NOVARIC^® Partner Eligibility & Due Diligence Guide

This guide describes the eligibility criteria and due diligence process that NOVARIC^® applies to all prospective partners before any cooperation agreement can be entered into or activated. It is intended to give prospective partners clear, upfront visibility of what is required and to establish transparent expectations at the outset of the relationship.

NOVARIC^® maintains a partner network through which recruitment, workforce mobility and education placement services are extended to new geographies and communities. The integrity of that network depends on rigorous pre-approval assessment. Due diligence is not a formality — it is a substantive process that protects candidates, employers and the NOVARIC^® brand from the harm that can arise through poorly-vetted intermediaries.

This guide should be read in conjunction with the NOVARIC^® Partner Assurance & Cooperation Framework (DOC-PTN-001) and the NOVARIC^® International Partner Code of Conduct (DOC-PTN-002).

This document is a Draft pending legal approval. The requirements described herein reflect NOVARIC^®'s intended standard and may be subject to revision before final publication.

NOVARIC^® considers partnership applications from organisations and individuals who can demonstrate an established, legitimate presence in their operating market and a clear capacity to support the delivery of responsible recruitment or education placement services. The following categories of organisation may be considered:

NOVARIC^® reserves the right to decline any application at any stage of the review process and is not obliged to provide reasons for a decision not to proceed. Being eligible to apply does not create any entitlement to partnership status.

Organisations or individuals who are currently subject to regulatory enforcement action, whose licences have been suspended or revoked, or who have been convicted of offences relating to fraud, labour exploitation or trafficking are ineligible to apply and must not seek to enter the NOVARIC^® partner network.

All prospective partners are required to submit a complete documentation package before their application can be progressed to substantive review. Incomplete submissions will be held pending receipt of all required items.

3.1 Organisational Identity & Legal Standing

• Certificate of incorporation or equivalent official registration document
• Proof of current registered address and principal place of business
• Memorandum and articles of association, or equivalent constitutional document
• List of current directors, partners or controlling principals with their roles
• Proof of beneficial ownership structure (where applicable under AML regulations)
• Current business registration or tax identification number

3.2 Regulatory Authorisations & Licences

• Copy of any licence, permit or registration required to conduct recruitment, placement, immigration advisory or education counselling activities in the applicant's jurisdiction
• Confirmation of current validity of all regulatory authorisations
• Where the applicant is a regulated professional (e.g. immigration adviser, lawyer), proof of current professional registration and good standing
• Details of any conditions, restrictions or limitations attached to existing licences

3.3 Identity Verification of Key Personnel

• Government-issued photo identification for the principal applicant or primary point of contact
• Government-issued photo identification for any director or partner who will be actively involved in candidate-facing activities
• Proof of current residential address for the principal applicant (utility bill or bank statement not more than three months old)

3.4 Operational History & References

• Brief description of the organisation's operating history, including years in operation, markets served and primary services
• At least two professional references from organisations (not individuals) with whom the applicant has worked in a professional capacity within the past three years
• Evidence of any memberships, accreditations or professional affiliations relevant to the proposed partnership scope

3.5 Compliance Declarations

• Signed declaration confirming no current or pending regulatory investigation, enforcement action or criminal proceedings against the organisation or its principals
• Signed declaration confirming no prior suspension or termination from a partnership arrangement with NOVARIC^® or a NOVARIC^®-affiliated entity
• Confirmation of acceptance of the NOVARIC^® Partner Code of Conduct (DOC-PTN-002) and the Partner Assurance & Cooperation Framework (DOC-PTN-001)
• AML/KYC self-declaration form as provided by NOVARIC^®

Important — Sensitive Document Transmission: Identity documents, regulatory certificates, and other sensitive materials must be provided only through a secure channel designated by NOVARIC^® following an initial eligibility review. Do not transmit sensitive documents through public contact forms, unencrypted email attachments, or consumer messaging applications. See Section 7 of this Guide.

NOVARIC^® applies a risk-based approach to partner due diligence. Each application is assessed against a range of factors that may indicate elevated risk or that may support confidence in the applicant's suitability. This assessment is conducted internally and does not involve a mechanistic scoring system — it is a holistic judgement informed by the evidence available.

4.1 Risk Factors Considered

The following factors may indicate elevated risk and will prompt closer scrutiny or additional information requests:

• Operating in a jurisdiction with a high-risk rating for corruption, labour exploitation or trafficking (based on publicly available international indices)
• Recent or prior involvement in regulatory investigations or enforcement actions
• Incomplete, inconsistent or unverifiable documentation
• Proposed partnership scope that extends significantly beyond the applicant's current licensed activities
• Complex or opaque ownership structures without clear beneficial ownership disclosure
• Adverse public information about the organisation or its principals (including press coverage, litigation records or complaints)
• Prior termination or suspension from another partnership arrangement without adequate explanation
• Unusually high volume of candidate referrals claimed relative to the applicant's apparent operational scale
• Discrepancies between information provided by the applicant and information obtained from independent sources
• Inability to provide verifiable professional references

4.2 Confidence Factors

The following factors support confidence in an applicant's suitability and may result in an expedited or more straightforward review:

• Long-established operation in a well-regulated jurisdiction
• Current membership of a recognised professional or industry body
• Demonstrable track record of candidate protection and ethical recruitment practice
• Clean regulatory and legal history
• Strong, independently verifiable professional references
• Transparent, simple ownership structure

NOVARIC^® conducts due diligence using the documentation provided and through review of publicly available information. NOVARIC^® does not represent that it has access to any particular sanctions database or law enforcement system, and applicants should not infer any such access from the existence of this process.

Following completion of the due diligence review, NOVARIC^® will communicate one of the following outcomes to the applicant:

NOVARIC^® is not obliged to give detailed reasons for a Declined outcome. General feedback may be provided at NOVARIC^®'s discretion. A declined applicant may reapply after a minimum of 12 months, provided the circumstances that led to the declined outcome have materially changed.

Partner approval is not indefinite. NOVARIC^® conducts periodic reverification of approved partners as part of its ongoing partner assurance programme. Reverification is typically conducted annually but may be triggered earlier by specific events or concerns.

6.1 Scheduled Reverification

Partners will be notified in advance of their scheduled reverification date and asked to submit updated documentation. The reverification process may not require the full documentation set of the initial application — NOVARIC^® will specify which items require updating.

6.2 Event-Triggered Reverification

Reverification may be triggered immediately, without advance notice, by any of the following events:

• Receipt of a complaint or concern about the partner's conduct from a candidate, employer or third party
• Adverse public reporting about the partner or any of its principals
• Notification by the partner of a material change (as described in Section 18 of the Partner Code of Conduct)
• Discovery by NOVARIC^® of information that was not disclosed during the initial due diligence review
• Regulatory action against the partner in any jurisdiction
• Significant changes in the partner's ownership, management or operating structure
• Failure to report a material change within the required notification period
• Extended inactivity with no candidate or employer referrals over a twelve-month period
• Changes in the risk profile of the partner's operating jurisdiction that warrant reassessment

6.3 Consequence of Non-Cooperation

Partners who do not cooperate with the reverification process within the timeframe specified by NOVARIC^® will have their partner status set to Expired. Expired partners may not represent themselves as approved NOVARIC^® partners, accept referrals or access any NOVARIC^® partner resources.

The due diligence process requires the submission of sensitive documents including identity documents, regulatory certificates and beneficial ownership disclosures. NOVARIC^® takes its obligations as a data controller and recipient of such materials seriously.

Sensitive documents must be provided only through a secure channel designated by NOVARIC^® following an initial eligibility review. Applicants must not submit sensitive documents through:
• Public contact forms on the NOVARIC^® website
• Unencrypted standard email attachments sent to general email addresses
• Consumer messaging applications (WhatsApp, Telegram, Messenger, etc.)
• File-sharing links to publicly accessible cloud storage
• Any channel not specifically confirmed by a named NOVARIC^® representative as the designated secure channel

NOVARIC^® will designate a secure submission method on a case-by-case basis once an initial eligibility assessment has confirmed that an application is worth progressing. This approach protects both the applicant's sensitive information and NOVARIC^®'s data handling obligations.

Documents received through designated secure channels are:

• Accessed only by personnel with a direct need to review them
• Stored in encrypted, access-controlled systems
• Retained only for the period required by applicable law or the due diligence process
• Not shared with third parties except where required by law or with the applicant's explicit consent
• Subject to the NOVARIC^® Data Protection & Privacy Policy

This guide 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^® reserves the right to update this guide at any time. Prospective partners should verify they are reading the current version before commencing their application.