CODE OF CONDUCT

1.Message from the Manager / Management

In a globalized and constantly changing world, all members of NovoGenio are daily in direct contact with different types of Companies, Employees, Citizens, Organizations, Asociations from different Countries, Cultures, Race and Genders. In any cases the relationship from NovoGenio Team members will be framed by the NovoGenio pilar values as they are Respect, Integrity, Compromise, Transparency and Excellence.

Being conscious of the need to keep the values at their higher standards we have constructed a Code of Conduct to serve as a guide and reference for all NovoGenio team members. This Code of Conduct is a living document that must be observed internally by all NovoGenio staff, regardless of their position.

The Code of Conduct reflects our values, and it is a guide to help ensure we are conducting our business activities to the highest ethical standards. It provides basic principles that guide interactions with fellow employees, clients, competitors, government bodies, suppliers, and the global community.

At NovoGenio, we firmly believe that the success of these policies lies in our ability to participate and create a dialogue for the continous internal improvement of management processes. With this in mind, I encourage everyone at NovoGenio to be the leader in terms of ethics, honesty, integrity, compromise, excellence and transparency in each and every one of the projects in which you participates.

As CEO of NovoGenio, I will personally promote this project, which places our values at the center of our work and relationship with our suppliers, customers and partners.

Dr. Gerardo Hidalgo Llinás

2.Introduction

NovoGenio constitutes this code as the framework that will serve as a guide for the entire team that makes up this company, setting the different values and principles that are a reference for NovoGenio in decision-making under any circumstance.

The objective that we pursue through the Code of Ethics and Business Conduct is to provide our professionals and the rest of the external agents that interact with the company on a day-to-day basis, regardless of the greater or lesser degree of responsibility they hold in the company, a series of behavior guidelines to be observed for a performance that is related to the spirit of the company.

In this way, our professionals will be able to respond to the trust placed by our environment through performance based on honest, diligent and ethically acceptable conduct, always seeking the satisfaction of all parties involved, both our workers and our clients and collaborators.

At NovoGenio we provide our services in accordance with these ethical principles. For effective compliance with the Code, the company makes available to its professionals an Ethics and Business Conduct Committee, which will act as an autonomous and independent internal body, helping them to perform appropriately in the practice of corporate values.

This code is addressed to the entire professional team of NovoGenio, including both the entity's administrators and any employee thereof, so that actions at all levels are in tune with the same business culture. Likewise, we will use our best efforts so that all our customers, suppliers and other stakeholders are aware of our code for an effective understanding of the nature and essence of NovoGenio.

3.Scope

This code establishes how NovoGenio must behave towards its interested parties or interest groups:

- Employees and those who work with us.

- Clients

- The society and environment in which we carry out our activity.

- Suppliers and partners in the value chain.

- Competitors and other business partners.

- Shareholders.

- Administration.

4. Values

We are a creative, innovative and versatile team, with ease for changes and a great capacity for adaptation. The following values must inspire all our activity, and be the NovoGenio seal in each service and decision made in our professional performance:

Excellence: we are committed to improving ourselves, we seek the highest quality in each project in which we are involved.
Commitment: our work must always be in accordance with the principles present in this code, rejecting any proposal that contradicts them.
Respect: we strive to understand the environment that surrounds us in order to develop a behavior that takes into account the different sensitivities of all those who are related to our company.
Reliability: to offer the highest quality in any service we provide, advising the client solidly and rigorously, being punctual in time and form.

5. Legal compliance

Compliance with the law is an unconditional requirement for NovoGenio, which undertakes to act in accordance with current legislation in all its manifestations..

NovoGenio doesn’t tolerate any violation of the law, nor complicity in any such violation.

6. Human Rights

NovoGenio carries out its activity and operations in a way that respects human rights, treating our workers and the workers of our suppliers with dignity, promoting fair labor practices. This includes offering fair and competitive wages, prohibiting harassment, intimidation and discrimination, prohibiting the use of child, forced, bonded or incarcerated labor and not engaging in human trafficking for any purpose

6.1 Child labour

NovoGenio undertakes not to use child labor in carrying out its work. The term “child” refers to any person below the legal minimum age to obtain employment in Spain.

All workers under 18 years of age will be protected against carrying out work that may be dangerous or harmful to their health, physical, mental, social, spiritual or moral development.

6.2 Slavery and human trafficking

NovoGenio avoids any involvement in any form of modern slavery, including human trafficking and forced, bonded labor.

All work must be voluntary on the part of the employee.

NovoGenio provides all employees with a written contract in a language they understand, which clearly outlines their rights and responsibilities with respect to wages, working hours, benefits, and other conditions of work and employment.

7. Employment practices

7.1. Harassment and intimidation

NovoGenio guarantees its employees a work environment free from physical, psychological, sexual and verbal harassment, as well as intimidation or other abusive conduct.

7.2 Diversity and inclusion

NovoGenio fosters a diverse and inclusive work environment in which employees are treated with dignity, respect and fairness, regardless of race, color, religion, gender, age, national or ethnic origin, disability, sexual orientation or preference, identity of gender, marital status, citizenship status, political preference, or other personal characteristic.

NovoGenio provides equal employment opportunity to employees and applicants for employment without discrimination, and complies with all nondiscrimination laws and regulations.

NovoGenio guarantees that employment, including hiring, pay, benefits, promotion, firing, and retirement, is based on ability and not on any personal characteristics.

7.3 Wages and benefits

NovoGenio remunerates workers as established in the General Agreement of the Chemical Industry, and provides all legally stipulated benefits. In addition to the remuneration for their normal working hours, the workers are compensated, as established in the aforementioned Agreement.

7.4 Working hours

NovoGenio acts taking into account the rules of the Workers' Statute and the General Agreement of the Chemical Industry that regulate work, hours of rest and annual vacations. Hours worked beyond the normal work week are voluntary.

7.5 Social dialogue and Freedom of association

NovoGenio respects the right of workers to freely associate and communicate openly with management about working conditions, without fear of harassment, intimidation, penalty, interference, or retaliation.

NovoGenio recognizes and respects any right of workers to exercise their legal rights of free association, including joining or not joining an association of their choice within the legal framework.

7.6 Disciplinary and complaint mechanism (ethical channel and compliance committee)

NovoGenio has an Employee Code of Conduct to address issues relating to employee work, conduct or absence.

NovoGenio also has a grievance mechanism (described in that code), so that employees can raise a problem or concern in the workplace or appeal a disciplinary decision.

7.7 Migrant workers

The term “migrant worker” refers to a person who is going to carry out, carries out or has carried out a remunerated activity in a State of which he is not a national. NovoGenio ensures that migrant workers are hired in full compliance with the employment and immigration laws of the host country.

8. Integrity and business ethics

8.1. Anti-corruption laws

NovoGenio complies with all anti-corruption laws and regulations applicable to the performance of its duties and activities.

8.2. Illegal payments

NovoGenio refrains from offering, promising, making, accepting, or agreeing to accept inappropriate payments of money or anything of value to public officials, political parties, candidates for public office, or others.

NovoGenio does not offer or agree to receive illegal payments from customers, vendors, their agents, representatives, or others. NovoGenio prohibits its employees from receiving, paying, or promising amounts of money or valuables, directly or indirectly, intended to exercise undue influence or improper advantage.

8.3. Fraud and deceit

NovoGenio does not promote the achievement of advantages of any kind by acting fraudulently, deceiving people, making false claims or allowing someone to do so on our behalf. This includes defrauding or stealing and any type of misappropriation of property or information.

8.4. Competition and antitrust

NovoGenio does not engage in formal or informal anti-competitive agreements that fix prices, collude, rig bids, limit supply, or allocate/control markets. We do not exchange current, recent, or future pricing information with competitors. We alsodo not participate in any cartel or in any activity that illegally restricts or affects competition.

8.5. Gifts/business attentions

NovoGenio competes based on the merits of its products and services. NovoGenio does not use the exchange of business courtesies to gain an unfair competitive advantage. Gifts of cash or its equivalent will not be offered or accepted.

8.6. Inside information

NovoGenio and its personnel will not use any material or non-publicly disclosed information obtained in the course of its business relationship with customers and suppliers as a basis for trading or allowing others to trade in shares or securities of any company.

8.7. Conflict of interests.

NovoGenio will avoid any conflict of interest or situations that give the appearance of a potential conflict. NovoGenio will notify all affected parties in the event of an actual or potential conflict of interest. Among them is the conflict between the interests of customers or suppliers and personal interests or close relatives, friends or associates.

9. Environment, health and safety

NovoGenio is a company committed to its surroundings and the environment. We seek sustainable development, production and consumption, production and consumption,in line with the principles of the Rio Declaration on Environment and Development. We continuously work on optimizing our processes to minimize the consumption of raw materials, emissions, waste, energy use and carbon footprint in general.

NovoGenio complies with current environmental laws. We use the appropriate procedures regarding the treatment and disposal of hazardous and polluting waste.

10. Protection Information

10.1Protection of confidential and private information

NovoGenio makes sure that all confidential and private information is properly protected.

NovoGenio complies with current data privacy laws and regulations, such as the Data Protection Regulation of May 25, 2018, EU Regulation 2016/679 that harmonizes Data Protection legislation throughout the European Union , and Organic Law 3/2018 of December 7, 2018 on the Protection of Personal Data and guarantee of digital rights.

NovoGenio protects third-party confidential and proprietary information, including personal data or information, from unauthorized access, destruction,use, modification, and disclosure by implementing appropriate physical and electronic security procedures.

NovoGenio will notify its customers and suppliers of any suspected data breach or security incident as soon as it becomes aware of it.

10.2 Intellectual Property

NovoGenio complies with all laws regarding intellectual property rights, including protection against disclosure.

11. Accurate record keeping

NovoGenio creates, stores and maintains accurate records, and doesn’t alter any record entries to conceal or misrepresent the underlying transaction for which it represents.

All records, regardless of format, made or received as evidence of a business transaction must fully and accurately represent the transaction or event they document. Records must be kept in accordance with applicable requirements.

12. Governance and management systems

12.1 Ethics and business conduct committee

This code implies the commitment by the NovoGenio professional team to adhere their daily behavior to the framework of rules, principles and basic values contained therein.

To provide it with a support mechanism that provides advice on the application of the code of conduct, the opportunity to report complaints, communication of incidents, communication of potential breaches, resolution of conflict situations, providing opinions and suggestions, or any other matter related to it, NovoGenio has a communication channel and an Ethics and Business Conduct Committee.

The Ethics and Business Conduct Committee will be made up of the shareholder partners of NovoGenio. The people who make up the Ethics and Business Conduct Committee will be responsible for assessing any conduct that is inappropriate for the company and, where appropriate, taking action in this regard.

12.2 Informant´s Channel

Complaints of the code of ethics and business conduct, suggestions, etc., may be addressed anonymously to the postal address:

Novogenio S.L. Ethics and Business Conduct Committee

Polígono Industrial Los Camachos

C/ Circonio, Parcela 70B | PC 30369 Cartagena, Murcia, Spain.

Or through the following contact channel:

https://app.kenjo.io/whistleblower/fc4d5423f90eedd96261ec9ce2d611a73c1c37f8cfaf2d3bb848d8cd89b112cd

Both the postal address and this code are published on the NovoGenio website and are thus made available to interested parties. The information received in said postal address will be received by the NovoGenio manager, who will communicate the content to the Ethics and Business Conduct Committee. If the complaint is not anonymous, the NovoGenio manager undertakes not to reveal in any case the identity of the person providing the information and the committee should focus on the content of the complaint, query or reported incident. NovoGenio will act to prevent, detect and correct any act of retaliation.

NovoGenio

Ethical Code