Doing What’s Right: NOVARIC® Code of Ethics

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Doing What’s Right: NOVARIC® Code of Ethics

Our commitment to integrity, transparency, and responsible business conduct

Document ID: NOVARIC-POL-COE-001 Version: v1.0 Effective: March 2026 Review: March 2027
Owner: NOVARIC® Legal & Compliance Division Classification: Public Status: Active

Message from Leadership

At NOVARIC®, we believe that the future of work is built on trust, integrity, and opportunity. Every interaction—with candidates, clients, partners, and each other—shapes not only our reputation but also the careers and lives we influence.

This Code of Ethics defines how we act, how we make decisions, and how we hold ourselves accountable. It is more than a document—it is a commitment to doing what is right, even when it is not the easiest path.

By living this Code, we reinforce our role as a trusted partner in shaping inclusive, sustainable, and forward-looking workforce solutions across Europe and beyond.

Purpose of the Code

The NOVARIC® Code of Ethics establishes the principles and standards that guide our conduct across all business activities, including recruitment, vocational training, HR consulting, relocation, and outsourcing.

It ensures that:

  • Our decisions reflect integrity and responsibility
  • Our actions align with legal and regulatory requirements, including GDPR (EU 2016/679)
  • Our services create fair, inclusive, and sustainable opportunities

This Code applies to all employees, leadership, partners, and representatives acting on behalf of NOVARIC®.

EU Legal Basis: EU Charter of Fundamental Rights (2000/C 364/01)  |  Treaty on the Functioning of the European Union (TFEU) Art. 157 (equal pay)  |  Directive 2000/43/EC (racial equality)  |  Directive 2000/78/EC (equal treatment in employment)

Living the Code

Living the Code means embedding ethical thinking into everyday decisions. It requires:

  • Acting with integrity in all professional situations
  • Asking questions when something feels unclear or incorrect
  • Speaking up when standards are not met
  • Leading by example at every level of the organisation
Ethics is not situational—it is foundational.

Our Ethical Principles

Be Inclusive

We value diversity in all its forms and actively promote equal opportunity. We create environments where individuals feel respected, heard, and empowered.

Be Honest

We communicate transparently and act with integrity. We build trust through truthfulness in our commitments, data, and interactions.

Be Courageous

We speak up, challenge unfair practices, and address ethical concerns proactively. We stand for what is right, even in difficult situations.

Be Accountable

We take responsibility for our actions, decisions, and their impact on people, businesses, and society.

EU Legal Basis: EU Whistleblower Protection Directive 2019/1937 (speak-up and non-retaliation)  |  Directive 2006/54/EC (equal opportunities and equal treatment)  |  UN Guiding Principles on Business and Human Rights

Our Commitments to Candidates and Clients

Why It Matters

We connect people with opportunities that shape their careers and lives. Trust is essential in every placement, training programme, and advisory service we deliver.

Our Commitment

We provide fair, transparent, and high-quality services that prioritise the dignity, privacy, and potential of every individual.

We Will

  • Ensure fair and unbiased recruitment processes, including blind recruitment practices
  • Promote equal opportunity and prevent discrimination in all hiring activities
  • Provide accurate and honest information to candidates and clients
  • Deliver high-quality vocational training aligned with market needs
  • Protect candidate and client data in full compliance with GDPR (EU 2016/679)
  • Act in the best interest of long-term employability and career development
EU Legal Basis: Directive 2008/104/EC (temporary agency work)  |  Directive 2019/1152/EU (transparent and predictable working conditions)  |  GDPR EU 2016/679 (data protection)  |  Directive 2000/43/EC (racial equality in employment)  |  Directive 2000/78/EC (equal treatment in employment and occupation)

Our Commitments to Our People

Why It Matters

Our people are the foundation of our success. A respectful, inclusive, and safe workplace enables innovation and excellence.

Our Commitment

We foster a culture where everyone can thrive, contribute, and grow.

We Will

  • Promote a diverse, equitable, and inclusive workplace
  • Ensure fair employment practices and equal opportunities
  • Maintain a zero-tolerance approach to harassment, discrimination, and retaliation
  • Support employee wellbeing, safety, and professional development — see Health & Safety Policy
  • Protect confidential and sensitive information in accordance with GDPR
  • Encourage open dialogue and respectful collaboration
EU Legal Basis: Directive 89/391/EEC (health and safety at work)  |  Directive 2006/54/EC (equal opportunities, equal treatment)  |  Directive 2019/1937 (whistleblower protection)  |  Albanian Law 10237/2010 (health and safety)  |  Maltese OHSA Cap. 424

Our Commitments to Business Integrity

Why It Matters

Integrity ensures the sustainability of our business and the trust of our stakeholders.

Our Commitment

We conduct all business activities ethically, transparently, and in compliance with applicable laws and regulations.

We Will

  • Maintain accurate financial records and transparent reporting
  • Prevent fraud, bribery, and corruption in all forms
  • Avoid conflicts of interest and disclose them when they arise
  • Compete fairly and ethically in the marketplace
  • Use data, technology, and AI responsibly and securely — governed by the NOVARIC® Nexus AI Operations Governance
  • Ensure operational resilience and continuity
EU Legal Basis: EU Anti-Bribery Framework & OECD Anti-Bribery Convention  |  Directive 2013/34/EU (financial reporting and transparency)  |  EU AI Act 2024 (responsible AI use)  |  GDPR EU 2016/679 (data and technology)  |  Albanian Penal Code (anti-fraud)  |  Malta Competition Act (fair competition)

Our Commitments to External Partners

Why It Matters

Our partners extend our impact. Their conduct reflects on our reputation.

Our Commitment

We collaborate only with partners who share our ethical standards and values.

We Will

  • Conduct due diligence when selecting partners and vendors
  • Promote ethical procurement and responsible sourcing
  • Ensure transparency in all business relationships
  • Manage conflicts of interest responsibly
  • Uphold professional conduct in all engagements
  • Encourage partners to adopt inclusive and sustainable practices
EU Legal Basis: Directive 2014/24/EU (public procurement)  |  GDPR Art. 28 (processor agreements and vendor governance)  |  UN Global Compact Principles (supply chain ethics)  |  EU Corporate Sustainability Due Diligence Directive (CSDDD) 2024

Our Commitments to Society and the Environment

Why It Matters

As a workforce solutions provider, we influence economic growth, social inclusion, and environmental responsibility.

Our Commitment

We contribute positively to society while minimising our environmental impact.

We Will

  • Support Diversity, Equity, and Inclusion (DEI) across all services
  • Advance access to employment and vocational training opportunities
  • Uphold human rights in all operations and partnerships
  • Implement and expand the NOVARIC® Green Initiative
  • Reduce environmental impact through responsible practices
  • Promote ethical use of technology and data
  • Contribute to sustainable workforce development
EU Legal Basis: EU Green Deal & European Climate Law (Regulation EU 2021/1119)  |  UN Sustainable Development Goals (SDGs 4, 8, 10, 13)  |  EU Corporate Sustainability Reporting Directive (CSRD) 2022/2464  |  EU Directive 2000/43/EC (anti-discrimination)  |  UN Guiding Principles on Business and Human Rights  |  European Pillar of Social Rights

Our Responsibilities

Every individual at NOVARIC® is responsible for upholding this Code.

We Are Expected To

  • Understand and apply the Code in daily work
  • Act with integrity in all decisions
  • Report concerns or violations in good faith via the Misconduct Reporting Procedure
  • Cooperate with internal reviews and investigations
Failure to comply with this Code may result in corrective or disciplinary action.

Speak-Up and Non-Retaliation

We are committed to a culture where concerns can be raised safely and confidently.

Our Commitment

  • Provide secure and confidential channels for reporting concerns — see Misconduct Reporting Procedure
  • Investigate all reports fairly and objectively
  • Protect individuals who report concerns in good faith
Retaliation against anyone who raises a concern is strictly prohibited.
Speaking up is not only a right—it is a responsibility.
EU Legal Basis: EU Whistleblower Protection Directive 2019/1937  |  GDPR Art. 82 (liability and right to compensation)  |  Maltese Whistleblower Protection Act (Cap. 527)  |  Albanian Law on Protection of Whistleblowers

Closing Remarks

At NOVARIC®, ethics is not a constraint—it is a competitive advantage. It strengthens our credibility, deepens trust, and ensures sustainable growth.

By doing what is right, we:

  • Empower individuals
  • Strengthen organisations
  • Contribute to a more inclusive and sustainable future of work

Every decision matters. Every action counts.

Together, we uphold the standards that define who we are.

EU Legal Compliance Framework

This Code of Ethics is aligned with and supported by the following EU directives, regulations, and international frameworks:

Framework / Directive Area Covered
GDPR (EU 2016/679) Data protection, candidate & client privacy
Directive 2000/43/EC Racial equality and non-discrimination
Directive 2000/78/EC Equal treatment in employment and occupation
Directive 2006/54/EC Equal opportunities and equal treatment (gender)
Directive 2019/1152/EU Transparent and predictable working conditions
Directive 2019/1937 Whistleblower protection and speak-up culture
Directive 89/391/EEC Health and safety at work
Directive 2008/104/EC Temporary agency work
Directive 2014/24/EU Public procurement and ethical sourcing
Directive 2013/34/EU Financial reporting and transparency
CSRD 2022/2464 Corporate sustainability reporting
CSDDD 2024 Corporate sustainability due diligence (supply chain)
EU AI Act 2024 Responsible and transparent use of AI systems
European Climate Law (EU 2021/1119) Environmental responsibility and green commitments
EU Charter of Fundamental Rights Human dignity, equality, solidarity, justice
UN Guiding Principles on Business and Human Rights Human rights due diligence and responsible conduct

Related NOVARIC® Documents

Document Reference
Company Governance NOVARIC-POL-CG-001
Workplace Policy
Employee Handbook
GDPR & Privacy Policy NOVARIC-POL-GD-001
Misconduct Reporting Procedure NOVARIC-POL-MR-001
Health & Safety Policy N-DOC-10008-032026
Governance Hub N-HUB-GOV

Published under NOVARIC® Resources  |  NOVARIC® Governance Hub

Version: v1.0  |  Effective: March 2026  |  Review: March 2027  |  Document ID: NOVARIC-POL-COE-001

NOVARIC® — The Future Starts At The Endgame.™  |  C 63881 — Malta  |  EU Trademark: 018313401  |  NOVARIC® Resources