EMPLOYEE CODE OF CONDUCT

THE SEVEN PRINCIPLES of the Novolex Employee Code of Conduct provide clear expectations for employee behavior and are the foundation of the company’s requirements for ethical business conduct. All Novolex employees must sign the code as part of the hiring process. The principles of the code are incorporated into Novolex employee handbooks, which are also introduced during new hire orientation. Additionally, the code and handbooks encourage employees to speak up if they believe they have witnessed a violation of the code. Employees can use the independent Novolex Ethics Helpline to confidentially report potential violations of the code. Novolex does not retaliate against employees who use the Helpline to report suspected violations.

Human Rights

Employee Code Of Conduct Principles

1 Obey the law

2 Avoid conflicts of interest

3 Keep accurate and honest records

4 Honor business obligations

5 Treat people with dignity an d respect

6 Protect company information, a ssets and interests

7 Commit to be a responsible gl obal citizen