Code of Ethics

The first Code of Ethics was developed in 1992. The Code has been continuously updated since to take into account new internal and external developments. The third version, issued in 2001, was the first document to define our goals, vision and values on an integrated basis.

Our work force is the base of the company. MOL Group is committed to consistently operating in accordance with lawful behaviour and fundamental ethical norms. Our employees contribute to MOL’s success not only through their expertise and performance, but also by creating a positive public opinion about the company.

The Code of Ethics is a compendium of norms and rules that every employee must follow when at work. We expect every individual and every organisation in contractual relationship with the Group and its member companies, as well as partners acting on the Group’s behalf, to comply with the Code. This includes the Board of Directors, and all subsidiaries and entities of which MOL Group, directly or indirectly, owns or controls more than fifty percent (50%) of voting or ownership interests, as well as the Company’s executives and employees. The Code should also be adhered to by the Company’s agents and representatives, including consultants. The Code also applies to all MOL Group companies’ contractors and vendors. We not only expect compliance to specific expectations and requirements as set out in the Code of Ethics, but we also vigilantly monitor and control adherence to them.

In 2006, in line with integrated business operations, the three separate ethics bodies that were operating in MOL Group (MOL Plc., TVK Plc. and Slovnaft a.s.) were transformed into a single body, the MOL Group Ethics Council. The first Group-level Code of Ethics, valid for all member companies and subsidiaries, was prepared concurrently, and was launched in 2007. Whilst preparing the Code, we took international best practice and standards into account to better reflect stakeholder expectations and to strengthen our practices and compliance.

Besides controlling and supervising investigations launched into breaches of ethics, the Ethics Council evaluates ethical risks related to our operations, and ensures that these regulations mitigate and reduce such risks.

The Code of Ethics completes the regulation pyramid together with the three main governing documents (OOR - Operational & Organisational Rules, DTR - Description of Tasks and Responsibilities, LDA – List of Decision-making Authorities) and MOL Group Guidelines. These three establish the structure of the organisation and set its basic operational framework - the CoE contributes to this structure by providing fundamental behavioural standards to be respected by Group employees.

For more information about ethical issues can be found in MOL Group’s Annual Reports: 2008, 2009, 2010.