MOL GROUP'S ETHICS MANAGEMENT SYSTEM

Code of Ethics and Business Conduct

  • All executive officers and employees of MOL Group member companies (MOL Nyrt. and all business enterprises controlled by MOL Nyrt.) must act in compliance with the Code.
  • All business partners must receive the Business Partner Code of Ethics asa binding appendix of contracts.
  • At all companies owned but not controlled by MOL Nyrt. we make conscious and continuous efforts to implement the Code and to ensure our ethical norms are adopted.

Ethics Council

  • Essential mission of the Ethics Council is to ensure MOL Group's ethical conduct and coordinate structured ethics development at all MOL Group companies by making individual decisions on ethics complaints. Its operartion is regulated in the EC Rules of Procedure.
  • Permanent members of the EC are executive managers and employee representative. The Chairperson of the Ethics Council is an external expert monitoring and safeguarding impartial and fair procedure and coordination ethics training and communications activities.

Ethics Officers

  • Operational work of the Ethics Council (e.g. operating grievance mechanisms, investigation, consequence management) is assisted by Group Ethics Officer.
  • In the course of carrying out their tasks, Ethics Council and Group Ethics Officer are assisted by Local Ethics Officers appointed from among employees by chief executive officers of individual MOL Group Companies having 20+ FTE.

Ethics & Compliance 'SpeakUp!' whistle-blowing

  • Internal and external stakeholders have the possibility to report an ethical misconduct or seek advice in written (post, e-mail, internet system) and through the 7/24 phone message recording system. Anonym complaints and questions can be submitted and confidentiality is ensured.
  • MOL Group does not tolerate repression against those reporting ethical issues.

Ethics Communication

  • Ethics norms are communicated to the internal and external stakeholders regularly.
  • Ethics Council publishes general and anonimous ethics resolutions to raise ethics awareness.
  • Annual ethics statistics and ethical misconducts are published on the MOL Group's webpage, intranet, in company newsletters and at annual managerial presentations in an anonymous way.

Ethics Training

  • Every newcomer receives a copy of the Code of Ethics and akcnowledge it in writing.
  • Tri-annually all employees must pass the Code of Ethics test via e-learning or classroom trainig.
  • Service station employees must have special ethics training in every 3 years.
  • All managers must give a presentation about the Code of Ethics and ethics cases once a year to all direct subordinates.

Ethics Monitoring

  • Country Chairpersons and CEOs must provide ethics related information annually (figures on e.g CoE extension, training, actions).
  • Ethics tasks of managers should be implemented to all managers yearly performance evaulation. Ethical behaviour should be integrated in the employee’s performance assessment.

Ethics Risk Assessment

  • Ethics Risk Matrix contains ethics breaches' risk evaulation by impact and likelihood based on experiences and estimation.
  • Self assessment of the MOL Group companies must take into consideration annual reports of external institutions (e.g. Transparency International, Human Rights, Watch).

Ethics Audit

  • Regular internal ethics audits should be conducted in MOL Group member companies and organisational units.
  • Ethics system should be audited by third party in every 5 years.