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 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, hinder, detect, uncover, and sanction it, and does not tolerate any conduct that undermines efforts to combat corruption. 

Having regard to the foregoing, MVM Group

• following the example of management, requires full compliance with the anti-corruption legislation and the internal regulations, thereby fostering the development and maintenance of the anti-corruption culture;
• ensures operational transparency in accordance with legal regulations, as well as documented decision-making;
• 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 anti-corruption management systems standard;
• encourages the expression of concerns arising in good faith and/or justifiably, without the fear of retaliation, guarantees that the whistleblower acting in good faith shall not suffer any disadvantage, reprisal, employment-related or business consequences;
• communicates the Group Anti-Corruption Policy within and outside the organisation;
• ensures that the requirements of the MSZ ISO 37001 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;
• ensures the identification, prevention and management of conflicts of interest, requiring all employees and managers to submit and annually update a conflict-of-interest declaration, and prohibits participation in any decision-making process involving personal interests;
• regulates the acceptance of gifts and other benefits;
• ensures that all procurement and public procurement procedures are transparent, documented and compliant with applicable competition law rules;
• conducts risk-based due diligence on all significant partners and applies contractual anti-corruption clauses;
• strictly prohibits false or misleading accounting, off-the-books accounting, and undocumented transactions;
• ensures the responsible and transparent use of available resources;
• does not participate directly in political activities, does not formulate political goals; does not provide monitary or in-kind political contributions, either directly or indirectly;
• ensures the functioning of the internal control system and the conduct of regular internal and external audits.

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: compliance@mvm.hu;
• 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.

MVM Group publishes information and data regarding the operation of its anti-corruption culture in its Annual Sustainability Report, which is available on its website.

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 documented, and proportionate and dissuasive 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.  

In formulating this Group-level Anti-Corruption Policy, MVM Group made every effort to ensure alignment with the United Nations (UN) Convention against Corruption, adopted in 2003.

Budapest, July 14, 2026