliance with the anti-corruption legislation and the internal regulations;

regularly reviews the risk of corruption in its organisation and the business processes related to its activity in relation to all forms of corruption;

sets and reviews anti-corruption objectives annually, and implements measures in order to achieve them;

is committed to meeting the requirements of the MSZ ISO 37001:2019 anti-corruption management systems standard;

encourages the expression of concerns arising in good faith and/or justifiably, without the fear of retaliation;

communicates the Group Anti-Corruption Policy within and outside the organisation;

ensures that the requirements of the MSZ ISO 37001:2019 anti-corruption management systems standard are integrated into the organisation’s processes through appropriate professional resources;

guides and supports employees in contributing to the effectiveness of the anti-corruption management systems;

regularly provides obligatory training for management and employees in the field of anti-corruption;

supports the development of the organisational culture of anti-corruption;

is committed to the continuous development of the anti-corruption management systems operating in the MVM Group.

In the spirit of the above, MVM Group allows and encourages the reporting of any attempt at or suspicion of any breach or deficiency of the Group Anti-Corruption Policy and the anti-corruption management systems operating in the MVM Group in good faith or based on reasonable belief (whether directly or via an appropriate third party), even anonymously, at central level on the following channels:

in email:;

by post: to the Compliance Function of MVM Ltd.,1031 Budapest, Szentendrei road 207-209.;

or at member company level on the channels indicated on their websites.

At MVM Group level MVM Ltd.’s central Compliance Function, at company level the companies’ Compliance Functions are in charge of and responsible for operating the anti-corruption management systems operating in the MVM Group, who have direct and immediate contact opportunities with the governing body and top management. The central and corporate Compliance Functions act independently and in accordance with their job description in the course of the performance of their tasks, they provide advice and guidance in connection with the anti-corruption controls, as well as matters related to corruption. They assess and, where necessary, investigate reported, identified or reasonably suspected corruption events, as well as any breach of the Group Anti-Corruption Policy and the anti-corruption management systems.

The member companies of the MVM Group do everything possible to ensure that, in the event of a violation of the Group Anti-Corruption Policy, the corrupt behaviour is investigated and legal consequences are imposed in accordance with the relevant laws and internal regulations. MVM Group guarantees that in the event of a violation or deficiency, all members of the management and employees are treated equally. 

MVM Group refrains from establishing or maintaining business relationships with third parties who do not comply with the provisions of the Group Anti-Corruption Policy or commit a crime of corruption established by a final court decision.  

Budapest, September 22, 2023


Károly Tamás Mátrai 

Chief Executive Officer

Dr. Kolos Katona

Chief Legal Counsel and Compliance Director