NOVARIC^® Doing Business Ethically Policy

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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.

EU Legal Basis: Treaty on European Union Art. 2 (values of the Union) | EU Charter of Fundamental Rights (2000/C 364/01) | Directive 2019/1937 (whistleblower protection) | GDPR EU 2016/679

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

Where stricter legal or regulatory requirements exist, those standards prevail.

EU Legal Basis: GDPR EU 2016/679 (data protection) | Directive 2000/43/EC (racial equality) | Directive 2000/78/EC (equal treatment) | Albanian Labour Code | Maltese Employment and Industrial Relations Act (Cap. 452)

1.3 Exceptions

No exceptions to this Policy are permitted.

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

Before any exchange of value, we assess whether it could be perceived as unethical. If so, it must not proceed.

EU Legal Basis: OECD Anti-Bribery Convention 1997 | UN Convention Against Corruption (UNCAC) 2003 | UK Bribery Act 2010 (international reference) | Albanian Penal Code Art. 195–244 (corruption offences) | Prevention of Corruption Act (Malta Cap. 568)

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 the NOVARIC^® GDPR Policy
• We avoid real or perceived conflicts of interest

EU Legal Basis: Directive 2013/34/EU (financial transparency and reporting) | GDPR EU 2016/679 (confidentiality and data protection) | Directive 2014/24/EU (fair competition and procurement) | EU Market Abuse Regulation EU 596/2014

3. Our Risk Framework

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

1. Define Clear Objectives. All activities must have transparent, legitimate, and documented purposes.
2. Assess Risk. Evaluate risks related to ethical breaches, bias, data misuse, and reputational impact.
3. Interact Appropriately. Act with integrity and comply with all relevant laws and policies.
4. Monitor and Improve. Continuously review outcomes, ensure compliance, and strengthen processes.

This framework ensures that risk is proactively managed and trust is maintained.

EU Legal Basis: ISO 31000:2018 (Risk Management) | Directive 2006/43/EC (statutory audits) | CSRD 2022/2464 (sustainability risk reporting) | CSDDD 2024 (supply chain due diligence)

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

All interactions must be ethical, transparent, and professional.

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

EU Legal Basis: Directive 2000/43/EC (racial equality) | Directive 2000/78/EC (equal treatment in employment) | Directive 2006/54/EC (gender equality) | Directive 2008/104/EC (temporary agency work) | Directive 2019/1152/EU (transparent working conditions)

Vocational Training

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

EU Legal Basis: Directive 2018/645/EU (professional qualifications) | European Qualifications Framework (EQF) Decision 2017/C 189/03 | Directive 2005/29/EC (unfair commercial practices)

Advisory and Consulting

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

EU Legal Basis: Directive 2014/65/EU (MiFID II — conflicts of interest standards) | GDPR Art. 28 (processor obligations in consulting engagements)

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.

EU Legal Basis: Directive 2014/24/EU (public procurement and transparency) | OECD Anti-Bribery Convention (funding and facilitation payments) | Directive 2013/34/EU (financial records)

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

When in doubt, the exchange must not proceed.

EU Legal Basis: OECD Anti-Bribery Convention | Prevention of Corruption Act (Malta Cap. 568) | Albanian Penal Code (corruption and undue influence) | Directive 2003/88/EC (proportionality standards in employment)

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

NOVARIC^® remains accountable for all third-party actions performed on its behalf.

EU Legal Basis: GDPR Art. 28 (processor agreements and vendor accountability) | CSDDD 2024 (supply chain due diligence) | Directive 2014/24/EU (procurement standards) | ISO 37001:2016 (anti-bribery management systems)

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

Data integrity is fundamental to trust.

EU Legal Basis: GDPR EU 2016/679 (data protection and privacy) | EU AI Act 2024 (responsible AI use and transparency) | Directive 2016/1148/EU (NIS Directive — network and information security) | EU Cybersecurity Act (ENISA Regulation EU 2019/881)

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

EU Legal Basis: Directive 2006/43/EC (statutory audit requirements) | ISO 19600:2014 (compliance management systems) | ISO 37001:2016 (anti-bribery management) | CSRD 2022/2464 (sustainability controls and reporting)

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 the Misconduct Reporting Procedure.

NOVARIC^® ensures confidentiality and fair investigation processes for all reported concerns.

EU Legal Basis: Directive 2019/1937 (whistleblower protection) | GDPR Art. 82 (liability for data breaches) | Maltese Whistleblower Protection Act (Cap. 527) | Albanian Law on Protection of Whistleblowers

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

Retaliation is strictly prohibited.

EU Legal Basis: Directive 2019/1937 (EU Whistleblower Protection Directive) | GDPR Art. 5(1)(f) (integrity and confidentiality) | Maltese Whistleblower Protection Act (Cap. 527) | Albanian Law on Protection of Whistleblowers No. 60/2016

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

Every decision reflects who we are.

At NOVARIC^®, we do what is right—consistently, responsibly, and with purpose.

EU & International Legal Compliance Matrix

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