NOVARIC^® International Partner Code of Conduct

This Code of Conduct sets out the minimum behavioural, operational and ethical standards that every approved and prospective partner of NOVARIC^® is required to observe. It applies to all individuals and organisations acting under a NOVARIC^® cooperation, referral or representation arrangement, regardless of geography, sector or the nature of the underlying engagement.

NOVARIC^® operates across recruitment, workforce mobility, education placement and professional development. In each domain, the integrity of the partner network directly shapes outcomes for candidates, employers, institutions and the communities they serve. Partners are therefore expected to embody — not merely comply with — the principles contained in this Code.

This Code is a living document. It reflects evolving international standards on fair recruitment, data protection, anti-corruption and responsible technology use. Partners are expected to familiarise themselves with the current version and to seek clarification from NOVARIC^® where any provision is unclear.

This document is a Draft pending legal approval. It does not yet constitute a binding contractual instrument. Upon approval, it will be incorporated by reference into the NOVARIC^® Partner Assurance & Cooperation Framework.

Partners must conduct themselves with the highest standards of professional integrity in all dealings with candidates, employers, educational institutions, public authorities and NOVARIC^® personnel. Professional integrity encompasses:

• Honesty in all representations made on behalf of or in connection with NOVARIC^®
• Transparency about the partner's identity, role and limitations
• Avoidance of conflicts of interest, or prompt disclosure where they arise
• Respect for confidentiality obligations in all communications
• Maintenance of professional competence relevant to the services provided
• Accountability for the actions of employees, agents and sub-representatives

A partner who becomes aware of conduct — by themselves, their staff or any associated party — that may constitute a breach of this Code must report the matter promptly to NOVARIC^® through the designated reporting channel.

Partners must maintain full compliance with all applicable laws and regulations in the jurisdictions in which they operate. This includes, without limitation:

• Employment and labour law, including rules on lawful engagement, working conditions and worker rights
• Immigration and visa regulations of origin, transit and destination countries
• Licensing and registration requirements for recruitment, placement or education-related activities
• Anti-money laundering (AML) and counter-terrorist financing (CTF) obligations
• Data protection legislation, including the EU General Data Protection Regulation (GDPR) where applicable
• Anti-bribery and corruption statutes, including local equivalents of the UK Bribery Act and FCPA principles
• Consumer protection and advertising standards relevant to candidate-facing communications

Partners must hold any licence, permit or registration required by law to carry out recruitment, placement or educational advisory activities in their jurisdiction. Evidence of such authorisations must be provided to NOVARIC^® upon request and whenever a material change occurs.

A partner operating without required regulatory authorisation may not represent themselves as affiliated with NOVARIC^® and must cease partner activities immediately pending resolution.

NOVARIC^® is committed to fair recruitment principles consistent with ILO General Principles on Fair Recruitment and IOM IRIS guidance. Partners share this commitment and must at all times:

• Ensure that all recruitment activities are transparent, legal and free from deception
• Provide candidates with accurate, complete and timely information about roles, terms and processes
• Obtain genuine, informed consent from candidates before proceeding with any application
• Refrain from making promises or representations that exceed what NOVARIC^® or an employer has confirmed in writing
• Actively support candidates in understanding their rights, including the right to withdraw at any stage
• Maintain accurate records of candidate interactions, consents and placements

Partners may not engage in deceptive or high-pressure recruitment tactics. This includes creating artificial urgency, withholding material information about a role, or selectively presenting terms to induce a candidate to accept an engagement they would otherwise decline.

Every candidate must be treated with dignity, respect and fairness throughout the recruitment process. Partners must not discriminate against any candidate on the basis of:

Where an employer or institution specifies selection criteria that could constitute indirect discrimination, the partner must flag this to NOVARIC^® before proceeding. Partners may not facilitate placements that breach applicable anti-discrimination law.

Partners must also ensure that their own internal processes — including shortlisting, screening interviews and candidate communications — are free from bias and that any AI-assisted screening tools are subject to human review before decisions are communicated to candidates.

All job postings, programme listings and educational placement opportunities presented to candidates by or through a NOVARIC^® partner must be accurate, current and clearly described. Partners must ensure that:

• Role titles and descriptions reflect the actual duties and working conditions
• Compensation, benefits and allowances are stated in full without misleading omissions
• Location, working hours and shift patterns are clearly communicated
• Visa, permit or qualification requirements are disclosed upfront
• Programme fees for education placements — where applicable — are stated transparently and in advance
• Any material changes to an opportunity are communicated to candidates without delay

Partners must not circulate hypothetical, speculative or unconfirmed opportunities as though they were live. Where an opportunity is subject to employer or institutional confirmation, this must be clearly stated.

Partners must provide candidates with clear and verifiable information about prospective employers, host institutions or placement organisations, including:

• The legal name and registered address of the employer or institution
• The nature of the employment relationship and any third-party engagement structures
• The applicable terms and conditions of employment or study
• The contact details of a responsible person at the employer or institution
• Any probationary period, trial engagement or conditional offer conditions

Partners may not withhold employer identity from candidates as a commercial protection measure once a conditional offer has been made. Where confidentiality is required at an earlier stage for legitimate commercial reasons, this must be communicated to the candidate explicitly and time-limited.

NOVARIC^® operates on an employer-pays model for recruitment fees. Partners must uphold this principle in all arrangements they facilitate.

Recruitment service fees charged for the matching, assessment, shortlisting or placement of candidates are the responsibility of the hiring employer or institution — not the candidate. Partners must never structure their fee arrangements in a way that effectively shifts this burden onto candidates, whether directly or indirectly.

Where a partner operates their own fee structures for distinct services (for example, independent careers coaching or skills assessments that are not part of the NOVARIC^® referral), these must be:

• Clearly separated from any NOVARIC^®-branded activity
• Disclosed transparently to the candidate before any commitment is made
• Consistent with applicable law and with the employer-pays principle as applied to core recruitment
• Not presented as a precondition for participation in any NOVARIC^® programme or referral process

Partners must not request, accept or facilitate any payment from a candidate in connection with a recruitment, placement or programme activity conducted under or associated with the NOVARIC^® name or framework.

Prohibited payments include, but are not limited to:

• Registration or administration fees
• Application processing charges
• Visa or immigration "service" fees paid to the partner (as distinct from official government fees paid directly to a government authority)
• Training, orientation or induction fees presented as a condition of placement
• Deposit or bond payments purportedly refundable upon commencement
• Fees for CV preparation, translation or document handling that are presented as mandatory
• Any payment described as a "contribution", "investment" or "partnership fee" from the candidate

This prohibition applies regardless of how the payment is labelled or structured. If in doubt, partners must seek written confirmation from NOVARIC^® before requesting any payment from a candidate.

Government fees: Official fees payable directly to a government authority (such as visa application fees submitted to an embassy or immigration authority) are not recruitment fees and are not prohibited. However, partners must not act as intermediaries for such payments without written authorisation from NOVARIC^®.

Partners must never confiscate, retain, withhold or destroy a candidate's identity documents — including passports, national identity cards, residence permits or travel documents — under any circumstances.

Where a partner receives copies of identity documents for legitimate verification purposes, they must:

• Collect only what is strictly necessary for the stated purpose
• Store copies securely with appropriate access controls
• Retain copies only for the minimum period required by law or the specific process
• Destroy copies securely once the retention period expires
• Never share or transfer copies to third parties without the candidate's explicit written consent and a lawful basis under applicable data protection law

The handling of identity document copies must comply with the NOVARIC^® Data Protection & Privacy Policy and applicable GDPR obligations. Sensitive document transmission must use secure channels designated by NOVARIC^® — not standard unencrypted email or public messaging applications.

Partners receive access to confidential information — including candidate personal data, employer briefs, placement terms and NOVARIC^® operational information — solely for the purpose of delivering agreed partner services. This information must:

• Be used only for the purpose for which it was shared
• Not be disclosed to any third party without prior written authorisation
• Be protected by appropriate technical and organisational security measures
• Be subject to data minimisation principles — partners should not collect more than is needed
• Be deleted or returned to NOVARIC^® upon request or upon termination of the partnership

Breach of confidentiality obligations is a serious matter that may result in immediate suspension of the partner relationship, legal action and notification to relevant regulatory authorities.

Partners must communicate with candidates, employers and NOVARIC^® through channels that have been agreed and are appropriate for the sensitivity of the information being exchanged. In particular:

• Substantive candidate communications should use email accounts that clearly identify the partner organisation
• Offers, agreements and programme terms must be documented in writing, not communicated solely by voice call
• Sensitive personal data must not be transmitted through unsecured channels
• Partners must not request candidates to communicate through personal messaging accounts that cannot be formally verified
• Any communication purporting to be from NOVARIC^® itself should be verified — NOVARIC^® communicates through its official domain addresses only

Where WhatsApp or equivalent messaging applications are used for candidate or employer communication, partners must observe the following standards:

• Use a registered business account where available, clearly identifying the partner organisation
• Never share or request sensitive personal data, identity document copies or financial information via unencrypted messaging threads
• Retain records of material communications in a durable, retrievable format
• Obtain candidate consent before adding them to group messaging channels
• Not use messaging platforms as the sole means of communicating material terms, offers or decisions
• Immediately cease messaging any candidate who requests not to be contacted through a particular channel

NOVARIC^® does not conduct official recruitment decisions, document collection or payment instructions through personal WhatsApp or social media accounts. Candidates who receive such requests should report them via the Fraud Awareness channel.

Where partners use AI-powered tools in connection with any activity conducted under the NOVARIC^® framework, they must ensure that such tools are used responsibly, transparently and in compliance with applicable law.

Responsible AI use in this context requires:

• Human review of any AI-generated output before it is communicated to candidates or employers
• Transparency with candidates when AI tools have been used in their screening or assessment
• Avoidance of automated decision-making that produces legal or similarly significant effects without human involvement, except where lawful and consented to
• Regular monitoring of AI tools for bias, inaccuracy or discriminatory outputs
• Compliance with the NOVARIC^® Responsible AI Policy where partners have been provided access to NOVARIC^® systems or tools

Partners must not use AI tools to generate fraudulent credentials, fabricated references or synthetic candidate profiles under any circumstances.

Partners may not subcontract, delegate or further assign any part of their NOVARIC^® partner activities to a third party without prior written approval from NOVARIC^®. Where subcontracting is approved:

• The partner remains fully responsible for the conduct of their subcontractors
• Subcontractors must be made aware of and must agree to the obligations in this Code
• The partner must conduct appropriate due diligence on any subcontractor before engagement
• Subcontractor details must be disclosed to NOVARIC^® in advance
• No further sub-delegation by subcontractors is permitted without fresh approval

Any breach by a subcontractor is treated as a breach by the partner. NOVARIC^® reserves the right to require the removal of any subcontractor at any time.

Partners must maintain a zero-tolerance position on bribery and corruption in all its forms. This applies to dealings with public officials, private sector counterparties, candidates and any other person connected with partner activities.

Prohibited conduct includes:

• Offering, promising or providing any financial or non-financial advantage to secure business, influence a decision or gain preferential treatment
• Soliciting or accepting any advantage from a candidate, employer or third party in connection with a recruitment or placement decision
• Making facilitation payments to expedite official processes
• Using intermediaries to channel corrupt payments indirectly

Partners must have in place, or commit to developing, reasonable anti-bribery controls proportionate to the scale and risk profile of their operations. Evidence of such controls may be requested by NOVARIC^® as part of the due diligence or reverification process.

Partners must maintain a mechanism through which candidates and other affected parties can raise complaints about the partner's conduct. This mechanism must be accessible, confidential and responsive. At minimum, complaints must receive an acknowledgement within five working days.

Partners must promptly forward to NOVARIC^® any complaint that:

• Alleges a breach of this Code
• Concerns conduct that may constitute fraud, trafficking or exploitation
• Has been escalated beyond the partner's initial resolution process
• Involves a candidate who has been placed under a NOVARIC^® referral

Partners must cooperate fully with any investigation conducted by NOVARIC^® or a relevant authority, and must not take any action that could compromise such an investigation.

Candidates and third parties may report concerns directly to NOVARIC^® at any time via the Fraud Awareness & Misconduct Reporting channel.

Partners must notify NOVARIC^® promptly — and in any event within ten working days — of any material change to their organisation or operating status. Material changes include:

• Expiry, suspension or revocation of any required licence or registration
• Change of legal name, ownership structure or controlling interest
• Commencement of insolvency proceedings or material financial difficulty
• Regulatory investigation, enforcement action or criminal proceedings against the partner or its principals
• Change of primary operating jurisdiction
• Significant changes to the services offered or the markets served

Failure to disclose material changes may result in immediate suspension of the partner relationship pending review.

NOVARIC^® reserves the right to suspend or terminate a partner relationship with immediate effect in any of the following circumstances:

• Breach of any provision of this Code
• Conduct that exposes candidates to harm, exploitation or financial loss
• Fraudulent, deceptive or misleading conduct
• Failure to maintain required licences or legal authorisations
• Conviction of a criminal offence by the partner organisation or any principal
• Failure to cooperate with a NOVARIC^® or regulatory investigation
• Reputational risk to NOVARIC^® arising from the partner's conduct

Upon suspension or termination, the partner must immediately cease representing themselves as affiliated with NOVARIC^®, remove any NOVARIC^® branding from their materials, and cooperate in the orderly handover of any active candidate or employer relationships.

No partner of NOVARIC^® — and NOVARIC^® itself — is in a position to guarantee, promise or warrant any specific outcome in relation to employment, immigration, visa issuance, residency, admission to an educational programme, or any other regulated determination made by a third party or public authority.

Partners must not, under any circumstances:

• Promise or guarantee that a candidate will secure employment with a specific employer or in a specific role
• Guarantee that a visa application, immigration petition or residency request will succeed
• Guarantee admission to any educational institution or programme
• Represent that payment of any fee will secure, expedite or improve the likelihood of a positive outcome
• Imply that NOVARIC^® has special influence with any government authority, embassy or immigration body

Such representations — whether explicit or implied — constitute fraud. They expose candidates to financial loss and exploitation. Partners who make such guarantees will be suspended immediately and reported to relevant authorities. Candidates who have been told that payment will guarantee an outcome should report this immediately via the Fraud Awareness channel.

No partner is authorised to collect money, bank transfers, mobile money or any other form of financial value from candidates on behalf of NOVARIC^®, or to receive payment into their own accounts in connection with any NOVARIC^®-branded or NOVARIC^®-associated process, unless this has been separately and explicitly authorised by NOVARIC^® in writing.

This prohibition applies to:

• Cash payments received in person
• Bank or wire transfers to partner accounts
• Mobile money (e.g. M-Pesa, MTN Mobile Money) transactions
• Cryptocurrency transfers
• Payment platform transactions (PayPal, Wise, etc.) to partner accounts
• Collection on behalf of a sub-partner or third party not known to NOVARIC^®

Any partner who collects funds in contravention of this section will be immediately suspended, and the matter will be escalated to legal counsel and, where appropriate, law enforcement. NOVARIC^® does not accept financial liability for payments made to partners in breach of this provision, but will investigate all such reports and assist affected candidates wherever possible.

Partners must not involve any undisclosed intermediary, sub-agent, broker or additional person in the handling of candidates or the collection of payments without prior written disclosure to and approval by NOVARIC^®. The partner relationship is personal and non-transferable without express written consent.

The purpose of this requirement is to protect candidates from exploitation by unvetted parties and to preserve the integrity of the NOVARIC^® partner network. Specifically:

• Partners must not introduce a candidate to a third party who then manages the relationship without NOVARIC^®'s knowledge
• Partners must not allow a third party to communicate with candidates using the partner's credentials or identity
• Partners must disclose any person who regularly assists in candidate-facing activities, even if not formally employed
• Partners must not use another person's contact details or accounts for communications that should properly be conducted in the partner's name
• Partners must not accept referral fees or commissions from undisclosed intermediaries without disclosing this to NOVARIC^®

Engagement with undisclosed intermediaries is a breach of this Code that will result in immediate suspension. Candidates who believe they have been dealt with by an undisclosed intermediary should report this to NOVARIC^® immediately.

This document 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.

Partners are responsible for ensuring they are familiar with the current version of this Code. NOVARIC^® will provide reasonable notice of material changes. Continued operation as a partner following notification of an updated Code constitutes acceptance of the revised terms.