Compliance

Code of Ethics of EXIM Hungary

EXIM Hungary’s Code of Ethics sets out for the Company and those associated with the Company the values and principles that EXIM Hungary holds important, its commitment to fair and ethical conduct, its rules of behaviour in the conduct of its business, thus strengthening trust in banks and cooperation between members of the banking system and our clients. The Code of Ethics represents the basis of the Company’s values, the general principles to be followed and the guidelines to be followed in the event of breaches of standards. Our Company is committed to protecting our reputation and the trust placed in us through corporate governance. In doing so, we will respect and comply with the rules for the protection of life and limb, health and the environment, and provide a safe and healthy environment for our employees, business partners and others who have dealings with us. The principles, requirements and standards set out in the Code of Ethics are a shared responsibility of all of us and are binding on all persons employed or engaged in an employment relationship with us and our business partners. The Code of Ethics provides guidance that is not a substitute for acting in good faith and with good faith in the interests of the integrity of the Company. It is also intended to provide clear and unambiguous guidelines and expectations for ethical business conduct, employee behaviour and conduct, and to enable awareness of the knowledge and compliance with ethical standards and the whistleblowing system, in the spirit of commitment to sustainability principles.

In addition to the requirements of the applicable laws and internal regulations governing EXIM Hungary’s operations, the Code of Ethics summarises and describes to the Company’s employees the potential ethical and corruption risks associated with EXIM Hungary’s operations, provides support for the detection and prevention of ethical risks and sets out ethical expectations for employees. This includes the fight against and prevention of money laundering and terrorist financing, fraud and corruption, breaches of financial sanctions, and the identification, detection and elimination of situations of conflict of interest. The Code of Ethics also aims to regulate standards of conduct and behaviour, including the gift policy, based on the principles of respect for human rights, fair treatment and non-discrimination.

The full text of EXIM’s Code of Ethics is available on the EXIM Hungary’s Hungarian website. These informations are available both in Hungarian and English language. The English translation has been prepared with due care. In case of any inconsistency between the present translation and the Hungarian text, the latter shall prevail. In case further information are required in relation with the above written, please do not hesitate to contact EXIM Hungary.

In order to comply with the Act XXV of 2023 on Complaints, Public Interest Disclosure and the Rules for Reporting Abuse (the “Complaints Act”), and with the Act CCXXXVII of 2013 on Credit Institutions and Financial Enterprises, EXIM Hungary (Eximbank Plc. and MEHIB Plc.) encourages the reporting of information about illegal or suspected illegal acts or omissions or other abuses. The whistleblowing system operated by EXIM Hungary aims to provide EXIM Hungary with the opportunity to report violations of the law and of rules that are contrary to the public interest and the interests of EXIM Hungary. EXIM Hungary encourages the good faith reporting of abuse of which the whistleblower becomes aware, but also encourages the reporting of situations where the whistleblower has reason to believe that abuse will occur.

The whistleblowing system also aims to ensure that reported whistleblowing is treated fairly and investigated properly, i.e.

  • increase the chances that management will be informed in a timely manner of otherwise hidden threats and abuses, thereby preventing financial, reputational or other losses;
  • create an internal atmosphere in which employees can voice their concerns (even anonymously) without fear of discrimination;
  • reduce the time and resources needed to solve problems;
  • deter employees from unethical actions.

What can be reported?

  • an unlawful or suspected unlawful act or omission;
  • other information relating to abuse;
  • information relating to suspected violations of principles specified in the Code of Ethics of EXIM Hungary may be reported; and
  • infringements under Article 116 of the Banking Act.

Who can make a report?

In accordance with the provisions of the „Complaints Act”, from July 25, 2023, the group range of potential whistleblowers is expanded. Who can make a report in the whistleblowing system?

  • the employee,
  • an employee whose employment with the Company has been terminated or an employee whose employment with the Company has been initiated,
  • a sole proprietor, a business association, if he/she/it has or has had a contractual relationship with EXIM Hungary or if he/she/it intends to establish a legal or contractual relationship with EXIM Hungary and the procedure for the establishment of such legal or contractual relationship has been initiated,
  • a partner or supplier or a person under their supervision or control who has commenced a procedure for entering into a contractual relationship with EXIM Hungary (or has a contractual relationship with, or has had a contractual relationship with EXIM Hungary),
  • trainees, students and volunteers (even if their employment or contractual relationship with EXIM Hungary has ended).

The whistleblowing system process at EXIM Hungary allows whistleblowing with the highest possible confidentiality guarantee. Investigations of whistleblowing reports are the responsibility of the Compliance Directorate, in which the employees of the Directorate act without discrimination or prejudice and all information relating to the report is held confidential. In the process of making a whistleblowing report, the whistleblower is entitled to appropriate protection, including discretion and the assurance that no whistleblower will suffer legal, moral or other consequences, repercussions, or, in more serious cases, harassment or any other form of retaliation or discrimination which may adversely affect him or her in relation to his or her report.

Where to report?

The whistleblower may make the report in writing or orally, for which EXIM Hungary provides the following options:

  • to the Compliance Directorate’s whistleblowing e-mail address at Eximbank Plc.: whistleblowing@exim.hu, or to MEHIB Plc.’s whistleblowing e-mail address at whistleblowing@mehib.hu,
  • anonymously via the whistleblowing reporting interface available on EXIM Hungary’s internal intranet system,
  • by leaving a voice message on an answering machine at +36-1-374-9170 (non-stop),
  • by post to the head office address at 1065 Budapest, Nagymező utca 46-48. or to the P.O. Box at 1244 Budapest, Pf. 913. (Eximbank Plc.), 1243 Budapest, Pf. 510. (MEHIB Plc.).

Reports made by post must be made in a sealed envelope and marked “To the Compliance Directorate, to be opened by the addressee only”.

Investigation of the report

For a thorough assessment and full investigation of the report, it is necessary for the whistleblower to provide the following information (where possible):

  • the first and last name of the whistleblower,
  • the contact details of the whistleblower,
  • the essential data to identify the person (if known) concerned by the report,
  • the department/directorate/person concerned by the report,
  • a description of the fact(s) likely to constitute the incident, including all known relevant information (e.g. where, when, by whom, how, for what purpose, what happened),
  • whether the incident has occurred, is ongoing or is likely to occur in the future,
  • how the whistleblower became aware of the event/situation,
  • whether there are other persons with relevant information or data in relation to the notification;
  • whether the whistleblower has informed others about the matter, if so, when and whom,
  • the estimated amount of damages, if any, incurred in connection with the incident,
  • a declaration by the whistleblower that the notification is made in good faith.

EXIM Hungary provides option for anonymous reporting, but draws the attention of the whistleblower to the fact that this makes it more difficult to deal with the report in substance, since contacting the whistleblower and requesting information is significantly more difficult, and in some cases impossible. In the course of the investigation of the report, the Compliance Directorate will maintain contact with the whistleblower to the extent necessary, in the course of which it may invite the whistleblower to clarify the notification or the facts and to provide further information. The Compliance Directorate shall investigate the facts set out in the notification as soon as possible, but not later than thirty days from the date of receiving the report. Exceptions to this limit may be made only in particularly duly justified cases, subject to the authorisation of the Compliance Director, and after informing the whistleblower, but the investigation may not exceed three months.

The whistleblower is protected in the context of his or her report or disclosure of information. The identity of the whistleblower and the details of the report will be kept strictly confidential at all stages of the investigation and this information will not be disclosed to anyone other than the investigators of the report. Any processing of personal data will be carried out in accordance with EXIM Hungary’s internal rules and the provisions of the relevant legislation in force at the time (including in particular the GDPR). Detailed rules on data processing are available below.

These information rules are available both in Hungarian and English language. The English translation of the these Rules has been prepared with due care. In case of any inconsistency between the present translation and the Hungarian text, the latter shall prevail. In case further information are required in relation with the above written, please do not hesitate to contact EXIM Hungary.