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 establishes, maintains and develops a management system operating in accordance with the MSZ ISO 37001:2019 anti-corruption management systems standard (hereinafter: “Anti-corruption management system”).

MVM Ltd.’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 Ltd.’s fundamental task is to exercise strategic governance and control over the companies of the MVM Group. This key role involves great responsibility, including in the fight against corruption.

MVM Ltd. is committed to fighting corruption, and therefore it explicitly prohibits and opposes all forms of corruption, taking definite steps to prevent and combat it. For this purpose, it establishes, maintains and develops a management system operating in accordance with the “MSZ ISO 37001:2019 – anti-corruption management systems” standard (hereinafter referred to as: “Anti-Corruption Management System”). 

Having regard to the foregoing,

• MVM Ltd.’s 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 Anti-Corruption Management System;

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

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

• ensures that the requirements of the Anti-Corruption Management System are integrated into the organisation’s processes;

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

• is committed to the continuous development of the Anti-Corruption Management System.

In the spirit of the above, MVM Ltd.’s management allows and encourages the reporting of any attempt at or suspicion of any breach or deficiency of the Anti-Corruption Policy and the Anti-Corruption Management System in good faith or based on reasonable belief (whether directly or via an appropriate third party), even anonymously, at the email address compliance@mvm.hu.

MVM Ltd.’s central Compliance Function is in charge of and responsible for operating the Anti-Corruption Management System. The Compliance Function conducts compliance activity at the level of MVM Ltd. and also the MVM Group.  In the course of the performance of its tasks, the Compliance Function provides advice and guidance in connection with the Anti-Corruption Management System, as well as matters related to corruption. It assesses and, where necessary, investigates reported, identified or reasonably suspected corruption events, as well as any breach of the Anti-Corruption Policy and the Anti-Corruption Management System. 

MVM Ltd. refrains from establishing or maintaining business relationships with third parties who do not comply with the provisions of the Anti-Corruption Policy.  

Budapest, May 20, 2022