NOVARIC® Master Terms of Service & Procedural Standards Controlled Document ID: N-DOC-10012-032026 | Version: v4.3 | Status: Published / Approved Effective date: 29 September 2026 | Approved by: Dr. Alban Gj. THIKA, Founder & Executive Director Entities: NOVARIC® Ltd. (Malta, C 63881) · NOVARIC® Sh.A. (Albania, NUIS/NIPT M02111033E) Canonical URL: https://novaric.eu/en/governance/service-terms/ Artifact generated: 2026-09-30T07:54:14 UTC VERIFIED CORPORATE RECORDS: Malta: NOVARIC Ltd., C 63881, Level 4 Angelica Court, Triq Giuseppe Cali, Ta' Xbiex XBX 1425; VAT MT21707805; incorporated 14 Feb 2014. Albania: NOVARIC Sh.A., M02111033E; Head office: Rruga Papa Gjon Pali II 12, Tiranë; Operational: Rruga Studenti Nd 2 H 6, 4001 Shkodër; Licence LN-9041-02-2025, issued 14 Feb 2025, indefinite. NOTICE: This artifact is a canonical plain-text reference. SHA-256 is an integrity reference, not an electronic signature. No eIDAS claim is made. ================================================================================ Master Terms of Service & Procedural Standards — NOVARIC® Europe Skip to main content NOVARIC ® Category: Documents & Standards Documents & Standards · Terms · Proposed N-DOC-10012-032026 NOVARIC ® Master Terms of Service & Procedural Standards Governing the provision of workforce mobility, recruitment, advisory and education services by NOVARIC ® Ltd. (Malta) and NOVARIC ® Sh.A. (Albania), with a conditional inactive schedule for proposed Montenegro operations. ● Published Terms of Service NOVARIC ® Group Malta & Albania Montenegro — Conditional Inactive EN — Authoritative language Read the Document Document Record Print / Save PDF Document Control Record N-DOC-10012-032026 · v4.3 · Published Document ID N-DOC-10012-032026 Version v4.3 Status ● Effective Effective Date 29 September 2026 Approved By Dr. Alban Gj. THIKA Founder & Executive Director Approval Date 29 September 2026 Issuing Entities NOVARIC ® Ltd. — Malta (C 63881) NOVARIC ® Sh.A. — Albania (NUIS/NIPT M02111033E) Scope Republic of Malta · Republic of Albania Montenegro: Conditional — Inactive (Schedule C) Supersedes NOVARIC-POL-TC-001 For new engagements from effective date only. Earlier cases assessed under terms accepted at contracting. Next Review September 2027 Canonical URL https://novaric.eu/en/governance/service-terms/ Historical Development & Case Applicability Non-retroactivity applies — see Section 1.3 Service and terms development. NOVARIC ® Ltd. was incorporated in Malta on 14 February 2014 (Company C 63881, confirmed by MBR Director Certificate). NOVARIC ® Sh.A. was established in Albania on 28 August 2020 (NUIS/NIPT M02111033E, confirmed by QKB Extract). The service framework and associated contractual terms have developed progressively, reflecting the services offered, operational experience, and applicable legal requirements over time. This document consolidates and updates that framework as at the effective date above. Verification note: The date of first provision of contractual terms to clients, and any service-start date prior to evidenced documentation, requires confirmation from contemporaneous engagement records. A date of 2017 has been referenced in internal governance materials but has not been independently verified from primary records available at the time of publication. This entry will be updated when supporting evidence is provided. Historical case applicability. Each engagement, complaint, and refund request is assessed against the agreement and version of the terms applicable when the relevant service was engaged, any subsequent variation validly agreed for that engagement, and the applicable law. Later publication or amendment does not automatically replace the terms governing an earlier engagement. Applicable law and mandatory rights. Contractual provisions remain subject to applicable mandatory law. Historical assessment considers the relevant jurisdiction, contracting entity, service type, and legally applicable dates, including any statutory transitional provisions. Nothing in this document excludes rights or remedies that cannot lawfully be excluded. Chronological document record. Document history records the development of the service framework; it does not, by itself, prove that a particular client received or accepted a particular version. Case-specific applicability must be supported by the engagement records for that case. △ Evidence gaps noted: Only evidenced document versions are listed below. The history of client-facing terms prior to NOVARIC-POL-TC-001 has not been confirmed from primary records. Where an engagement pre-dates the earliest listed version, the applicable terms must be established from the case file. Historical versions are preserved and not silently overwritten. Version history of NOVARIC® client-facing terms documents Document Version Published Effective Entity / Jurisdiction Key change Supersedes Status NOVARIC-POL-TC-001 Terms & Conditions for Providing Services v1.0 Unknown ! Unverified Active at date of each engagement ⚔ Project reported NOVARIC ® Ltd. (Malta) NOVARIC ® Sh.A. (Albania) Malta · Albania First evidenced client-facing terms. Contains Sections 1–14 including refund policy (Sections 7, 7.A, 7.1–7.4.A.11). Archived copy obtained 29 Sep 2026. — ⚔ Operative Live at novaric.co N-DOC-10012-032026 Master Terms of Service & Procedural Standards v4.3 29 Sep 2026 ✓ Verified 29 Sep 2026 NOVARIC ® Ltd. (Malta, C 63881) NOVARIC ® Sh.A. (Albania, M02111033E) Malta · Albania · Montenegro (inactive) Consolidates and supersedes NOVARIC-POL-TC-001 for new engagements from 29 Sep 2026. Adds separate entity structure, Option B refund ceiling, Section 6 withdrawal framework, verified corporate records, and Schedule C (inactive). Removes complaint-conditioned refund clauses. NOVARIC-POL-TC-001 For new engagements from effective date only ✓ Effective Document Fingerprint — Approved Artifact SHA‑256: 63930350c2be21cef8ffd5417d9fcb0d43602dac79ab29b7b679404ee371d355 ↓ Download approved artifact (.txt, 89 KB) Release manifest (JSON) This fingerprint identifies the approved release artifact N-DOC-10012-032026-v4.3-approved-20260929.txt (89,360 bytes, UTF-8). It enables an integrity comparison with the version recorded in the Document Register. It is not, by itself, an electronic signature or proof of legal approval. No eIDAS or equivalent legal‑validity claim is made. The HTML page carrying this display has a separate checksum recorded in the release manifest. Contents ▾ ▾ 1. Purpose, Scope & Precedence 2. Parties & Corporate Architecture 3. Core Legal Principles 4. Anti-Placement Fee Rules & Service Categorisation 5. Candidate Rights, Complaints & Procedural Safeguards 6. Withdrawal, Cancellation, Refunds & Complaints 6.1 Preamble, Contracting Entity & Scope 6.2 Fee Categorisation & Disbursement Accounting 6.3 Statutory Withdrawal Rights 6.4 Pro-Rata Calculation Methodology 6.5 Option B — Discretionary Partial Refund (Assessment Ceiling) 6(E) Billable Work & Portal Submission Standard 6.6 Full Refund — Company Default 6.7 Filing Coordination 6.8 Refund Request Procedure 6.9 Unrestricted Access to Regulators 6.10 Jurisdictional Application Notes 6. Data Protection & Nexus Human Governance 6. Service Delivery Standards 6. Intellectual Property & Confidentiality 6. Limitation of Liability 6. Force Majeure & Sovereign Discretion 6. Governing Law & Dispute Resolution 6. Amendments & Communications 6. Severability & Entire Agreement 6. Accurate Communications, Confidentiality & Preservation of Rights Schedule A — Malta Specific Schedule B — Albania Specific Schedule C — Montenegro (Conditional — Inactive) Internal Case Management Tools Related Documents Document Record 1. Purpose, Scope & Precedence 1.1 Purpose These Master Terms of Service and Procedural Standards (" Master Terms ") establish the rights, obligations and procedural standards governing the provision of services by NOVARIC ® Ltd. (Malta) and NOVARIC ® Sh.A. (Albania) (each individually a " NOVARIC Entity " and collectively the " Company ") to its clients, candidates and programme participants. These Master Terms reflect the Company's commitment to lawful, transparent, and candidate-protective service delivery across all operating jurisdictions. 1.2 Scope Subject to the jurisdictional schedules herein, these Master Terms apply to: Workforce mobility and international recruitment services Executive search and talent advisory services HR consultancy and employer compliance advisory Education advisory, programme enrolment and academy services provided by NOVARIC ® Academy Digital platform services (Case Progress Centre, Nexus COMM, Jobs Hub) Any ancillary administrative, document formalisation, or coordination services agreed in a Service Order These Master Terms are incorporated by reference into individual Service Orders , engagement letters, or enrolment agreements. In the event of inconsistency, the specific Service Order prevails over these Master Terms, unless these Master Terms expressly provide otherwise. 1.3 Precedence & Transitional Application Note Relationship with NOVARIC-POL-TC-001 (Legacy Terms). The existing commercial terms document published at novaric.co/our-services/tc-outlines-providing-services/ (internally referenced as NOVARIC-POL-TC-001) remains the operative commercial terms document until these Master Terms are formally adopted by written executive approval. Upon formal adoption, these Master Terms shall supersede NOVARIC-POL-TC-001 for all new Service Orders entered into on or after the stated effective date. Service Orders governed by NOVARIC-POL-TC-001 prior to the effective date continue to be governed by those terms for their duration, unless the client consents in writing to migration. NOVARIC-POL-TC-001 will be updated with a supersession notice upon adoption. These Master Terms are currently an unapproved working draft . They confer no rights, impose no obligations, and do not supersede NOVARIC-POL-TC-001 until executive adoption is formally recorded. 2. Parties & Corporate Architecture 2.1 NOVARIC® Ltd. (Malta) Registered name NOVARIC Ltd. Jurisdiction Republic of Malta Company registration number C 63881 Verified record MBR Director Certificate, 4 February 2025, signed by f/Registrar of Companies Incorporation date 14 February 2014 Verified record MBR Certificate & Memorandum of Association Registered office Level 4, Angelica Court, Triq Giuseppe Calì, Ta' Xbiex, XBX 1425, Malta Verified record MBR Director Certificate & CFR VAT Certificate, 29 January 2025 Director of record Alban Gj. Thika (Identity Card No. 5410L, issued by Malta) Verified record MBR Director Certificate, 4 February 2025 VAT registration number MT21707805, registered with effect from 1 March 2014, under article 10 of the Value Added Tax Act 1998 Verified record CFR Certificate of VAT Registration, 29 January 2025; Main trade classification: 7810 — Activities of employment placement agencies … Verification Clients may verify current registered particulars at registry.mbr.mt Governing law for this entity's obligations Laws of Malta (see Schedule A ) 2.2 NOVARIC® Sh.A. (Albania) Registered name NOVARIC (legal form: Shoqëri Aksionare — Joint Stock Company) Verified record QKB Commercial Register Extract, 9 June 2026 Jurisdiction Republic of Albania NUIS/NIPT M02111033E Verified record QKB Extract & Private Employment Agency Licence Establishment date 28 August 2020; registered at QKB: 11 September 2020 Verified record QKB Extract Head office Rruga Papa Gjon Pali II 12, Tiranë, Albania Verified record QKB Extract Operational address Rruga Studenti, Nd 2, H 6, 4001, Shkodër, Albania Verified record Private Employment Agency Licence LN-9041-02-2025 Administrator of record Alban Thika (appointed 01/06/2024, term to 01/06/2027) Verified record QKB Extract Private Employment Agency Licence LN-9041-02-2025, Category X.2.A, issued 14 February 2025, validity: indefinite, issued by Ministry of Finance and Economy / National Business Center (QKB); approved by Minister of Economy, Culture, and Innovation (Decision No. 2609/1 prot., 14 February 2025) Verified record QKB Licence and Ministerial Approval Letter Verification Clients may verify current registered particulars at qkb.gov.al Governing law for this entity's obligations Laws of the Republic of Albania (see Schedule B ) Corporate architecture note. NOVARIC ® Ltd. (Malta) and NOVARIC ® Sh.A. (Albania) are separate legal entities. Each entity contracts independently for the services within its own jurisdiction. No Malta-entity obligation automatically binds the Albanian entity, and vice versa, unless a Service Order expressly states joint engagement. 2.3 Montenegro — Status (Proposed NOVARIC® A.D. Podgorica) Montenegro operations: not established. A proposed entity "NOVARIC® A.D. Podgorica" registration and authority to contract have not been established from the evidence reviewed. No registration number, contracting authority, or legal personality has been confirmed from available official records of the Central Registry of Business Entities of Montenegro (CRPS — Centralni registar privrednih subjekata ). Any reference to Montenegro operations in this document constitutes a conditional, inactive schedule only. See Schedule C . 3. Core Legal Principles & Character of Obligations 3.1 Obligation of Diligent Means All representation, advisory, application-coordination and mobility-facilitation tasks undertaken by the Company constitute an Obligation of Diligent Means ( Obligatio de Mediis ) — not an Obligation of Result ( Obligatio de Resultat ). The Company commits to exercise professional skill, care, and diligence in performing contracted services. The Company does not guarantee any particular outcome including, without limitation: Employment placement, job offer, or contract of employment Visa, residence, or work permit approval University or programme admission Specific timeline for any sovereign or third-party process 3.2 Sovereign Discretion The issuance, refusal, or revocation of permits, visas, residence authorisations, and any other administrative clearances are sovereign state prerogatives exercised by the competent national authorities of Malta, Albania, the European Union, or any other jurisdiction. The Company has no influence over sovereign administrative decisions and accepts no liability for refusals, delays, or changes in policy by any state authority. 3.3 Professional Standards The Company applies professional standards consistent with applicable employment agency regulation, including the obligations of diligence under: Maltese common law principles of mandate and professional services Albanian Civil Code (Law No. 7850), Articles 450 et seq. on obligations of diligence Applicable EU consumer protection instruments where the client or candidate qualifies as a consumer under applicable law 4. Anti-Placement Fee Rules & Service Categorisation 4.1 Governing Principle — Economic Substance Substance governs form. Applicable employment agency legislation evaluates the economic purpose and substance of any charge to a worker or candidate, not the label applied to an invoice line. Accordingly, any charge to a candidate that is, in substance, a recruitment placement fee — regardless of the service code, administrative description, or documentary form used — is prohibited by the Company. 4.2 Regulatory Framework The Company's fee policy is governed by, and in each case must comply with: Malta — S.L. 452.130 (Employment Agencies Regulations, enacted via L.N. 270 of 2023, as amended): Regulation 15 prohibits employment agencies from charging fees to jobseekers or applicants for employment. The Company operates in compliance with this prohibition. Verified legal source see Schedule A for full regulatory citation; access: legislation.mt Albania — Law No. 15/2019 on the Promotion of Employment ( Ligji Nr. 15/2019 "Për Nxitjen e Punësimit" ): Prohibits private employment agencies from charging placement fees to jobseekers. Project reported pending legislative text confirmation Montenegro — Employment Mediation Law ( Zakon o posredovanju pri zapošljavanju ): Prohibits charging fees to jobseekers for employment mediation services. Applies only to the extent of Schedule C activation. Project reported Schedule C is inactive ILO Fair Recruitment Principles (guidance only): The employer-pays principle. Recruitment costs must not be borne by workers. 4.3 Permitted Candidate Charges Charges to candidates or individuals are permissible only where: The service is genuinely distinct from employment placement or recruitment mediation; The service is optional — the individual is not required to purchase it as a condition of accessing any employment-related service; The charge is fully and transparently disclosed before any commitment is made; The service has clear, documentable operational substance and is not a disguised recruitment fee; The charge does not, in aggregate, constitute remuneration of the Company for placing the individual in employment. Examples of permissible standalone services include: certified translation services, independent educational tuition delivered through NOVARIC ® Academy (subject to voluntary enrolment), and third-party government processing fees paid at cost. 4.4 Prohibited Charges The following are absolutely prohibited: Any fee charged to a candidate described as, or functioning as, a charge for securing, facilitating, or accelerating a job placement or referral Mandatory "registration fees", "processing fees", or "administration fees" applied to all candidates as a condition of service Recovery of employer-side recruitment costs from the candidate Any fee structure that would result in the candidate bearing the economic burden of the Company's remuneration from the employer 5. Candidate Rights, Complaints & Procedural Safeguards 5.1 Non-Derogable Rights These Master Terms do not, and cannot, restrict the following rights, which are preserved in all circumstances regardless of any other contractual term: Right to contact public authorities: Any candidate or client retains the unrestricted right to contact, report to, or file a complaint with any competent regulatory, law enforcement, or administrative authority at any time. Right to seek legal advice: Any person retains the right to obtain independent legal advice regarding their rights and obligations at any time. Right to file regulatory complaints: Candidates and clients may lodge complaints with the MCCAA (Malta), DIER (Malta), the Albanian Consumer Protection Commission, the Directorate of Labour Inspection (Albania), or any other competent authority. See jurisdictional schedules. Right to appeal decisions: Any candidate or client may appeal administrative decisions through the statutory channels applicable in their jurisdiction without restriction by these terms. 5.2 Filing Coordination Protocol (Proposed — Operational Only) Status: Proposed operational policy — subject to executive and legal review. Where a candidate has granted the Company a power of representation for a specific application file, the candidate agrees to notify the Company's case officer before making a direct submission to the relevant authority that relates to the same file. The purpose of this protocol is to avoid the filing of duplicate or conflicting submissions. This obligation: (a) is limited to the specific file for which representation was granted; (b) does not restrict the candidate's right to make any submission at any time; (c) does not prohibit the candidate from making independent submissions — it requires only reasonable notice; (d) does not constitute a gagging clause or restriction on access to justice. Where a candidate makes a direct submission without notice and this causes documented delay or additional cost, the Company may — only upon demonstration of actual causation and quantified cost — raise the matter with the candidate for discussion. No automatic penalty, fee forfeiture, or adverse consequence applies. 5.3 Internal Conciliation Procedure (Tier 1 — Proposed) The Company proposes to operate a voluntary internal conciliation procedure as the first stage of complaint resolution. This procedure is: Voluntary: Candidates and clients are not required to use this procedure before accessing any statutory or judicial remedy. Non-binding: Outcomes from Tier 1 review are not binding on either party unless a settlement agreement is separately signed. Target timeline: 15 business days from receipt of a complete written complaint (proposed target — not a contractual guarantee). Parallel rights preserved: Use of this procedure does not pause statutory time limits or restrict rights to file external complaints simultaneously. Written complaints should be addressed to the Company's designated complaints officer. Contact details will be specified in individual Service Orders and on the NOVARIC ® complaints page. 5.4 No Gagging Clauses Absolute commitment. These Master Terms contain no clause that restricts, penalises, or has the effect of discouraging a candidate or client from: reporting suspected unlawful conduct to any authority; cooperating with any regulatory investigation; making a complaint to a public authority; or seeking independent legal or welfare advice. Any term that purported to have such an effect would be void and unenforceable under applicable law. 6. Withdrawal, Cancellation, Refunds & Complaints Relationship with legacy NOVARIC-POL-TC-001. This Section 7 is the proposed replacement for Sections 7, 7.A, 7.1, 7.2, 7.3, 7.4, and 7.4.A.1–7.4.A.11 of the document currently published at novaric.co/our-services/tc-outlines-providing-services/ (internally referenced as NOVARIC-POL-TC-001). NOVARIC-POL-TC-001 remains the operative document until these Master Terms are formally adopted. Where any provision of NOVARIC-POL-TC-001 is more favourable to the consumer than these Master Terms, the more favourable provision is preserved in the interim. 6.1 Preamble, Contracting Entity & Scope of Application The refund, cancellation, and withdrawal rights applicable to any engagement depend on four determinant factors, which must be established at the outset of each Service Order: Contracting entity: Whether the relevant NOVARIC ® entity is NOVARIC ® Ltd. (Malta, C 63881), NOVARIC ® Sh.A. (Albania, NUIS/NIPT M02111033E), or — when and if Schedule C is activated — a future Montenegro entity. The contracting entity determines the applicable governing law and regulatory framework. Counterparty capacity: Whether the client or candidate is a Consumer (an individual acting wholly or mainly outside their trade, business, craft, or profession) or a Commercial Client / Employer . Consumer-protective statutory rights under EU Directives and national law apply exclusively to consumers and cannot be contracted out of. Contract medium: Whether the contract was concluded as a Distance Contract (concluded entirely by electronic or telephone means without simultaneous physical presence) or an On-Premises Contract (concluded at the Company's registered or operational premises with the consumer physically present). The 14-day statutory withdrawal right under Directive 2011/83/EU applies to distance and off-premises contracts. Service Order scope: The specific deliverables, milestones, payment terms, and post-submission obligations defined in the individual Service Order. Note: Any provision of applicable law that is mandatory for the protection of the consumer prevails over these contractual terms to the extent of any inconsistency. The Company may not contract out of mandatory consumer protection rights. 6.2 Categorisation of Fees & Disbursement Accounting All fees collected under a Service Order are classified into the following four strictly separated categories. Each category carries different refund treatment, and the Company is required to maintain auditable records sufficient to verify the amount falling within each category: Category A — Sovereign & Statutory Disbursements Actual government application fees, administrative stamps, visa fees, and court duty fees paid directly and verifiably to a sovereign public authority (e.g. fees payable to Identità Malta, the Albanian General Directorate of Migration, consular posts, or equivalent bodies). These amounts are non-refundable to the extent that they have been remitted to the public authority and are non-recoverable from that authority. The Company must, upon request, produce official state receipts or documented proof of payment to the sovereign body as a condition of retaining such amounts. Category B — Direct Third-Party Out-of-Pocket Expenses Documented disbursements to private third parties on behalf of the client, including courier charges, certified translation fees, apostille stamps paid to authorised agencies, and notarial fees. These amounts are non-refundable only to the extent that: (a) they were actually incurred and paid; (b) they are not recoverable from the third-party vendor; and (c) the Company produces itemised receipts and proof of payment. The Company may not withhold third-party disbursements that were not actually paid or that are recoverable. Category C — NOVARIC® Professional Service Fees Consideration paid for NOVARIC ® 's advisory, document formalisation, case auditing, representation, administrative coordination, and post-submission monitoring services. These fees are refundable in accordance with the withdrawal and proportionate-refund provisions set out in Sections 6.3 to 7.6 below. No portion of professional service fees may be declared fully "earned" or "non-refundable" solely by reference to a procedural milestone (such as submission to a government portal) unless the Service Order expressly defines that milestone as constituting full contractual discharge of all professional service obligations. Category D — Recruitment & Placement Charges (Employer-Borne Only) Charges to employers for recruitment, search, and talent-placement services are strictly employer-borne. Under Maltese S.L. 452.130 (Regulation 15), Albanian Law No. 15/2019 (Articles 7–8), and, when operative, Montenegrin employment mediation law, the Company is absolutely prohibited from charging recruitment placement fees to candidates, workers, or jobseekers. Any invoice, fee schedule, or service code that in substance constitutes a placement fee charged to a candidate — regardless of the label applied — is void and irrecoverable. Where such amounts have been collected from a candidate in violation of applicable law, they are refundable in full. 6.3 Statutory Withdrawal Rights for Consumers (Distance Contracts) 7.3.1 Right of Withdrawal — 14-Day Period Where a consumer has concluded a distance contract or off-premises contract with the Company, the consumer has the right to withdraw from that contract without giving any reason and without penalty, within 14 calendar days from the date of conclusion of the contract. This right is conferred by Article 9 of Directive 2011/83/EU on Consumer Rights and the applicable national implementing legislation in Malta (Consumer Affairs Act, Cap. 378) and Albania (Law No. 9902/2008). Correction of legacy published terms. The current live NOVARIC-POL-TC-001 states: "Fees paid for services are non-refundable once the application has been submitted." This statement, as applied to consumer distance contracts, is inconsistent with Directive 2011/83/EU. A service is fully exempt from the withdrawal right only when the service has been completely performed (not merely submitted to a portal), provided the consumer gave prior express consent and explicit acknowledgement of loss of withdrawal rights before performance began (Art. 16(a)). Where post-submission services remain outstanding (monitoring, biometric scheduling, status follow-up, outcome representation), the contract has not been fully performed and the withdrawal right is not extinguished by the act of submission alone. 7.3.2 Commencement of Service During the Withdrawal Period Where a consumer makes an express, durable-medium request for the Company to commence service delivery during the 14-day withdrawal period: Performance may commence, but the consumer's right of withdrawal is not forfeited solely by reason of commencement. If the consumer subsequently withdraws, they are liable to pay only an amount proportionate to the services actually performed up to the date of communication of withdrawal, calculated in proportion to the total price agreed. The consumer is not liable to pay any amount beyond what corresponds to performed services. If the Company failed to inform the consumer of the right of withdrawal before the contract was concluded, or failed to inform the consumer that they would lose the right of withdrawal upon full performance, the consumer owes nothing for services performed during the withdrawal period — in accordance with Article 14(3) of Directive 2011/83/EU. 7.3.3 Complete Loss of Withdrawal Right — Conditions The right of withdrawal is extinguished where the service has been fully and completely performed (not partially performed), provided that both of the following conditions were satisfied before performance began: The consumer gave prior express consent to performance commencing before the end of the withdrawal period; and The consumer made an explicit, documented acknowledgement that they understood the right of withdrawal would be lost upon full performance. These conditions must be documented in a durable medium (email, signed agreement, or equivalent). The burden of proof that both conditions were satisfied lies with the Company. 7.3.4 Digital Content Rules — NOVARIC® Academy For digital content supplied by NOVARIC ® Academy not supplied on a tangible medium (e.g. online learning platform access, downloadable materials, streamed content): The right of withdrawal is extinguished once access or streaming begins, provided the consumer gave prior express consent and made an explicit, documented acknowledgement of the loss of the withdrawal right before access commenced — per Article 16(m) of Directive 2011/83/EU. Scheduled, live, or in-person cohort instruction is not digital content for the purposes of Article 16(m). Such instruction follows the proportionate service rules in Section 6.4 below. Non-refundable registration fees for Academy programmes are subject to the general unfair terms review in Section 6.8. Blanket non-refundable registration fees that exceed demonstrable actual administrative setup costs may constitute unfair terms under Directive 93/13/EEC and national law. 7.3.5 Reimbursement Timeline — Statutory Requirement Upon valid withdrawal, the Company must reimburse the consumer for all amounts paid, less any proportionate deduction for services actually rendered, within 14 calendar days of receiving the consumer's notice of withdrawal — in accordance with Article 13(1) of Directive 2011/83/EU. Reimbursement must be made using the same means of payment as used by the consumer for the initial transaction, unless expressly agreed otherwise. 6.4 Pro-Rata & Proportionate Calculation Methodology Arbitrary milestone-forfeiture percentages are withdrawn. Previous drafts and working revisions of these terms included automatic "earned fee" tiers (examples: 25% upon engagement, 60% upon document preparation, 100% upon portal submission). These fixed-percentage forfeiture provisions are inconsistent with the proportionality obligation under Directive 2011/83/EU Article 14(3) and constitute potentially unfair terms under Directive 93/13/EEC Annex 1(d) unless they accurately reflect actual costs and work performed. They are not included in these Master Terms. Proportionate deductions from refunds are calculated as follows: Identify total contract price as stated in the Service Order (Category C professional fees only; Categories A and B are separately accounted). Identify and document each service task or deliverable included in the Service Order scope, with a corresponding fee allocation or hourly rate. Record and verify which tasks have been completed and delivered as at the date of withdrawal or cancellation, supported by contemporaneous work records. Calculate the proportionate amount as: (Total Contract Price × Completed Tasks / Total Contracted Tasks), based on documented task completion records, or alternatively, using verified hourly rates for time spent on completed work. Submit to client an itemised written statement of the proportionate calculation within the decision timeline specified in Section 6.8. Submission to a government portal does not equal 100% performance unless the Service Order expressly defines the contract scope as terminating strictly upon transmission and identifies no post-submission obligations. Where the Service Order includes post-submission monitoring, status follow-up, biometric scheduling, employer liaison, or outcome representation, those unperformed components remain outstanding and their corresponding fee value remains refundable. 6.5 External Circumstances & Discretionary Partial Refund (Option B — Assessment Ceiling) [MANAGEMENT DECISION REQUIRED — Option B adoption] The provision below is a proposed commercial rule drafted for management and legal review. It must not appear in the final published terms without explicit written executive approval from Dr. Alban Gj. THIKA and written legal sign-off from appointed Malta and Albania counsel. It does not apply to any engagement governed by NOVARIC-POL-TC-001 or any version of the terms pre-dating formal adoption of these Master Terms. 7.5.1 Historical Reference — NOVARIC-POL-TC-001 Section 6.1(a) [HISTORICAL — NOVARIC-POL-TC-001 — for reference and redline comparison only] "If an application cannot be completed successfully due to circumstances beyond our control—after NOVARIC® has fully assessed all available options—we may issue a partial refund of up to 75% of the service fees or any partial fees paid. This refund will be calculated based on the final service fees as indicated on documentation, invoices, or receipts exchanged between NOVARIC® and the client." This provision is preserved verbatim for comparison. The proposed Option B below supersedes it upon formal executive adoption and applies only to new engagements from the stated effective date. 7.5.2 Option B — Discretionary Partial Refund (Assessment Ceiling) Where an application cannot proceed or fails due to objective external circumstances genuinely beyond either party's control — including the unexpected closure of a sovereign quota, a documented material change in applicable law, or a force majeure event — NOVARIC ® will conduct an evidence-based assessment of the particular engagement. That assessment takes into account: The professional services actually performed and documented in contemporaneous work records meeting the time records standard in Section 6(E); Verified third-party disbursements net of actual recoveries from vendors; Any sums already repaid, credited, or recoverable from others; The applicable agreement and law; and The scope of deliverables remaining unrendered at the point of failure. Following that assessment, NOVARIC ® may grant a discretionary partial refund of up to 75% of the eligible service fees . The actual amount may be lower than 75%, or no discretionary refund may be due, depending on the evidence. The 75% figure is a ceiling on this discretionary assessment , not a guaranteed refund and not an automatic statement that 25% of fees has been earned. 7.5.3 Definition — Eligible Service Fees "Eligible service fees" means NOVARIC ® professional service fees in Category C only, calculated as: Category C fees collected − sums already refunded or credited to this client − sums recoverable by the Company from third parties on the client's behalf − VAT and statutory levies (which are accounted separately) Eligible service fees exclude in all circumstances: Category A — sovereign and statutory disbursements (government fees, visa fees, court stamps); Category B — verified third-party out-of-pocket expenses (courier, translation, apostille), net of actual recoveries; Category D — any charge that in substance constitutes a recruitment placement fee payable by a candidate or worker (void under applicable law regardless of invoice form); VAT, statutory levies, and any amount collected on behalf of a third party; Sums already refunded, credited, or recoverable from others. 7.5.4 Communication Requirement Where a discretionary assessment is completed under this Section, NOVARIC ® must deliver to the client a written statement within the 15-business-day decision window in Section 6.8, itemising: The total Category C fees collected and the basis for the eligible service fee calculation; The services performed with dates, documented outputs, and evidence references; The basis for any amount deemed earned, with reference to the applicable work records; The proposed discretionary refund amount and the method of its calculation; Category B third-party amounts deducted, with receipts available for inspection; Any applicable mandatory statutory entitlement, stated separately from and independently of the Option B assessment. 7.5.5 Priority — Statutory Rights and Stronger Remedies Prevail Option B never reduces a stronger right. This discretionary assessment ceiling does not operate to reduce: (i) any statutory refund entitlement under Directive 2011/83/EU or applicable national law; (ii) any refund remedy arising from NOVARIC ® 's breach, negligence, or non-performance (see Section 6.6); or (iii) any more favourable refund promise validly incorporated into the specific Service Order or prior engagement. Where any such stronger right exists, it is calculated and applied first, and Option B applies only to any residual discretionary assessment of Category C fees not already governed by that stronger right. 7.5.6 Non-Retroactivity The Option B assessment ceiling applies only to engagements entered into under these Master Terms from the stated effective date. Engagements governed by NOVARIC-POL-TC-001 or any earlier version of the terms are assessed under their own contractual record and applicable mandatory law. The Refund Reconciliation Calculator (internal tool) will not apply the Option B formula to cases whose confirmed terms version predates these Master Terms. 7.5.7 Acceptance Tests (Section 6.5 / Option B) Internal quality assurance test matrix — not for publication. The following scenarios confirm correct application of Option B and the priority rules above. The Refund Reconciliation Calculator must produce the stated outcomes for each. Test Scenario Correct outcome T-A1 Zero work; consumer distance contract; withdrawal Day 8 Full Cat C refund within 14 calendar days per Art. 13(1) CRD. Option B not applied — statutory withdrawal governs. T-A2 Partial work (2/4 deliverables); consumer distance; withdrawal Day 10 with express-request commencement Proportionate refund (50% of Cat C) per Art. 14(3) CRD. Option B ceiling does not reduce statutory proportionate amount. T-A3 Portal submitted; 2 post-submission deliverables outstanding; visa refused (no Company fault); withdrawal period expired Proportionate refund for unperformed deliverables (Section 6.4); Option B ceiling (up to 75% of eligible fees) applied to residual. Portal submission does not earn 100% of Cat C. Itemised statement required. T-A4 Quota closes after doc preparation; force majeure; withdrawal period expired Option B applies. Evidence-based assessment. If minimal Cat C work performed, refund may approach or exceed 75% ceiling (ceiling does not reduce what proportionate calculation would grant). Itemised statement required. T-A5 NOVARIC® missed contractual submission deadline; application failed Section 6.6 governs — 100% Cat C refund + recoverable Cat B. Option B never reduces a breach remedy. Human review + legal counsel required. T-A6 Translation agency issues full credit note after cancellation Cat B recovery passed to client in full. Eligible service fees (Cat C only) reduced by zero — Cat B recovery is not counted against Option B ceiling. No double recovery. T-A7 Academy client cancels after 3 of 8 live sessions; withdrawal period expired Proportionate tuition refund: 5/8 × tuition fee. Registration fee: retained only to extent of documented actual setup cost. Option B not applied — proportionate calculation governs direct service delivery cancellation. T-A8 2024 engagement governed by NOVARIC-POL-TC-001 Assessed under NOVARIC-POL-TC-001 terms and applicable mandatory law at date of engagement. Option B ceiling not applied retroactively. Calculator loads NOVARIC-POL-TC-001 version. Human review required if version uncertain. 6(E) Billable Work Standard & Portal Submission 6(E).1 Portal Submission Is Not Full Performance Core principle. Submission of a client application, supporting documents, or case file to a government portal, authority registry, or employer system is one deliverable within the contracted scope of service. Unless the Service Order expressly defines the contract as terminating upon transmission and identifies no post-submission obligations, portal submission does not constitute full contractual performance. Fees corresponding to post-submission deliverables that remain unperformed are refundable on a pro-rata basis per Section 6.4. Deliverables that may be outstanding after portal submission, depending on the Service Order scope, include: status monitoring; biometric appointment scheduling; authority correspondence and follow-up; employer or sponsor liaison; outcome advice; appeal or review support; compliance guidance on the result. Where these form part of the contracted scope, the corresponding fee value is not earned upon submission. 6(E).2 Time Records Standard Where NOVARIC ® relies on time worked as the basis for a deduction from a refund, each time entry must contain: staff name and verified role; date; task description (sufficient to identify the specific deliverable produced); duration in hours and minutes; agreed rate in EUR as specified in the case-specific Service Order; and reference to the output produced. Time records must be contemporaneous or, where retrospective, clearly marked as such. Internal meetings, file administration overhead, and any activity not agreed in the Service Order are not deductible from the client's refund entitlement. 6(E).3 Engagement Type Rules Fixed-fee: The proportionate refund is calculated by reference to the fixed fee and the deliverable schedule in the Service Order — not by imputing an hourly rate. No unilateral conversion to hourly billing without advance written client agreement and applicable contractual authority. No double recovery of the fixed fee and the same hours. Hourly-rate: Governed by the agreed rate in the case-specific Service Order and the time records standard above. Any rate applied must be the rate agreed with this specific client before the work was performed. Retainer: What is included in the retainer and what constitutes chargeable out-of-scope work must be specified in the Service Order. Out-of-scope charges require advance written client agreement before the work commences. Academy tuition (session-based): Proportionate by sessions delivered. Live cohort instruction is not digital content for the purposes of Article 16(m) of Directive 2011/83/EU. 6(E).4 Internal Valuation vs. Recoverable Debt A time-based internal valuation used to calculate the proportionate deduction in a refund assessment does not automatically create a legally recoverable debt. Such a deduction is valid only where the agreed rate was specified in the applicable Service Order and accepted by the client, the time records meet the standard above, and the deduction does not reduce a statutory refund entitlement below the legally required amount. [MANAGEMENT DECISION REQUIRED — Rate Card] A proposed NOVARIC® EUR rate card is prepared as a separate internal management decision document (WS-E). No rate from that document may be applied to any existing or new case without explicit management adoption and prior written agreement with the specific client. US dollar rates from external reference agreements do not apply to NOVARIC® engagements and must not be converted, relabelled, or reproduced in NOVARIC® client documents. 15. Accurate Communications, Confidentiality & Preservation of Rights Communications, Confidentiality & Preservation of Rights [LEGAL REVIEW REQUIRED — Workstream D] This clause is a proposed draft for management and legal review. It requires jurisdiction-specific assessment by appointed Malta and Albania counsel before adoption. It must not appear in the final published terms without written legal sign-off. 16.1 Scope and Purpose Both NOVARIC ® and its clients and candidates (each a "party") benefit from accurate, good-faith communications during and after an engagement. This Section establishes proportionate obligations that protect both parties whilst expressly preserving all statutory rights, regulatory access, and freedoms of expression protected by applicable law. 16.2 What This Clause May Require Each party agrees to make reasonable efforts to: Refrain from making knowingly false statements of fact about the other party, the engagement, the services performed, or the outcome; Refrain from impersonating staff, representatives, or officials of the other party; Refrain from making unlawful threats; Refrain from disclosing protected personal data or confidential case materials belonging to the other party without authority, where those materials were received in confidence in connection with the engagement; Refrain from deliberate, bad-faith destruction of contemporaneous evidence relevant to an unresolved dispute. Where a party believes the other has made a factual error in a public or private communication, they may notify the other party through the designated communications channel to request voluntary correction. There is no obligation to correct communications that constitute honest opinion, uncertain accounts, or protected expression. 16.3 What This Clause Does Not Prohibit 🛡️ Absolute preservation of the following — non-derogable: Honest criticism of NOVARIC ® 's services, processes, pricing, or outcomes, including reviews on public platforms; Truthful accounts of a client's or candidate's own experience, even where that account is negative or critical; Good-faith reports and complaints to regulatory authorities, consumer protection bodies, ombudsmen, or law enforcement agencies; Whistleblowing and protected disclosures under applicable whistleblowing law; Legal representation and the giving of evidence in any proceeding; Communications protected by qualified privilege, legal privilege, or public-interest protection under applicable law; Describing an unresolved dispute as unresolved, a pending complaint as pending, or an outcome as unsatisfactory. 16.4 No Gag Conditions on Refunds or Settlements Absolute prohibition. No refund, settlement payment, credit note, or case review offered or agreed by NOVARIC ® may be conditioned on: deleting a post, review, or complaint; withdrawing a regulatory or judicial complaint; signing a non-disparagement or non-disclosure undertaking as a condition of receiving money owed; or any act or undertaking that has the effect of deterring the exercise of statutory rights. An allegation made by a client or candidate must not be characterised as defamatory solely because NOVARIC ® disputes it. Where NOVARIC ® genuinely believes a statement is actionable, the matter is routed to human legal counsel for a jurisdiction-specific assessment before any legal step is taken. 16.5 Communications During Dispute Resolution Processes The following applies to communications during ongoing dispute resolution processes: Internal review: No confidentiality obligation arises from the fact that an internal review is open. Either party may communicate freely with third parties, regulators, and advisers during an internal review. Voluntary mediation or ADR: Where both parties voluntarily agree to participate in a mediation or ADR process, specific communications made within that process may attract a without-prejudice or confidentiality protection under applicable law. Participation in ADR does not restrict either party's right to withdraw and pursue other remedies. Validly agreed arbitration: Where an arbitration clause is validly agreed under applicable law and the parties are bound by it, the procedural rules of the applicable arbitration institution govern. This does not override mandatory consumer forum rights under Regulation (EU) No 1215/2012. Court or tribunal proceedings: Communications made in or for the purpose of legal proceedings attract the protections prescribed by the applicable court's rules. The existence of court proceedings does not automatically impose silence on either party regarding matters not subject to a specific court order. Pending proceedings do not impose general silence. Each party retains the right to seek legal advice, communicate with their advisers, and exercise all statutory rights, at all times. 6.6 Full Refund in Cases of Company Default 🛡️ Full refund on Company default — preserved from legacy terms. The published NOVARIC-POL-TC-001 states: "If the Company fails to submit the application due to its own negligence, a full refund of the service fee will be provided to the candidate." This commitment is retained and extended in these Master Terms. Where an application fails, is rejected, is dismissed, or cannot proceed as a direct result of any of the following: The Company's gross negligence or wilful misconduct; An unexcused failure by the Company to submit a complete and timely application; A material breach of the Company's professional obligations under the Service Order; Submission of materially erroneous, incomplete, or fraudulent documentation prepared or caused by the Company; — then the client is entitled to a 100% refund of all Category C professional service fees paid , together with a refund of all Category B third-party disbursements that are recoverable from the relevant vendors. Category A sovereign disbursements are refundable only to the extent the relevant authority returns them. 7.6.2 Standard of Negligence Negligence is assessed by reference to the objective standard of a reasonably competent employment advisory and documentation service operating in the applicable jurisdiction. The fact that an application was rejected by a sovereign authority does not, of itself, constitute negligence by the Company — sovereign administrative decisions are exercises of state discretion outside the Company's control (see Section 3.2 on sovereign discretion). However, failure to follow mandatory procedural requirements, submission of documents known to be incorrect, or failure to perform agreed services within the contracted scope, may constitute negligence or breach. 6.7 Filing Coordination & Resolution of Conflicting Submissions Replacement of legacy Section 7.A. The published NOVARIC-POL-TC-001 (Section 7.A) contains provisions stating that clients "agree to refrain from prematurely bypassing NOVARIC®'s processes or directly engaging with third parties unless explicitly authorized in writing by NOVARIC®" and describing direct client engagement with authorities as causing "Disrupted Processes," "Impacted Outcomes," and "Harmed Professional Relationships." These provisions are replaced in full by the following balanced Filing Coordination Protocol. A blanket prohibition on contacting public authorities is incompatible with administrative due process, constitutional petition rights, and is void as an unfair contract term under Directive 93/13/EEC Annex 1(q) (terms excluding or hindering the consumer's right to take legal action or exercise any other legal remedy). 7.7.1 Coordination Objective Where the Company holds a power of representation on behalf of a client or candidate for a specific application file, both parties agree in good faith to coordinate communications with the relevant sovereign or third-party authorities, so as to avoid the filing of duplicate, contradictory, or conflicting submissions that could cause administrative confusion, delay, or rejection of the application. 7.7.2 Client's Retained Rights — Non-Derogable Nothing in this Section 6.7, and no provision of any Service Order, restricts or penalises the client or candidate from: Contacting, communicating with, or submitting information to any public authority, government body, court, tribunal, or regulatory authority at any time; Filing a complaint, appeal, or petition with any competent authority; Seeking independent legal advice at any time; Exercising any constitutional, statutory, or common-law right of petition, appeal, or access to justice. The Company expressly acknowledges that the right to petition public authorities is a non-waivable constitutional and statutory right. Any contractual term purporting to restrict such rights is void and unenforceable. 7.7.3 Notice Obligation (Operational Only) As an operational matter — not as a condition of any right or remedy — where a client or candidate intends to submit a document, application, or communication directly to a sovereign authority in relation to a file for which the Company holds a power of representation, the client is requested to notify the Company's designated case officer at least two (2) business days in advance where practicable, so that the Company may coordinate its own submissions to avoid duplication. Failure to provide this advance notice does not: (a) constitute a breach of contract; (b) trigger any automatic fee forfeiture, penalty, or adverse contractual consequence; or (c) restrict any right to a refund or other remedy. 7.7.4 Consequence of Documented Conflicting Submission In the narrow circumstance where a client's direct submission to a sovereign authority without prior notice causes a documented, measurable administrative failure — including a rejection or delay directly and solely attributable to conflicting information filed by the client — the following procedure applies: The Company must issue a written notice to the client identifying: the specific submission, the specific administrative conflict, and the documented impact on the application. The client must be given a reasonable opportunity of at least seven (7) business days to respond and, where possible, to rectify the conflict. The Company may be relieved from liability for delays or rejection solely to the extent directly and causally attributable to the conflicting submission, and only where it can demonstrate that the conflict caused the outcome and that the conflict would not have arisen had the Company's submission proceeded as planned. Any deduction from fees or charges levied in this scenario requires: (a) specific identification of additional labour or expense incurred solely to rectify the conflict; (b) itemised invoicing; (c) proportionate calculation. No automatic fee forfeiture, no blanket breach declaration, and no contractual penalty applies. 6.8 Refund Request, Audit & Disbursement Procedure 7.8.1 Submission Channel Refund requests must be submitted in writing to governance@novaric.eu or via the official refund submission form on the NOVARIC ® Case Progress Centre. The written request must include: Claimant's full name and, where applicable, case reference number; Proof of payment (bank statement, receipt, or payment confirmation); A brief statement of the grounds for the refund request; The original payment method to which any approved refund should be returned. 7.8.2 No Excessive Documentation Requirements Replacement of legacy Sections 7.4.A.7 and 7.4.A.8. The published NOVARIC-POL-TC-001 (Sections 7.4.A.7 and 7.4.A.8) requires: (a) that refunds will not be processed until any complaints filed with external authorities are "resolved" and the claimant provides "notarized evidence of the withdrawal of such complaints"; and (b) that representation claims require "a legally binding power of attorney." These requirements are excised in full : Conditioning a refund on withdrawal of an external regulatory complaint is an aggressive commercial practice under Directive 2005/29/EC Articles 8–9 and is void under Directive 93/13/EEC Annex 1(q), Malta Cap. 378 Part VI, and Albanian Law 9902/2008 Article 27. Requiring notarised evidence of complaint withdrawal imposes a disproportionate formal burden inconsistent with the principle of accessible consumer remedies. A notarised power of attorney is not required for a refund claim made by the primary account holder or by an identified authorised representative with written authorisation. Standard identity verification suffices. 7.8.3 Decision Timelines Acknowledgement The Company will acknowledge receipt of a complete refund request within three (3) business days . Reasoned decision The Company will issue a written decision, with an itemised proportionate calculation supporting the decision, within fifteen (15) business days of receipt of a complete request. Proposed term 15 business days is a target commitment subject to executive confirmation as a binding SLA Payment of approved refund Approved refunds will be disbursed within 14 calendar days of the decision date, via the original payment method, in accordance with the statutory standard under Directive 2011/83/EU Article 13(1). 7.8.4 Request Window The published NOVARIC-POL-TC-001 (Section 6.4) requires clients to request refunds within 30 days of the final outcome. This draft preserves a reasonable request window but clarifies that: The 30-day internal window applies to the Company's own administrative process. It does not operate as a contractual limitation period that extinguishes statutory consumer rights. Statutory claims under consumer protection law are subject to the limitation periods prescribed by applicable national law (not the Company's internal administrative window). Where a client submits a refund request after 30 days, the Company will consider it on its merits and apply mandatory law. The request may be declined on non-statutory grounds only where no mandatory right to a refund exists under applicable law. 7.8.5 Internal Appeal Where a refund request is denied, the claimant may appeal by submitting additional documentation or representations within ten (10) business days of the written decision, consistent with legacy NOVARIC-POL-TC-001 Section 6.4.A.11. This internal appeal: Is a voluntary, accessible mechanism — not a prerequisite for any statutory or judicial remedy; Does not suspend or extend any statutory limitation period for bringing legal proceedings; Does not prevent the claimant from simultaneously lodging a complaint with a regulatory authority or consumer tribunal; Does not require any waiver, non-disclosure undertaking, or withdrawal of any complaint as a condition of participation. 6.9 Unrestricted Access to Regulators & Statutory Remedies 🛡️ Absolute commitment — no derogation permitted. Invoking this refund procedure, accepting a full or partial refund, signing a settlement, or engaging in any internal or external dispute mechanism does not and cannot waive, restrict, condition, or penalise the client's or candidate's right to exercise any of the following: Regulatory complaints (Malta): Malta Competition and Consumer Affairs Authority (MCCAA), Director of Employment and Industrial Relations (DIER), Identità Malta (procedural complaints), Consumer Claims Tribunal. Regulatory complaints (Albania): Consumer Protection Commission, State Labour Inspectorate ( Inspektorati Shtetëror i Punës ), any other competent Albanian regulatory authority. Regulatory complaints (Montenegro — when operative): Market Inspection ( Tržišna inspekcija ), Agency for Protection of Personal Data and Free Access to Information (AZLP). Independent legal advice: Any client, candidate, or beneficiary may obtain legal advice from a lawyer, law centre, or legal aid authority of their choice at any time. Legal proceedings: Any client or candidate may initiate legal proceedings before the courts or tribunals of competent jurisdiction under applicable national law or, where applicable, Regulation (EU) No 1215/2012 (Brussels I Recast) on jurisdiction in consumer matters. Whistleblowing and regulatory reporting: Any person may report suspected unlawful conduct to competent regulatory, law enforcement, or prosecutorial authorities without restriction. Absolute prohibition — complaint-conditioned refund. NOVARIC ® shall never, under any circumstances, condition the processing or payment of a refund on: (a) the withdrawal of a complaint filed with a regulatory authority, court, or tribunal; (b) the signing of a non-disparagement, confidentiality, or non-disclosure agreement as a condition of receiving moneys owed; (c) the provision of notarised or other evidence of regulatory withdrawal; or (d) any other act or undertaking that has the effect of deterring the exercise of statutory rights. Any term in any document issued by or on behalf of the Company that purports to have such an effect is void, unenforceable, and contrary to the mandatory provisions of Directive 93/13/EEC, Directive 2005/29/EC, Malta Cap. 378 Part VI Section 44, and Albanian Law 9902/2008 Article 27. 7.9.1 Consumer Jurisdiction Note Section 12 of these Master Terms provides that disputes arising from services by NOVARIC ® Ltd. are subject to Maltese jurisdiction and that disputes from services by NOVARIC ® Sh.A. are subject to Albanian jurisdiction. In relation to consumer contracts, Regulation (EU) No 1215/2012 (Brussels I Recast), Articles 17–19, provides that a consumer habitually resident in an EU Member State may bring proceedings against a trader in the courts of the consumer's own domicile, and may only be sued in their own domicile. An exclusive jurisdiction clause that purports to override this right is unenforceable against a consumer in an EU consumer-contract context. 6.10 Jurisdictional Application Notes Malta Application Note Services contracted by NOVARIC ® Ltd. (C 63881) are additionally governed by: S.L. 452.130 (Employment Agencies Regulations, L.N. 270/2023 as amended by L.N. 108/2024, 109/2024, 147/2026) — Regulation 15 strictly prohibits charging recruitment placement fees to workers and jobseekers. Any Category D charge to a candidate is void and refundable. Consumer Affairs Act (Cap. 378) , Part VI — implements Directive 93/13/EEC on unfair terms. The MCCAA enforces consumer protection rights in Malta. The Consumer Claims Tribunal has jurisdiction over consumer claims. The Arbiter for Financial Services (Cap. 555) has no jurisdiction over immigration, recruitment, or general consumer service disputes. Directive (EU) 2024/1233 (Recast Single Permit Directive) — 90-day decision benchmark for Identità Malta. The Company cannot guarantee a permit outcome or timeline but will process applications diligently within this framework. Civil Code (Cap. 16) , Articles 1032, 1134 — liability for breach of professional obligations and mandate. Albania Application Note Services contracted by NOVARIC ® Sh.A. (NUIS/NIPT M02111033E) are additionally governed by: Law No. 7850 (Kodi Civil) , Articles 450, 771–783 — mandate contract rules and professional diligence obligations. Law No. 9902/2008 "Për Mbrojtjen e Konsumatorëve" , Articles 27–28, 35–42 — unfair contract terms prohibition and consumer rights in distance selling. Conditions that bar refund processing based on external complaints or reputational allegations are prohibited as unfair terms. Law No. 15/2019 "Për Nxitjen e Punësimit" , Articles 7–8 — absolute prohibition on placement fees charged to jobseekers by private employment agencies. Law No. 79/2021 "Për të Huajt" — residence and work permit framework in Albania. Sovereign discretion applies; the Company does not guarantee administrative outcomes. Montenegro Application Note — Conditional & Inactive INACTIVE. This note is informational only. No contractual rights or obligations arise in Montenegro until Schedule C is formally activated following CRPS registration, Ministry of Labour licensing, tax registration, and executive adoption. EU Directives, EU consumer protection standards, and Maltese domestic law do not have direct legal force in Montenegrin domestic administrative proceedings. When and if Schedule C is activated, the following Montenegrin instruments apply to refund and complaint rights: Zakon o zaštiti potrošača ("Sl. list CG", br. 2/14, 6/14, 43/15, 70/17, 67/19, 146/21) on unfair terms and Market Inspection jurisdiction; Zakon o obligacionim odnosima ("Sl. list CG", br. 47/08, 4/11, 22/17) on mandate and professional liability; Zakon o posredovanju pri zapošljavanju ("Sl. list CG", br. 24/19, 86/22, and reported amendment 003/26 Unresolved amendment text pending official gazette confirmation ) on the prohibition on charging placement fees to jobseekers. 7. Data Protection & Nexus Human Governance & Nexus Human Governance 6.1 Data Processing Principles The Company processes personal data as a data controller in accordance with: Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR), applicable to NOVARIC® Ltd. (Malta) and to NOVARIC® Sh.A. (Albania) by contractual alignment and institutional policy Maltese implementing legislation (Data Protection Act, Chapter 586 of the Laws of Malta) Albanian Law No. 9887/2008 as amended on the Protection of Personal Data The Company's Data Protection & Privacy Policy, published at novaric.eu/en/governance/?document=data-protection-privacy Cross-border data transfer safeguards (Standard Contractual Clauses or equivalent mechanisms) and internal data processing roles and records are subject to ongoing data governance audits. Clients may request information about data transfers and processing roles by contacting the Company's Data Protection Officer. 6.2 NOVARIC® Nexus System — AI Role Definition AI assists; humans decide. The Company uses the NOVARIC ® Nexus COMM and Case Progress Centre systems, which incorporate artificial intelligence tools to assist in workflow tracking, preliminary message categorisation, document scheduling, and procedural reminders. These AI tools do not, and may not, make legal determinations, complaint adjudications, refund dispute evaluations, or any binding decisions on behalf of the Company. All such decisions are strictly performed by qualified human officers. No automated algorithm, AI model, or autonomous agent holds authority to bind the Company, determine client rights, or conclude any legal or commercial outcome. 6.3 Candidate Data Rights All data subjects are entitled to exercise their rights under GDPR, including the rights of access, rectification, erasure, restriction, portability, and objection. Requests should be directed to the Company's Data Protection Officer at the contact details specified in the Company's Data Protection & Privacy Policy. 8. Service Delivery Standards Standards The Company will deliver services with reasonable professional skill and care. Specific service deliverables, timelines and communication standards will be detailed in individual Service Orders. Where no specific timeline is agreed, the Company will perform within a reasonable time having regard to the nature of the service and applicable third-party and sovereign processes. This section is a high-level framework placeholder. Detailed service delivery protocols are subject to executive review and will be elaborated in final Master Terms. 9. Intellectual Property & Confidentiality Property & Confidentiality All intellectual property rights in materials, reports, templates and documentation produced by the Company in the course of service delivery vest in the applicable NOVARIC ® entity unless expressly agreed otherwise in a Service Order. The Company will treat all client and candidate information as confidential and will not disclose it to third parties except as required for service delivery, by law, or with the consent of the data subject. NOVARIC ® is a registered EU trademark (EU Trademark 018313401). Unauthorised use of the trademark or associated trade dress is prohibited. This section is a framework placeholder pending finalisation of IP and confidentiality provisions. 10. Limitation of Liability of Liability To the maximum extent permitted by applicable law, the Company's aggregate liability to any client or candidate arising out of or in connection with services provided under these Master Terms and any Service Order shall not exceed the total fees paid by that client or candidate for the specific service giving rise to the claim, in the 12 months preceding the event giving rise to the claim. Nothing in these Master Terms excludes or limits the Company's liability for: (a) death or personal injury caused by negligence; (b) fraud or fraudulent misrepresentation; (c) any liability that cannot be limited or excluded by law. This section is a framework placeholder. The proportionality and enforceability of liability caps under applicable consumer protection law require legal review and may be subject to modification. 11. Force Majeure & Sovereign Discretion & Sovereign Discretion The Company shall not be liable for any delay or failure in performance caused by circumstances beyond its reasonable control, including but not limited to: decisions by sovereign authorities on permits, visas or clearances; changes in law or government policy; natural disasters; industrial action; or failure of third-party systems or infrastructure outside the Company's control. Force majeure does not entitle the Company to retain fees for services not rendered. The proportional refund obligations in Section 6 apply where relevant. 12. Governing Law & Dispute Resolution Law & Dispute Resolution Governing law and jurisdiction are determined by the contracting NOVARIC entity and the applicable jurisdictional Schedule: Services by NOVARIC ® Ltd.: governed by the Laws of Malta (see Schedule A ) Services by NOVARIC ® Sh.A.: governed by the Laws of the Republic of Albania (see Schedule B ) Montana schedule inactive; no governing law provision operative (see Schedule C ) Specific dispute resolution clauses, including any arbitration or ADR provisions, are subject to legal review and will be finalised in the adopted version of these Master Terms. 13. Amendments & Communications & Communications These Master Terms may be amended only by written instrument executed by an authorised officer of the relevant NOVARIC ® entity, subject to the document control procedures under which these terms are maintained. Material amendments affecting clients or candidates under active Service Orders will be notified in advance, with a reasonable period allowed for the client to raise objections or terminate without penalty where the amendment is to their detriment. 14. Severability & Entire Agreement & Entire Agreement If any provision of these Master Terms is held to be invalid, unlawful, or unenforceable by a competent court or authority, that provision shall be severed and the remaining provisions shall continue in full force and effect. The parties shall negotiate in good faith to replace any severed provision with a valid and enforceable provision that achieves the same commercial purpose to the greatest extent possible. These Master Terms, together with any applicable jurisdictional Schedule and the specific Service Order, constitute the entire agreement between the parties with respect to the subject matter and supersede all prior representations, understandings and agreements, except as provided in the Precedence Note in Section 1.3. Schedule A — Malta Specific Schedule A.1 Governing Law Services contracted by NOVARIC ® Ltd. (C 63881) are governed by the Laws of Malta, including the Civil Code (Chapter 16 of the Laws of Malta) and applicable subsidiary legislation. The courts of Malta shall have exclusive jurisdiction over disputes arising from such services, subject to any mandatory consumer protection forum rights. A.2 Employment Agencies Regulatory Framework — S.L. 452.130 Regulatory disclosure. Employment agency services in Malta are regulated by Subsidiary Legislation 452.130 — Employment Agencies Regulations (enacted via Legal Notice 270 of 2023, as amended by L.N. 108 of 2024, L.N. 109 of 2024, and Legal Notice 147 of 2026). Authoritative text: legislation.mt/eli/sl/452.130/eng . Verified legal source L.N. 270/2023 confirmed; amendments L.N. 108/2024, L.N. 109/2024 and L.N. 147/2026 as c … S.L. 452.130 distinguishes three principal licence categories: Recruitment Agency / Employment Agency: Provides permanent or fixed-term placement services to employers. Subject to licensing by the Director of Employment and Industrial Relations (DIER). Employment Business (Temporary Work Agency / Labour Hire): Supplies workers to client undertakings on a temporary basis. Subject to separate licensing and bank guarantee requirements. Outsourcing Agency: Provides outsourced service delivery where the agency is responsible for the work outcome and supervision of workers. Licence classification: The applicable NOVARIC® Ltd. licence category under S.L. 452.130 is flagged for executive confirmation and verification against DIER licensing records. [UNRESOLVED — requires DIER register extract] Fee prohibition — Regulation 15: Regulation 15 of S.L. 452.130 prohibits any employment agency from charging fees to jobseekers or to persons applying for employment. The Company is bound by this prohibition in all Malta-jurisdiction engagements. Verified legal source Regulation 15 confirmed as the operative fee prohibition; exact statutory wording subje … A.3 EU Single Permit Framework — Directive 2024/1233 The EU Single Application Procedure Directive 2024/1233 of 24 April 2024 (OJ L 2024/1233, 30.4.2024) entered into force and repeals Directive 2011/98/EU with effect from 22 May 2026 (Article 20 of Directive 2024/1233). Verified legal source repeal date confirmed from Directive text: eur-lex.europa.eu/eli/dir/2024/1233/oj Under the Directive (Article 5(2) and Article 8), competent national authorities must issue a decision on a complete single permit application within 90 days of the date of submission of the complete application. An extension may apply in complex or exceptional cases. Procedural implementation in Malta is administered by Identità Malta . Verified legal source 90-day deadline confirmed from Directive 2024/1233 text Important limitation. EU Directives apply in Malta via national transposition and Identità Malta procedural guidelines. The Company does not and cannot guarantee a guaranteed approval, a fixed issue date, or any outcome of any permit application. The 90-day benchmark is a statutory obligation on the competent authority, not on the Company. Actual processing timelines depend on individual case complexity, completeness of documentation, and sovereign administrative capacity. A.4 Consumer Protection — Malta & EU Framework Where a client or candidate qualifies as a consumer under applicable law: Consumer Rights Directive 2011/83/EU: Distance contract cooling-off rights, pre-contract information obligations (Article 6(1)), and withdrawal provisions (Articles 14(3), 16(a), 16(m)) apply as set out in Section 6 of these Master Terms. Unfair Terms Directive 93/13/EEC: Any term that creates a significant imbalance to the detriment of the consumer is unfair (Article 3) and voidable. The indicative list of potentially unfair terms in the Annex to Directive 93/13/EEC includes: (d) terms permitting the seller to retain sums paid where the consumer decides not to conclude or perform the contract without providing for the consumer to receive equivalent compensation where the seller is the party cancelling; (i) terms irrevocably binding the consumer to conditions with which they had no real opportunity to become acquainted before the conclusion of the contract; (q) terms excluding or hindering the consumer's right to take legal action or exercise any other legal remedy. Malta Consumer Affairs Act (Cap. 378): Part VI and S.L. 378.17 provide additional consumer protection in Malta. Regulatory complaint routes (Malta): Malta Competition and Consumer Affairs Authority (MCCAA — mccaa.org.mt ); Consumer Claims Tribunal; Director of Employment and Industrial Relations (DIER) for employment-related complaints. Note: References to the Arbiter for Financial Services (Cap. 555) have been removed from this document. The Arbiter for Financial Services has jurisdiction over financial services complaints, not general consumer or employment services complaints. The competent consumer authority is the MCCAA. Schedule B — Albania Specific Schedule B.1 Governing Law Services contracted by NOVARIC ® Sh.A. (NUIS/NIPT M02111033E) are governed by the Laws of the Republic of Albania. The competent courts of Albania shall have jurisdiction over disputes arising from such services, subject to mandatory consumer forum rights. B.2 Albanian Legal Framework Albanian Civil Code (Law No. 7850 — Kodi Civil) Articles 450 et seq. govern the obligation of professional diligence. Articles 771–783 govern the contract of mandate and agency ( Kontrata e Porosisë ), which characterises the Company's representation obligations. Consumer Protection (Law No. 9902/2008 "Për Mbrojtjen e Konsumatorëve") Articles 27–28 prohibit unfair contract terms in consumer agreements. Distance selling provisions apply to contracts concluded remotely. Project reported legislative text confirmation pending Employment Promotion (Law No. 15/2019 "Për Nxitjen e Punësimit") Regulates private employment agencies and prohibits the charging of placement fees to jobseekers. The Company is bound by this prohibition for all Albania-jurisdiction engagements involving employment mediation. Project reported legislative text confirmation pending Law on Foreigners (Law No. 79/2021 "Për të Huajt") Governs residence and work permits for foreign nationals in Albania. The Company assists with documentation and procedural coordination but does not guarantee any administrative outcome. Project reported legislative text confirmation pending B.3 NOVARIC® Academy — Educational and Employment Mediation Services NOVARIC ® Sh.A. (NUIS/NIPT M02111033E) holds a verified Private Employment Agency Licence in Albania: Licence number LN-9041-02-2025 Verified record QKB Licence Document Category code X.2.A — Employment mediation services in the labour market and/or professional training Subcategory Employment mediation in the labour market (Private Employment Agencies) Issued by Ministry of Finance and Economy, National Business Center (QKB), Republic of Albania Ministerial approval Decision No. 2609/1 prot., Minister of Economy, Culture, and Innovation Blendi Gonxhja, 14 February 2025 Verified record Ministerial Approval Letter Issue date 14 February 2025; Validity: Indefinite Licensed place of business Shkodër, Rruga Studenti, Nd 2, H 6, 4001, Albania Academy educational and vocational training services are subject to the following terms: Enrolment is voluntary and separate from any employment-placement or mobility service Tuition fees are disclosed in full before enrolment commitment Certification standards and programme outcomes are described accurately in programme materials Academy enrolment does not create any obligation to engage employment placement services and does not confer any advantage in employment placement decisions B.4 Regulatory Complaint Routes (Albania) Albanian Consumer Protection Commission (Komisioni i Mbrojtjes së Konsumatorit) State Labour Inspectorate (Inspektorati Shtetëror i Punës) National Business Centre (QKB) for corporate registration queries Courts of Albania for contractual disputes Schedule C — Montenegro Conditional Schedule CONDITIONAL SCHEDULE — INACTIVE. This Schedule C is inactive in its entirety. It establishes no commercial offer, no contractual rights, and no representation of any kind in Montenegro or for Montenegro-related services. This schedule will not become operative until all of the following conditions are satisfied and formally recorded: (1) corporate registration with the Central Registry of Business Entities of Montenegro (CRPS); (2) licensing by the competent Montenegrin ministry or authority; (3) tax registration (PDV — Porez na dodatu vrijednost) in Montenegro; (4) appointment and confirmation of local legal counsel; (5) formal written executive approval incorporating this schedule into the operative Master Terms. C.1 Legal Framework Reference (Information Only — Not Operative) For reference purposes only, the following Montenegrin legislative instruments would be relevant upon activation of this schedule. No representation is made as to the current accuracy or completeness of any legislative citation below pending formal legal review: Employment Mediation Zakon o posredovanju pri zapošljavanju i pravima za vrijeme nezaposlenosti ("Sl. list CG", br. 24/19, 86/22, and reported amendment "Sl. list CG", br. 003/26 Unresolved br. 003/26 amendment text pending confirmation from sluzbenilist.me Foreigners Zakon o strancima ("Sl. list CG", br. 12/18, 3/19, 86/22 and subsequent amendments). Governs the issuance of temporary residence and work permits ( dozvola za privremeni boravak i rad ) by the Ministry of the Interior ( Ministarstvo unutrašnjih poslova — MUP ) under annual quotas ( godišnja kvota ). Project reported full amendment history pending confirmation Consumer Protection Zakon o zaštiti potrošača ("Sl. list CG", br. 2/14, 6/14, 43/15, 70/17, 67/19, 146/21). Rules on unfair contract terms and jurisdiction of the Market Inspection ( Tržišna inspekcija ). Obligations Zakon o obligacionim odnosima ("Sl. list CG", br. 47/08, 4/11, 22/17). Governs mandate ( ugovor o nalogu ) and professional liability for diligence. Personal Data Zakon o zaštiti podataka o ličnosti ("Sl. list CG", br. 79/08, 70/09, 44/12, 22/17). Supervised by the Agency for Protection of Personal Data and Free Access to Information (AZLP). Note: GDPR does not have direct legal force in Montenegrin domestic administrative proceedings. C.2 Unresolved Cross-Border Questions (Information Only) The following questions require local legal counsel resolution before Schedule C can be activated: Which NOVARIC entity would be the contracting party for Montenegro services (a new Montenegro entity vs. cross-border contract from Malta entity) PDV (VAT) registration obligations and invoicing requirements under Montenegro tax law Data protection — adequacy of GDPR-equivalent protections for cross-border data flows from EU to Montenegro Employment agency licensing requirements under the Ministry of Labour and applicable bank guarantee requirements Whether EU Single Permit Directive 2024/1233 procedures apply — confirmed: EU Directives have no direct legal force in Montenegro domestic administrative proceedings Internal Case Management Tools The following tools are accessible to authorised NOVARIC® staff only. They require separate authentication and are not part of the public terms document. Real client cases may only be processed once the secure operational layer has been commissioned (Decision D-12). Internal Tool G-1 · Staff Only Case Risk Assessment Identify legal, regulatory and evidentiary risks in an active or historical case. Requires staff authentication. Demo mode — fictional data only. Open G-1 Tool → Staff login required Internal Tool G-2 · Staff Only Refund Reconciliation Calculator Itemised refund calculation including statutory entitlement, Option B assessment, and evidence requirements. Requires human approval before any disbursement. Open G-2 Tool → Staff login required 🔒 These tools require separate staff authentication independent of this page's access controls. They are not visible to or accessible by clients or the general public. Continue reading Related documents Governance documents relevant to clients, candidates, and partners. The operative client-facing terms remain NOVARIC-POL-TC-001 until these Master Terms are formally adopted. Client & Candidate Rights 3 Governance & Ethics 3 Legal & Data 2 Client & candidate rights documents Terms & Conditions Operative Terms & Conditions for Providing Services The currently operative NOVARIC® client-facing terms (NOVARIC-POL-TC-001). Governs all active engagements until these Master Terms are formally adopted. View operative terms NOVARIC-POL-TC-001 ↗ Ethics & Candidate Protection Standard Ethical Recruitment & Candidate Protection Standard NOVARIC®'s institutional commitment to fair, transparent, and candidate-protective recruitment across all operations and approved partners. Read the standard NOVARIC-POL-ETH-002 Candidate Protection Procedure Complaints Procedure How to raise a concern or complaint, internal escalation routes, timelines, and your rights to contact external regulatory bodies. View procedure Governance Hub Governance & ethics documents Partnership Governance Framework Partner Assurance & Cooperation Framework Governance standards, partner categories, approval lifecycle, and conditions for authorised cooperation with NOVARIC®. View framework DOC-PTN-001 Ethics, Fraud & Misconduct Guidance Fraud Awareness & Recruitment Scam Prevention Identify and report recruitment fraud, verify NOVARIC® communications, and protect yourself from scams. Read fraud guidance DOC-ETH-001 Technology Governance Policy Responsible AI Policy How NOVARIC® uses AI tools, the boundaries of automated decision-making, and the human-oversight mandate for all legal and client-facing determinations. Read AI policy DOC-GOV-002 Legal & data protection documents Data & Privacy Policy Data Protection & Privacy Policy How NOVARIC® collects, processes, and protects personal data, your GDPR rights, and how to contact the Data Protection Officer. Read privacy policy Governance Hub Legal Terms Website Terms & Conditions Terms governing use of the NOVARIC® website, including intellectual property, acceptable use, and limitations of liability for website content. Read website terms Legal These Master Terms are proposed for adoption and are not yet operative. The currently operative client-facing terms are NOVARIC-POL-TC-001, published at novaric.co . Upon formal adoption, these Master Terms will govern new engagements from the stated effective date. Earlier engagements are assessed under the terms accepted at the time of contracting and applicable mandatory rights. Document Record Document metadata (18 fields) Document control metadata Proposed Document ID N-DOC-10012-032026 Proposed term (Proposed allocation — not formally confirmed) Document Title NOVARIC® Master Terms of Service & Procedural Standards Document Type Terms of Service Proposed Version v4.3 — Published Category Documents & Standards Classification Internal Draft — Not for Public Distribution Publication Status Unapproved Draft — Not Published Issuing Entity NOVARIC® Group (NOVARIC® Ltd., Malta & NOVARIC® Sh.A., Albania) Applicable Jurisdictions Republic of Malta · Republic of Albania · Montenegro (Conditional — Inactive: Schedule C) Scope Review Date September 2026 Effective Date Dr. Alban Gj. THIKA, Founder & Executive Director — not yet operative Next Review To be set upon adoption Document Owner NOVARIC® Executive Board Approver Dr. Alban Gj. THIKA, Founder & Executive Director — Dr. Alban Gj. THIKA (proposed approver) Legal Reviewers Jurisdictional Legal Reviewers — Malta & Albania [PENDING ASSIGNMENT] Authoritative Language English Related Documents NOVARIC-POL-TC-001 (legacy) · NOVARIC-POL-ETH-002 · DOC-PTN-001 · DOC-GOV-002 Authoritative URL (proposed) https://novaric.eu/en/governance/service-terms/ 🛡️ Candidate and client protection. These Master Terms are designed to ensure that all persons engaging with NOVARIC ® receive services that are lawful, transparent, and fair. Nothing in these terms restricts your right to seek independent advice, contact a regulator, or exercise any statutory right you hold under applicable law. Document Control Record Authoritative document control information Proposed Document ID N-DOC-10012-032026 (proposed — not formally confirmed) Title NOVARIC® Master Terms of Service & Procedural Standards Version v4.3 — Published Status Published / Approved Classification Public Issuing entity NOVARIC® Group Jurisdiction Malta · Albania · Montenegro (Conditional — Inactive) Document owner NOVARIC® Executive Board Approver Dr. Alban Gj. THIKA, Founder & Executive Director Effective date Not operative — pending approval Approved 29 September 2026 Next review To be set upon adoption Authoritative source https://novaric.eu/en/governance/service-terms/ Published by NOVARIC® under document-control procedures. Approved 29 September 2026 by Dr. Alban Gj. THIKA, Founder & Executive Director. This document is the primary controlled copy at the authoritative URL. Effective date: 29 September 2026. Governed by NOVARIC® document-control procedures and subject to review, version control and legal approval. Document ID: N-DOC-10012-032026 (formally allocated upon adoption). ↑ Top We use essential cookies to make this site work. We would like to use optional analytics cookies to improve it — only with your consent. See our Cookie Policy . Accept essential only Accept all Manage preferences ================================================================================ END — N-DOC-10012-032026 v4.3 — 29 September 2026 ================================================================================