Reporting incidents that breach integrity

In compliance with the provisions of Act XXV of 2023 on complaints, public interest disclosures and rules related to whistleblowing (Complaints Act), Act CXXII of 2009 on the more economical operation of publicly owned companies and Government Decree 339/2019 (XII 23) on the internal control system of publicly owned companies - MVM Zrt. maintains dedicated (so-called “Whistleblowing”) channels for receiving reports of incidentsillegal acts and omissions, and other abuses and complaints that breach organisational integrity.

In particular, but not limited to, the following are considered to be breaches of organisational integrity

  • ·violation of the provisions of the Code of Ethics of MVM Zrt.,
  • a breach of the MVM Group's internal regulations through intentional or grossly negligent acts, conduct or omissions,
  • corruption,
  • fraud,
  • abuse.


The whistleblower is expected to make the report in good faith and to disclose all relevant information known to him or her for the purpose of properly assessing and investigating the case. MVM Zrt. will ensure that no whistleblower will be subjected to any detriment, harassment or any other form of retaliation or discrimination as a result of providing information in the case of suspected incidents of integrity breaches, while false or untrue reporting made in bad faith may, depending on its content, lead to legal consequences. The whistleblower shall not suffer any disadvantage even if the report made in good faith proves to be unfounded during the investigation.

For the effective investigation of such reports, it is necessary to provide at least the following information:

  • data essential for the identification of the person who is the subject of the complaint for a breach of the Code of Ethics or other breach of organisational integrity;
  • the most specific and detailed description possible (place, date, act, natural or legal persons involved) of the reported event, ethical misconduct or breach of rules that breaches organisational integrity;
  • documents, information, means of evidence available to the whistleblower and/or data relating to their availability which may prove the incident;
  • identification of persons who may witness or have knowledge of the reported event, act or circumstances,
  • a declaration by the whistleblower that the whistleblowing is done in good faith.


Reports can be made through the following channels:

  • E-mail:
  • By post or in person: to/by contacting the Compliance Function of MVM Zrt.
    1031 Budapest, Szentendrei út 207-209.


If the notification is made by post, the notification must be sent in a sealed envelope and must be marked as follows: "To the Compliance Function - Reporting an Integrity Incident".

Further information on reporting integrity incidents:

  • the email account is checked on a daily basis,
  • MVM Zrt. will investigate all reports,
  • anonymous reporting is possible, but in this case it is also necessary that MVM Zrt. has at least some contact information of the whistleblower (e.g. e-mail address, postal address or mailbox address) to facilitate the efficient conduct of the investigation, to provide further information and to allow for feedback,
  • the identity of the whistleblower, if not anonymous, cannot be disclosed to third parties either during or after the investigation (unless disclosure is required by law),
  • the confidentiality of the notification is ensured, information concerning the content of the report and the person concerned by the report may be shared with other departments or employees of MVM Zrt. only to the extent strictly necessary for the assessment of the report or the conduct of the investigation, in addition to informing the person concerned by the report,
  • reports are investigated in accordance with the relevant internal rules of MVM Zrt. (Internal rules MVM-BSz-027 for handling integrity incidents within the organisation of MVM Zrt.).

If the report

  • has been made by the same person repeatedly, with the same subject matter and content;
  • was not made by a person entitled to submit a report under the Complaints Act and the report does not contain sufficient information for a substantive examination;
  • was made by an unidentified whistleblower and the report does not contain sufficient information for a substantive examination;
  • the public interest or overriding reasons of private interest would be disproportionate to the restriction of the rights of the natural or legal person concerned by the investigation of the report

the substantive examination of the report may be dispensed with.

As a first step in the procedure, it will be examined whether the report raises a suspicion of a breach of integrity and, if so, a substantive investigation into the breach of integrity will be launched, culminating in an investigation report.

By submitting a report, the natural person submitting the report consents to the processing of his or her personal data in accordance with the provisions of the privacy policy entitled “Privacy Policy for Whistleblowers of integrity incidents".

More detailed information on the rights and obligations of the natural person submitting the report, the natural person who has substantive information about the report and the natural person concerned by the report, and other useful information, can be found at the following links: