• Personal safety
• Health protection and promotion
• Process Safety and Risk Management
• Attracting employees
• Retaining and Motivating Employees
• Human capital development
• Commitment to Fair Employment
• Ethics
• Social Investment

Ethical framework

In 2010, we placed special emphasis on updating the Code of Ethics and Rules of Procedure, implementing e-learning and continuing ethical communication according to the following:

• The Code of Ethics, adopted three years ago, was reviewed based on experiences gained after the Code had been adopted. Other codes of ethics in this industry sector, provisions of law and suggestions and sustainability evaluation criteria were also used in the evaluation. The revised Code of Ethics emphasises that the norms formulated in the Code cover all stakeholders, and that the managers exercise special responsibility for integrating ethical norms into everyday corporate practice. Regulations for accepting gifts and rules of ethical procedures were also changed. The position of Ethics Officer was introduced for the companies of the MOL Group;
• Ethics e-learning aimed at improving awareness was successfully completed by 99 % of MOL Plc employees with Internet access, by 97 % of TVK Plc employees with Internet access, and 100 % of Slovnaft employees. In addition, live ethics training sessions were held in several companies of the MOL Group;
• IES, the Italian member of the Group, has also adopted the Code of Ethics;
• Within the framework of internal communication, three articles were published in the internal company magazine, Panoráma, which dealt with the ethics evaluation of 2009, the results of the e-learning courses, and the positions taken by the Ethics Council on promoting awareness of acceptable behavior in particular situations;
• Ethical expectations and Key Performance Indicitors (KPI) were defined for all Country Chairmen;
• INA adopted the Code of Ethics in 2010, and the INA Ethics Council was established with an independent expert appointed as Council President. In 2010, the INA Ethics Council received one notification, and its investigation is in progress.

Ethical cases

Only the ethics cases reported to the Ethics Council are summarised below. The task of the Council is to ensure that all MOL Group employees comply with the Code. Among the most important of the Council’s duties and responsibilities is replying to complaints and questions, and conducting consequent investigations. At Slovnaft, questions related to ethical issues are answered by the Ethics Council in conjunction with the in-house Ethics Advisory Service. In 2010, the Ethics Council responded to 89 questions related to harassment, discrimination, conflicts of interest and business gifts.
In 2010, the Ethics Council received ten notifications. The Ethics Council investigated seven of the ten cases, and in four cases the Corporate Security department was asked to conduct investigations. Ethical misconduct was proven in four cases out of seven.
The increasing number of notifications and questions means that employees now pay more attention to ethical issues and display increasing trust in the Ethics Council.

Ethical notifications received and investigations conducted by stakeholder group (2010)

* The Ethics Council considered the accusations unfounded and did not initiate an ethics investigation.

In order to promote ethical awareness, the Ethics Council annually publishes details of cases with proven ethical misconduct. The cases to date are as follows:

• Improper employee behaviour – Getting into a stressful traffic situation and entering a security area. One of MOL Group’s employees was not willing to identify himself when a security guard asked him to do so. He used vulgar and offensive words and hit the guard’s arm. His behaviour clearly breached  the Code of Ethics that states: “As a MOL Group employee you must never engage in behaviour that could be characterised as offensive, intimidating, malicious or insulting,“ and “you must never humiliate or injure another person.” Since security rules were violated, the Ethics Council recommended taking measures related to labour law. In addition, the Council proposed the publication of the incident at meetings and via Intranet, and the taking of proper measures in order to prevent similar situations from the occurring in the future. 
   
• Failure to report an accident – One of the business partners of MOL Group asked for employee volunteers to assist with some cleaning. One of the employees was injured during the course of the work and was given treatment by a paramedic. The stakeholders breached the Code of Ethics that states that it is mandataory to: “promptly report to local management any accident, injury, illness, unsafe or unhealthy conditions, incident, spill or release of material to the environment, so that immediate steps can be taken to correct, prevent or control such occurrences.” The Ethics Council notified the Retail Division that the business partner had breached MOL’s ethical standards and HSE rules, and recommended that the partner be fined, participate in training sessions on the Ethics Code, and be made better aware of HSE rules.
   
• Violation of health and safety requirements – One of the business partners of MOL Group working at a location in a situation hazardous to human health did not report that the workers had not been provided protective clothing in proper sizes, and therefore performed the work without protective clothing. Performance of these tasks without regard to safety requirements not only endangered the partner’s health, but also the health of his colleagues. The MOL Group manager who delegated the work did not insist that the work be perfomed only in protective clothing, and neglected giving priority to HSE criteria. The stakeholders violated the Code of Ethics that holds:  “MOL Group is committed to providing all employees – and those of other companies working on our premises – with a safe and secure work environment, where no one is subject to unnecessary risk.” The Ethics Council did not suggest introducing penalties for workers who breached the Code of Ethics due to extraordinary circumstances, and instead recommended that personnel be made aware of the importance of  HSE criteria and culture.
   
• Acceptance of offers of accomodation – Several managers of MOL Group participated in an an unofficial professional conference held by a supplier during their holiday. The managers did not seek permission from their supervisor. The managers infringed  the Code of Ethics that states that employees: “[may] not accept offers of travel, holidays and/or accommodation made by a business partner, third party contractor or company acting on behalf of MOL Group (consultants, agents, franchise partners, etc.). In certain cases (e.g. professional training, or invitations to make presentations) acceptance of such offers of travel and accommodation is permitted, if it has been approved by the supervisor exercising employer’s rights.” The Ethics Council suggested that the managers concerned should be held responsible for breaching ethical standards and for unexemplary behaviour.

The Ethics Council regularly reported all ethical issues to the Executive Board and took measures to raise awareness.

Compliance

MOL Group is committed to fair marketing behaviour without corruption and improvement of the culture of competition. In 2010, a new organisational unit, the Compliance Team, was established and made responsible for the execution of the group-level Compliance Programme. The aim is to clearly identify the risk elements (cartel, abuse of dominant position) of the business operations of MOL Group and make proper suggestions to eliminate such risks. Compliance officers in INA and Slovnaft have also been nominated. In 2011, the team aims to support the MOL Group member companies in implementation and to continue training courses and conducting market analysis and inspections.