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NOVARIC^® Doing Business Ethically Policy

Ethics, Risk & Compliance Framework

Governing ethical conduct, risk management and compliance across all NOVARIC^® business activities

1. Introduction

1.1 Purpose

At NOVARIC^®, we shape the future of work by connecting people with opportunities through ethical, transparent, and responsible workforce solutions.

This Policy establishes the standards that govern how we conduct business across recruitment, vocational training, HR consulting, relocation, and outsourcing services. It reinforces our commitment to integrity, trust, and compliance, ensuring that all external interactions reflect the highest ethical standards.

It builds on the NOVARIC^® Code of Ethics and translates principles into operational expectations for daily decision-making.

1.2 Scope and Applicability

This Policy applies to:

• All NOVARIC^® employees, leadership, and representatives
• All interactions with external stakeholders, including candidates, employers, institutions, partners, vendors, and public authorities

It governs situations where there is potential risk of:

• Bribery or corruption
• Conflicts of interest
• Unethical influence or decision-making
• Misuse of data, information, or professional position

All activities must comply with:

• Applicable local and international laws
• EU regulations, including GDPR (EU 2016/679)
• Industry standards and internal NOVARIC^® policies

1.3 Exceptions

1.4 Roles and Responsibilities

2. Our Ethical Commitments

2.1 Zero Tolerance for Bribery and Corruption

NOVARIC^® does not tolerate any form of bribery, corruption, or improper influence.

We commit that:

• We do not offer, give, or accept anything of value to improperly influence decisions
• We do not use third parties to engage in unethical practices
• We do not make facilitation payments, regardless of local custom
• We apply the same standards across public and private sectors

2.2 High Standards of Ethical Business Conduct

We are accountable for how we act, decide, and engage.

We commit that:

• All interactions are transparent, fair, and professionally justified
• Services and engagements have clear, legitimate business objectives
• Compensation is fair, reasonable, and aligned with market value
• We respect confidentiality, privacy, and data protection at all times — governed by NOVARIC® GDPR Policy
• We avoid real or perceived conflicts of interest

3. Our Risk Framework

NOVARIC^® applies a structured risk-based approach to all external interactions.

4. Our Interactions

NOVARIC^® engages with a wide range of stakeholders including:

• Candidates and jobseekers
• Employers and corporate clients
• Educational institutions and training partners
• Government and regulatory authorities
• Service providers and vendors

4.1 Engagement

We only work with reputable stakeholders who meet our ethical standards.

We ensure:

• All engagements have a clear purpose and documented scope
• Services are legitimate and verifiable
• Compensation reflects fair market value
• No engagement is used to improperly influence decisions

Recruitment Services

• Candidate selection is merit-based, fair, and unbiased
• No candidate is favoured due to improper incentives
• Information provided to candidates and clients is accurate and transparent

Vocational Training

• Programmes are designed to enhance employability and skills
• Certifications reflect genuine achievement
• Training is never misleading or exploitative

Advisory and Consulting

• Recommendations are objective and evidence-based
• Client interests are served without conflict or bias

4.2 Funding and Collaborations

We may collaborate with institutions and organisations to advance workforce development and social impact.

We ensure:

• All collaborations have clear, documented objectives
• Funding is transparent, reasonable, and properly recorded
• No funding is used to gain unfair advantage
• Only reputable organisations are supported

We do not provide funding to individuals in ways that could influence professional decisions.

4.3 Gifts, Hospitality, and Benefits

We strictly prohibit improper incentives.

We commit that:

• No gifts, payments, or benefits are provided to influence decisions
• Cash or cash-equivalent gifts are never permitted
• Hospitality must be modest, reasonable, and business-related
• Gifts, if allowed, must be infrequent, transparent, and compliant with laws

5. Use of Third Parties

We engage third parties only when:

• They meet NOVARIC^® ethical and compliance standards
• Proper due diligence has been conducted
• A formal agreement is in place
• Services and pricing are justified and documented

6. Data, Technology, and Confidentiality

We are committed to responsible data and technology use.

We ensure:

• Full compliance with GDPR (EU 2016/679) and applicable data protection laws
• Secure handling of candidate, client, and partner data
• Ethical use of AI and digital tools in recruitment and HR processes — governed by the NOVARIC^® Nexus AI Operations Governance
• Protection of confidential and proprietary information

7. Controls

NOVARIC^® maintains internal controls to ensure compliance, including:

• Risk monitoring systems
• Approval and documentation procedures
• Regular audits and reviews
• Training and awareness programmes

8. Breach of This Policy

Violations of this Policy may result in:

• Corrective actions
• Disciplinary measures
• Termination of employment or partnerships

All suspected or actual misconduct must be reported through official channels — see Misconduct Reporting Procedure.

9. Speak-Up and Non-Retaliation

We foster a culture where concerns can be raised safely.

We commit to:

• Providing confidential reporting channels — Misconduct Reporting Procedure
• Investigating all concerns objectively
• Protecting individuals who report in good faith

10. Definitions

11. Closing Statement

Doing business ethically is central to NOVARIC^®’s identity and long-term success.

By upholding this Policy, we:

• Strengthen trust with clients, candidates, and partners
• Protect the integrity of our services
• Contribute to a fair, inclusive, and sustainable labour market

. EU & International Legal Compliance Matrix

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

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