Employee Code of Conduct

The conduct of every Novolex^® employee can affect our reputation, the confidence that our customers and the public have in us and our potential for long term growth. The Novolex Employee Code of Conduct and Business Ethics provides our employees with our expectations for how they should conduct themselves, acting with integrity, ethically and responsibly at all times by respecting both the letter and spirit of applicable laws and regulations. Our goal is to ensure that sound business practices are in place across all aspects of our operations that will foster relationships of trust among employees and with our commercial partners, shareholders, government authorities and the communities where we live and work.

To support compliance with the Code, Novolex provides an Ethics & Compliance Helpline that employees can use to report potential violations of the Code including but not limited to fraudulent activities, financial irregularities, bribery, compliance with the US Foreign Corrupt Practices Act and the UK Bribery Act, as well as privacy and security concerns, workplace safety and employment policy practices. The Helpline utilizes an automated system that facilitates an efficient assessment and investigation process.