Doing What's Right: NOVARIC^® Code of Ethics

NOVARIC® is committed to conducting all business with integrity, transparency and respect for every person. The Code of Ethics sets out the values and standards of conduct expected of everyone who acts within or on behalf of the NOVARIC® group.

The Code provides practical guidance for decision-making, supports legal and regulatory compliance across the jurisdictions in which we operate, and reinforces the commitment to fairness, accountability and responsible conduct that underpins everything we do.

The Code does not replace applicable law. Where law sets a higher standard, that standard applies. Where law falls short of our values, the Code guides us further. Where the Code and a specific NOVARIC® policy address the same matter, the more specific policy applies unless it conflicts with the Code's underlying principles.

All NOVARIC® policies are expected to be consistent with this Code. If you believe a policy conflicts with the Code, you should raise the concern through the channels set out in the Speak Up section.

The Code of Ethics fulfils several distinct functions within the NOVARIC® governance framework:

• Decision guidance. It helps everyone working with or for NOVARIC® make sound decisions in situations that may not be explicitly covered by a specific policy.
• Minimum ethical standard. It sets a floor of expected conduct that applies regardless of jurisdiction, role or business context.
• Legal and regulatory anchoring. It connects our values to applicable legal frameworks in Malta, Albania and across the European operations in which we work.
• Responsible business conduct. It supports compliance with international responsible business standards and sector-specific obligations.
• Protection of people. It protects candidates, workers, clients and partners by making clear what they can expect from everyone who acts for NOVARIC®.
• Framework for raising concerns. It establishes the commitment to a speak-up environment where concerns can be raised without fear of retaliation.

The Code is a governance document, not a legal instrument. It does not constitute legal advice, create enforceable obligations on third parties, or certify compliance with any regulatory standard.

The Code applies to all individuals who act within or on behalf of the NOVARIC® group. This includes:

Where third parties — including suppliers, partners or agents — act on NOVARIC®'s behalf, they are expected to uphold standards consistent with this Code. NOVARIC® takes steps to communicate these expectations as part of commercial and partnership engagement.

Certain sections — particularly those relating to data handling and privacy — apply specifically to how NOVARIC® processes personal data relating to candidates, clients and other data subjects. These obligations are set out in more detail in the Data Protection & Privacy hub and associated notices.

Following the Code means translating its principles into day-to-day decisions and conduct. The following represents core expected behaviours:

• Know and follow the Code and relevant NOVARIC® policies applicable to your role.
• Apply sound judgment; ask for guidance when a situation is unclear or novel.
• Treat every person — colleagues, candidates, clients, partners and the public — with dignity, courtesy and fairness.
• Speak up promptly when you become aware of a concern, suspected breach or potential violation.
• Cooperate fully and honestly with any authorised review or investigation.
• Complete required compliance training and keep knowledge current.
• Protect confidential information relating to NOVARIC®, its people, candidates, clients and partners.
• Identify, disclose and appropriately manage any conflict of interest before it affects a decision.
• Use NOVARIC® systems, resources and name only for authorised, legitimate purposes.
• Comply with applicable data protection law when handling personal data.
• Behave consistently whether observed or not — the standard does not change depending on who is watching.

Compliance with the Code is a condition of engagement with NOVARIC®. Serious or repeated breaches may result in disciplinary or contractual consequences, subject to applicable law and the terms of the relevant engagement.

Five principles form the foundation of the NOVARIC® Code of Ethics. They apply to every role, every relationship and every jurisdiction in which we operate.

NOVARIC®'s ethical commitments are specific to the relationships we hold. The following sections set out what we value, what we commit to and what we will do for each stakeholder group.

The Code creates responsibilities for every individual within its scope. These are not aspirations — they are expectations of conduct.

1. Know the Code. Read and understand this Code and the policies applicable to your role. Claim of ignorance is not a defence against a breach.
2. Follow applicable policies. Comply with relevant NOVARIC® policies and applicable law. Where a policy is unclear or appears to conflict with the Code, seek guidance before acting.
3. Seek guidance when uncertain. If you are unsure whether a proposed action is consistent with the Code or applicable policy, ask before you act. Decisions taken without adequate guidance remain your responsibility.
4. Report concerns promptly. If you become aware of a potential breach of the Code, applicable law or NOVARIC® policy, report it through the channels described in the Speak Up section. Do not wait for certainty — report the concern and allow it to be assessed properly.
5. Cooperate with investigations. Participate honestly and completely in any authorised review, investigation or audit. Withholding information or providing false statements may itself constitute a breach.
6. Maintain confidentiality. Protect confidential information relating to NOVARIC®, its people, clients, candidates and partners — during and after your engagement. This obligation continues after the engagement ends.
7. Complete required training. Complete any compliance, ethics or data protection training required for your role or engagement.
8. Disclose conflicts of interest. Identify and promptly disclose any situation where a personal, financial or family interest could — or could appear to — influence a business decision. Do not participate in decisions where such a conflict exists until it has been appropriately managed.
9. Use resources responsibly. Use NOVARIC® systems, name, branding and resources only for authorised, legitimate purposes. Misuse is a breach of the Code.

NOVARIC® is committed to a working environment where concerns can be raised openly and without fear. Speaking up is not just permitted — it is expected. Early reporting of concerns protects individuals, the organisation and the people we serve.

NOVARIC® does not promise a specific response or investigation deadline. Concerns are assessed and prioritised based on their nature and available information. Complainants and reporters will be kept informed to the extent that confidentiality and the investigation permit.

A conflict of interest arises when a personal, financial or family interest could — or could appear to — influence a business decision or professional judgment. Conflicts do not automatically constitute a breach of the Code, but they must be identified, declared and appropriately managed.

1. Recognise. Be alert to situations where a personal or financial interest — including interests of close family members — could affect or appear to affect your judgment. Potential conflicts include personal relationships, financial stakes, secondary employment, gifts and outside business activities.
2. Declare. Report any actual or potential conflict to your manager or through the governance contact as soon as it is identified — before it affects a decision. Do not wait to see whether it matters.
3. Avoid improper influence. Do not participate in decisions, assessments or approvals where an undisclosed or unmanaged conflict exists. Recuse yourself from the relevant process until appropriate management is in place.
4. Seek guidance. If you are unsure whether a situation constitutes a conflict, seek guidance before acting. An appearance of conflict may be as significant as an actual one.
5. Record. Decisions made in the context of a declared conflict should be appropriately documented, including the nature of the declaration and any management measures taken.

Full requirements are set out in the Conflicts of Interest Policy.

The NOVARIC® Code of Ethics operates within and in support of applicable legal frameworks across our jurisdictions of operation. The table below identifies relevant legal instruments and their relationship to the Code. Listing an instrument is not a claim of certified compliance — it identifies the legal context within which the Code's principles apply.

This table is provided for governance information only. It does not constitute legal advice. The applicability of any instrument to a specific NOVARIC® entity or transaction depends on the facts of each situation. Instrument references are subject to verification and amendment.

The Code of Ethics is part of a wider NOVARIC® governance framework. The following documents provide more specific requirements and guidance across areas relevant to the Code.

When facing a decision where the ethical course is unclear, the following questions provide a structured starting point.

The following plain-language definitions apply to terms used in this Code. Where a term has a more specific meaning in applicable law or a NOVARIC® policy, that definition controls in the context of that instrument.