总部地址: H-1117 Budapest, Irinyi József str. 4-20/B

通讯地址: H-1117 Budapest, Irinyi József str. 4-20/B

电话: +36 1 225-6100

传真: +36 1 225-6193

邮箱: info@mvmegi.com

Whistleblowing and Reporting Channels

Reporting integrity violations

MVM EGI Zrt. - in compliance with the provisions of Act CXXII of 2009 on the more economical operation of public companies and Government Decree 339/2019 (XII. 23.) on the internal control system of public companies - maintains dedicated channels for the reporting of incidents and complaints that violate organisational integrity (so-called "whistleblowing").

In particular, but not exclusively, an event that breaches organisational integrity is considered to be a whistleblowing incident:

• Violation of the provisions of its Code of Ethics,
• corruption,
• fraud,
• abuse.

The whistleblower is expected to make the report in good faith and to provide all relevant information known to him/her for the proper assessment and investigation of the case. MVM EGI Plc will ensure that no whistleblower will suffer any disadvantage, harassment or any other form of retaliation or discrimination as a result of providing information in relation to suspected incidents of integrity breaches, while false or untrue reporting made in bad faith may lead to legal consequences depending on its content. Nor can a whistleblower be prejudiced if a report made in good faith is found to be unfounded during the investigation.

For a successful investigation of a notification, the following information is required as a minimum:

• information essential to the identification of the person complained of as a result of a breach of the Code of Ethics or other breach of organisational integrity;
• a description, as specific and detailed as possible (place, date, act, natural or legal persons involved) of the reported event, ethical breach, breach of conduct that violates organisational integrity;
• any documents, information, means of proof and/or data relating to the availability of documents, information, means of proof and/or their availability to the whistleblower as evidence of the incident;
• an indication of the persons who can testify to or have knowledge of the event, act or circumstances of the reported event or act.

Notifications can be made through the following channels:

• By post, by letter to. H-1117 Budapest, Irinyi József str. 4-20/B. - to be marked: 'For the Compliance Advisor, s.k. for resolution
• By e-mail: compliance@mvmegi.com
• In person: at the headquarters of MVM EGI Zrt. via the mailbox in the CEO wing

If the notification is made by post or in person, the notification must be sent in a sealed envelope and must be marked 'Notification of an incident with integrity implications'.

Notifications can also be made to MVM Zrt. via the following channels:

• By e-mail: compliance@mvm.hu
• By post: to MVM Zrt. Compliance, 1031 Budapest, Szentendrei str. 207-209.

Further information on reporting incidents with integrity:

• MVM EGI Ltd will investigate all reports,
• Only the designated staff of MVM EGI Ltd. shall have access to the reports and the confidentiality of the report shall be guaranteed,
• anonymous reporting is possible, however, in this case it is necessary that MVM EGI Zrt. has at least some contact details of the reporter (e.g. e-mail address, postal address or P.O. Box address) to facilitate the efficient conduct of the investigation, to provide further information and to allow for feedback,
• as a first step in the procedure, an assessment is made as to whether the notification raises a suspicion of an integrity breach and, if so, an integrity breach investigation is initiated, which concludes with an investigation report.
• the notifying natural person, by submitting the notification, consents to the processing of his/her personal data as described in the Privacy Notice "Privacy Notice for Whistleblowers".