NOVARIC^® Ethical Recruitment & Candidate Protection Standard

This Standard sets out NOVARIC^®'s institutional commitment to ethical recruitment and the protection of candidates throughout every stage of the recruitment, placement and mobility process. It applies to:

• All NOVARIC^® internal recruitment operations and personnel
• All approved partners acting under a NOVARIC^® cooperation agreement
• All programme activities including workforce mobility, skills placement, education advisory and international referral services
• Any third party that has been approved to represent NOVARIC^® in a candidate-facing capacity

Ethical recruitment is not merely a compliance obligation — it is the foundation of NOVARIC^®'s value proposition. Candidates who engage with NOVARIC^® and its partners must be able to trust that the information they receive is accurate, that their interests are protected, and that they will not be exploited or misled.

This document is a Draft pending legal approval. It reflects NOVARIC^®'s intended standard. Upon approval, it will form part of the partner governance framework and will be binding on all approved partners.

NOVARIC^® affirms the inherent dignity of every worker and candidate. Every person who engages with our services is entitled to:

All recruitment processes conducted by NOVARIC^® and its partners must be transparent. Transparency means that candidates can understand:

• Who they are dealing with — including the full legal name of the partner or organisation
• What the process involves — the steps, timelines and decision points
• What information is being collected and why
• Who will have access to their information
• What the likely outcome range is — and what factors influence it
• What their rights are, including the right to withdraw
• How to raise a complaint or concern

Transparency does not require disclosure of commercially sensitive information that is legitimately confidential. But it does require that candidates are never left confused about where they stand, what is expected of them or what will happen next.

All employment, education and programme opportunities presented to candidates must be accurately and fairly described. NOVARIC^® and its partners must ensure that:

• Job roles, duties and working conditions are described in line with what has been confirmed by the employer
• Salary, compensation and benefits are stated accurately and are not inflated to attract candidates
• Working hours, shift patterns and location requirements are disclosed
• Qualification and language requirements are stated clearly, so candidates can self-assess their eligibility
• Visa or immigration requirements are disclosed, with honest information about the process involved
• Education programme fees, entry requirements and expected outcomes are stated in full
• Material changes to an opportunity are communicated to candidates without delay

It is not permissible to describe an opportunity in terms that would be materially different from a reasonable candidate's experience if they proceeded. Where uncertainty exists — for example, because an employer has not yet confirmed all terms — this must be clearly communicated to the candidate before they invest time or resources in an application.

Deception and misrepresentation are absolutely prohibited in all NOVARIC^®-connected recruitment activity. Any partner found to have engaged in deceptive practices will face immediate suspension and referral to relevant authorities.

Prohibited forms of deception include:

• Describing a position or programme in terms materially different from reality to induce a candidate to apply
• Promising employment, visa approval, admission or any other regulated outcome that the partner cannot guarantee
• Implying that NOVARIC^® or any partner has special influence with government authorities, embassies or educational institutions
• Creating false urgency — for example, claiming that only a few places remain when this is untrue
• Omitting material facts that a reasonable candidate would consider important to their decision
• Presenting unconfirmed or speculative opportunities as live, confirmed vacancies
• Misrepresenting the identity, scale or credentials of the partner organisation
• Using fabricated testimonials, case studies or placement statistics

The payment of fees by workers and candidates as a condition of access to employment or programme participation is a globally recognised risk factor for labour exploitation. NOVARIC^®'s approach to recruitment fees is grounded in this understanding and reflects internationally recognised fair recruitment principles.

The core principle is straightforward: workers and candidates should never bear the cost of being recruited. This principle applies regardless of the terminology used to describe the payment, the means by which it is collected, or the market in which the recruitment takes place.

NOVARIC^® references internationally recognised fair-recruitment principles — including those articulated by the International Labour Organization (ILO) in its General Principles and Operational Guidelines for Fair Recruitment, and by the International Organization for Migration (IOM) under the International Recruitment Integrity System (IRIS) — as guidance for the development and ongoing review of this Standard. Reference to an external standard does not imply certification, accreditation or endorsement by any external body.

NOVARIC^® operates on an employer-pays model for recruitment services. This means:

• Fees charged for recruitment, matching, shortlisting and placement services are borne by the hiring employer or institution
• Candidates are not charged for participation in the recruitment process facilitated by NOVARIC^® or its approved partners
• Fee structures agreed with employers must not be structured in a way that is effectively recovered from candidates through wage deductions, salary withholding or equivalent mechanisms
• Partners must not enter into arrangements with employers that result in recruitment costs being passed to workers

The employer-pays standard applies to all recruitment activities conducted by or through NOVARIC^® and its partners. Where a partner operates independent services that are separately fee-bearing, these must be clearly separated and must not be presented as a condition of participation in any NOVARIC^® programme.

Where a partner offers candidate-facing services that carry a legitimate fee — such as independent careers coaching, certified language assessment or skills training conducted outside the scope of a NOVARIC^® referral — the following requirements apply:

• The service must be genuinely distinct from the NOVARIC^® referral process — it must not be a precondition for receiving a referral
• The fee and its purpose must be disclosed to the candidate in writing before any commitment is made
• The candidate must be told explicitly that this service is separate from — and not required for — any NOVARIC^® programme
• The partner must not use their NOVARIC^® partner status as a selling point for the separate fee-bearing service
• Any such service must comply with all applicable consumer protection and advertising regulations

Partners who are uncertain whether a proposed service arrangement complies with this section must seek written guidance from NOVARIC^® before proceeding.

Official fees payable directly to a government authority — such as visa application fees submitted by a candidate to an embassy or immigration authority — are not recruitment fees and are not prohibited by this Standard. However, the following rules apply:

• Partners must not act as financial intermediaries for government fee payments without written authorisation from NOVARIC^®
• Candidates must be directed to official government channels for fee payment — not to partner accounts or third-party payment platforms
• Partners must provide candidates with accurate, current information about official government fee amounts. They must not inflate or misrepresent these figures
• Partners must not add handling charges, administration fees or commission to government fees
• Where official fees are paid directly by a candidate to a government authority, this must be clearly documented and distinguishable from any other payments

Candidates should always verify official government fees directly with the relevant authority (e.g. embassy, immigration department, national registry) before making any payment. NOVARIC^® does not handle government fee payments on behalf of candidates.

No partner or representative of NOVARIC^® may request or accept any payment from a candidate in connection with any recruitment, placement or programme activity conducted under or associated with the NOVARIC^® name.

Payments that are absolutely prohibited include:

• Registration, application or administration fees
• Processing charges for CVs, documents or applications
• Visa or immigration "service fees" paid to a partner rather than to the government authority
• Training or orientation fees presented as mandatory for placement
• Deposits or bonds supposedly refundable upon commencement of employment
• Any payment described as a "contribution", "investment", "placement bond" or similar
• Payments to secure priority processing or a "guaranteed" outcome
• Payments to any undisclosed sub-agent or intermediary in connection with a NOVARIC^®-branded process

Any candidate who has been asked to make a payment of any kind in connection with a NOVARIC^®-branded process should report this immediately via the Fraud Awareness & Misconduct Reporting channel.

NOVARIC^® and its partners are committed to equal opportunity in all aspects of the recruitment process. Selection decisions must be based on relevant skills, qualifications and experience — not on characteristics unrelated to the role or programme requirements.

Discrimination — whether direct or indirect — is prohibited on grounds including:

Where an employer specifies selection criteria that may give rise to concerns about indirect discrimination, the partner must raise this with NOVARIC^® before proceeding. Partners must not facilitate placements that contravene applicable anti-discrimination law, regardless of what an employer requests.

The confiscation, retention, withholding or destruction of a candidate's identity documents is absolutely prohibited. This applies to all NOVARIC^® partners and representatives under any circumstance.

A candidate's passport, identity card, residence permit, travel document or any equivalent official document remains at all times the property of the candidate. No partner may take possession of, or exercise any form of control over, a candidate's identity documents.

Where copies of identity documents are required for verification purposes:

• Copies must be collected only for a clearly stated, legitimate purpose
• The candidate must be informed of why the copy is needed and how it will be used
• Copies must be transmitted only through a secure channel designated by NOVARIC^®
• Copies must be stored securely with access restricted to authorised personnel
• Copies must be destroyed securely once no longer required for the stated purpose
• Copies must not be shared with third parties without explicit written consent and a lawful basis

Candidate personal data is collected and processed for the purpose of facilitating their participation in recruitment or programme activities. NOVARIC^® and its partners must handle this data in compliance with applicable data protection legislation, including the GDPR where relevant.

Partners must ensure that:

• Candidates are provided with a clear privacy notice at the point of data collection
• Data is collected only to the extent necessary for the recruitment or programme purpose
• Data is not retained beyond the period necessary for the purpose for which it was collected
• Data is not transferred to third parties without a lawful basis and, where required, explicit consent
• Candidates can exercise their rights under applicable data protection law — including access, correction and deletion
• Personal data is protected by appropriate technical and organisational security measures

The full NOVARIC^® Data Protection & Privacy Policy is available at novaric.eu/en/governance/.

Every candidate has the right to raise a complaint about the conduct of any NOVARIC^® partner or representative, and to receive a timely and substantive response. Partners must:

• Maintain an accessible, confidential complaints mechanism
• Acknowledge complaints within five working days
• Investigate complaints fairly and without prejudice
• Communicate outcomes and any remedial action to the complainant
• Forward to NOVARIC^® any complaint that alleges a breach of this Standard or the Partner Code of Conduct

Candidates may also report concerns directly to NOVARIC^® at any time through the Fraud Awareness & Misconduct Reporting channel, regardless of whether they have first raised the matter with the partner. NOVARIC^® investigates all credible reports of partner misconduct.

Candidates who have been asked to pay any fee, who have been promised a guaranteed outcome, or whose documents have been withheld should report this to NOVARIC^® immediately. These are serious red flags for fraud and exploitation.

Where AI-assisted tools are used in any part of the recruitment or screening process — including CV screening, candidate ranking, interview scheduling or communication generation — the following requirements apply:

• No candidate-facing decision may be communicated without prior human review of the AI output
• AI tools used for shortlisting or ranking must be subject to regular review for bias and discriminatory outputs
• Candidates must be informed when AI tools have been used in their assessment, where this is required by applicable law
• Partners must not use AI tools to generate fabricated candidate profiles, synthetic references or misleading application materials
• AI-generated communications must be reviewed for accuracy before dispatch — particularly where they convey information about opportunity terms, timelines or decisions

The NOVARIC^® Responsible AI Policy (DOC-GOV-002) provides further guidance on the responsible use of AI tools across NOVARIC^® operations and the partner network.

The ethical recruitment principles in this Standard apply equally to education placement activities, including the recruitment of students and learners for further and higher education programmes, vocational training and professional development courses.

Specific requirements for education placement activities include:

• Programme fees, entry requirements and expected learning outcomes must be stated accurately and in full
• Institution names, accreditation status and qualification recognition must not be misrepresented
• Learners must be provided with clear information about their rights, including refund and withdrawal policies
• Commission arrangements with educational institutions must not create incentives to recruit unsuitable candidates
• Partners must not present an institution's acceptance rate, completion rate or graduate outcomes in a misleading manner
• Education placement fees charged to institutions must not be structured in a way that is effectively recovered from learners

Any partner offering education advisory services must hold relevant authorisations where required by the law of their operating jurisdiction.

NOVARIC^® draws on the following internationally recognised frameworks and principles as guidance in developing and maintaining this Standard:

NOVARIC^® references internationally recognised fair-recruitment principles as guidance. Reference to an external standard does not imply certification, accreditation or endorsement by any external body. NOVARIC^® does not claim ILO endorsement, IRIS certification or any other formal accreditation unless separately stated and verified.

If you are a candidate engaging with a recruitment process that is said to involve NOVARIC^®, use this checklist to protect yourself:

• Verify the partner is listed as an approved NOVARIC^® partner at novaric.eu/en/governance/partner-verification/
• Confirm that you have not been asked to pay any fee to a partner or intermediary — recruitment through NOVARIC^® is free to candidates
• Check that the opportunity has been described clearly and in writing — not just verbally or by voice call
• Verify that you have not been promised a guaranteed employment, visa or admission outcome — no one can guarantee these
• Confirm that your identity documents are in your possession and have not been withheld by anyone
• Check that the employer or institution has been named and that you have been given verifiable contact details
• Confirm that you have been given clear information about the process timeline and next steps
• Check that you know how to make a complaint and who to contact if something goes wrong
• If you have been contacted by someone claiming to represent NOVARIC^® through a personal WhatsApp or social media account, verify this independently — NOVARIC^® does not conduct official processes through personal accounts
• If anything feels wrong, report it immediately via novaric.eu/en/governance/fraud-awareness/

If you have been asked to pay money, your documents have been withheld, or you have been promised a guaranteed outcome in exchange for payment — these are serious warning signs of fraud. Stop, do not pay, and report it immediately.

This Standard is maintained under the NOVARIC^® document-control framework. The authoritative version is the English-language text published at the canonical URL. In the event of any discrepancy between a translated version and the English text, the English text prevails. NOVARIC^® will notify approved partners of material changes to this Standard. Continued operation as an approved partner following notification constitutes acceptance of the updated terms.