At MTG we promote a culture of openness, responsibility and accountability. We want to conduct business in full compliance with laws, regulations, international initiatives and standards.

We have not had any cases of non-compliance with law or regulations nor no fines were paid during 2022.

Our Code of Conduct is built on our values; striving to inspire and ignite, exploring opportunities, enhancing lives and shaping the future. More importantly, the code is a guide for all our employees on how we do (and don’t do) business. It helps us navigate the ethical and legal situations we face daily.

Our code describes our responsibilities towards customers, business partners, shareholders and each other. It also sets out our position on topics such as fair working conditions, asset protection, anti-corruption practices, conflicts of interest, competition, data privacy and much more.

As a responsible global business, we are committed to international initiatives and standards such as:

• the OECD Guidelines for Multinational Enterprises
• the UN Global Compact
• the Fundamental Conventions of the ILO
• the UN Universal Declaration of Human Rights, and;
• the UN Guiding Principles on Business and Human Rights.

We review our policy framework annually and if significant changes are made we need approval from the Board.

As we promote a culture of openness, responsibility and accountability, we want everyone to feel comfortable about raising concerns, including possible violations of our Code of Conduct, policies, applicable laws and regulations. It is important for all our employees to know that their concerns will be taken seriously and investigated properly without fear of retaliation and that their confidentiality will be respected. Therefore, we have established a Whistleblower process and encouraged our employees to raise their concerns directly.

Should an employee not feel comfortable raising concern with their line manager or manager’s manager, they can contact our Whistleblower channel.

At MTG we take anti-bribery and corruption seriously, which is why we have the Anti-Bribery and Corruption Policy. During 2022 we had no confirmed incidents of corruption and no incidents that lead to employee dismissal or disciplinary action. No contracts with business partners had to be terminated or not renewed due to violations related to corruption, and no legal cases were brought against us or our employees.

We also want to develop and maintain strong business relationships with suppliers who are committed to ethical standards equivalent to our own. Our Supplier Code of Conduct sets out the standards with which all companies providing products or services to MTG are expected to comply. It is important to note that failure to comply with the standards and provisions in the Supplier Code may result in MTG reviewing and potentially ending a co-operation with a supplier.

A core central team consisting of the Group Head of Data Protection works closely with appointed local Data Protection Managers and Human Resources to make sure data protection matters are handled correctly within all companies of MTG Group.

We have continued to follow our roadmap which includes activities such as updating privacy notices and data processing agreements, reviewing retention periods, handling data subject requests, establishing data breach procedures, as well as producing policies/guidelines and different types of training and awareness activities.

We have established a clear framework that manages data incidents and breaches which will ensure that we report possible personal data breaches within 72 hours. All personal data breaches are documented centrally. Complying and working with GDPR has become part of our daily work as we have moved into a governance phase and processes are starting to fall into place. We are continuously improving our workstreams and processes to ensure to include GDPR into daily work, to keep GDPR relevant and prioritized.