The present Charter is not intended to remind or complete all the laws and regulations, conventions or internal guidelines that govern the activities of the company and its employees. It also cannot address all the situations that managers or employees may encounter during their activities.

There are many situations that are not covered by internal and external laws, regulations, or other standards. In such situations, the principles of integrity, respect and fairness must govern the conduct of each individual, without prejudice to local laws and regulations.

Each employee must exercise vigilance, thoughtfulness, common sense, and good judgment.

The purpose of this Charter is not to detail in an exhaustive way the behaviors to be adopted in each situation, but to provide guidelines and to recall the spirit that must govern each decision.

Sometimes, some situations may not be simple. However, any decision must be made in consideration of the principles of this Charter and requires asking some fundamental questions:

• Is it legal?
• Does it comply with the Ethics Charter?
• What is the consequence of my action or inaction?
• Would I feel comfortable explaining and justifying my decision if it were known within the company or externally?
• Is it aligned with Novolyze’s values?

 

1. CONFIDENTIALITY AND DISCRETION

2. INTEGRITY

2.1. RESPECT OF PEOPLE

2.2. RESPECT FOR THE RULES OF TRADE

2.3. RESPECT FOR PROPERTY AND DATA

3. PROFESSIONNALISM

3.1. RESPECT OF PARTNERS

3.2. RESPECT OF SAFETY, HYGIENE AND WORKING CONDITIONS

3.3. RESPECT OF DIVERSITY AND INCLUSION

4. PROTECTION OF THE PLANET

4.1. ENVIRONMENTAL MANAGEMENT

4.2. PRESERVATION OF NATURAL RESOURCES

 

1. CONFIDENTIALITY AND DISCRETION

Novolyze is committed to respecting, both internally and externally, the confidentiality of data, information, know-how, intellectual and industrial property rights, and trade secrets in the implementation of our solutions, whether in commercial relations, partnerships, collaborative initiatives or any other type of activity involving the company or our employees.

All our employees are required to keep confidential information related to Novolyze, our customers, suppliers, and internal teams for themselves only. This obligation continues even after they leave Novolyze.

All sensitive information must be kept confidential, unless it has been publicly disclosed in an authorized manner, as its unauthorized disclosure could be detrimental to Novolyze or our stakeholders. Each employee must ensure that any information which is not public, remains strictly confidential.

Novolyze will ensure that the company’s employees who may have precise and confidential information likely to have an influence on the company’s valuation publish it or use it in compliance with market rules, i.e., without exposing themselves to any insider trading.

Thus, each employee is committed to:

• Use discretion when talking about their professional activities,
• Limit the disclosure of confidential information to those who have a legitimate need to know,
• Keep securely, regardless of their format (paper or electronic), all confidential data relating to Novolyze’s activities and to the companies with which it has business relations,
• Share sensitive digital data in encrypted form with the tool(s) available with Novolyze,
• Prevent any disclosure of confidential information to persons outside Novolyze (including their family members).

 

2. INTEGRITY

Novolyze maintains honest, transparent, fair, and equitable relationships with all its our stakeholders and, in particular, with our customers, suppliers and other business partners, in accordance with the ethical principles listed in the preamble.

Consequently, Novolyze is committed to honor our contractual obligations and to respect both the letter and the spirit of its commercial agreements. Employees must act with objectivity, professionalism, integrity, and fairness in order to maintain a healthy relationship with all Novolyze’s stakeholders.

 

2.1. RESPECT OF PEOPLE

Novolyze ensures that we comply with laws and to ensure that they are respected in the exercise of our activities, in particular by ensuring that the practices of our suppliers and service providers comply with its commitments in terms of respect for people. If this is not the case, Novolyze will endeavor to implement corrective actions with the partner and, in the absence of satisfactory results, will cease business relationships with the supplier or service provider concerned.

This commitment includes in particular the non-use of forced labor -i.e., labor carried out under duress or threat-, concealed labor -not officially declared to the competent local authorities-, or child labor in any form. It also includes the refusal of any act that could be assimilated with prostitution or pimping of adults or children. Novolyze undertakes to inform the competent local authorities of any information relating to reprehensible acts in this field that we might have witnessed.

In terms of equal access, Novolyze prohibits all forms of discrimination and encourages diversity in all forms. Our company is committed to respecting the diversity of our employees and providing them with an inclusive work environment.

 

2.2. RESPECT FOR THE RULES OF TRADE

Novolyze commits to carry out our commercial activities in compliance with local regulations. In particular, the company commits to respect the specific rules governing private and public markets, regardless of the country in which it operates. Novolyze accepts for its own account and promotes in its purchasing procedures the rules of competition in all countries where the company is active.

Novolyze will therefore take particular care to fight against corruption and influence peddling, in all their forms, as these practices are subject to criminal penalties both for the company and for the individual(s) involved in any form of corruption, even indirect.

Novolyze will also be vigilant about financial flows that could have a criminal or delinquent origin or destination, in order to contribute to the fight against money laundering and the financing of terrorism. In addition, we prohibit all trade flows that would include countries under European or US embargo.

 

2.3. RESPECT FOR PROPERTY AND DATA

As part of our quality certification, Novolyze has adopted rules governing conflicts of interest and in particular their declaration. As such, all company employees are invited to inform Novolyze, through the HR department, of any situation likely to present a potential conflict of interest, as far as possible before any action or decision is being initiated.

Novolyze also undertakes to comply strictly with the laws and standards in force in each country where we operate, with a specific focus on accounting, tax, and customs. The company will respect the obligations resulting from the country in which we have chosen to establish our headquarters and to take all necessary measures to ensure that all commercial and financial transactions are faithfully and accurately recorded in our financial statements and maintained available for auditing within the framework prescribed by the legislation.

Novolyze requires our employees to observe the utmost respect in their use of company assets that may be made available to them in the course of their duties. Thus, Novolyze is committed to take all necessary measures to prevent and detect situations of misuse of corporate assets that could emanate from our entire organization.

Novolyze is also committed to protect the personal data of the individuals we deal with. We also undertake to maintain a charter for the use of information systems, with the objective to define the rules related with usage and conservation of computer data and to implement technological solutions designed to protect personal data (customers and employees).

In the same spirit, in order to protect image and reputation, we will ensure that we obtain the express authorization of individuals before using any support that includes one or more attributes of the personality of an employee or a person outside Novolyze (photograph or video representing an identifiable person, a name, etc.) and that employees who express themselves on social networks on a subject directly or indirectly related to the company, our brands or our products do not provide confidential information and/or information that could damage our reputation.

 

3. PROFESSIONNALISM

3.1. RESPECT OF PARTNERS

Novolyze is committed to creating a relationship of trust with the market by providing a reliable and relevant source of information, promoting dialogue with shareholders, and organizing meetings and visits of our premises for institutional investors, thus enabling them to meet with our operational managers and gain a better understanding of the company’s business and organization.

Novolyze also ensures that our commitment to sustainable development is reflected throughout our supply chain strategy. For that purpose, Novolyze has developed a “Supplier Code of Conduct” describing Novolyze’s social, societal, and environmental commitments and associated supplier expectations. A supplier’s failure to comply may constitute a cause of termination of the commercial relationship.

Novolyze is committed to responsible and sustainable relationships with our suppliers and to give preference to local sourcing, small and medium-sized companies, startups, rather than systematically going to large groups.

 

3.2. RESPECT OF SAFETY, HYGIENE AND WORKING CONDITIONS

Safety is one of the fundamental principles of Novolyze’s obligation as an employer and we pay particular attention to ensuring that our personnel can carry out their work in conditions of well-being and with the lowest possible exposure to risks that may be induced by its activities.

In this respect, Novolyze commits to:

• Identify and evaluate the short- and long-term risks induced by each employee’s activity, department, and workstation.
• Provide adequate training and tools to prevent work-related accidents and potential illnesses.
• Anticipate and consider the human impact of changes in working conditions.
• Take psychosocial risks into consideration and adopt appropriate management methods. Novolyze does not tolerate any form of moral or sexual harassment. We ask each employee to alert management in case of suspected situation of moral or sexual harassment in order to ensure fast implementation of the necessary corrective actions and any other appropriate measure

Novolyze is committed to ensuring transparency in our communication with employees by systematically conducting at least an annual appraisal interview with each employee, by giving each employee access to clear information on their rights and duties within the company, by providing information adapted to each local context, particularly through the translation (at least in English and in French) of internal documents, and by taking into account human impacts when implementing reorganization or restructuring projects.

Novolyze is committed to respecting the major stages of life (birth, marriage, vacations, death of a family member, etc.) and to minimizing, as much as possible for a fast-moving company, situations of unknown short-term schedule, in order to reduce the constraints linked to atypical hours.

 

3.3. RESPECT OF DIVERSITY AND INCLUSION

Novolyze prohibits all discrimination in recruitment and encourages diversity in all forms. Novolyze is committed to respecting the diversity of our employees and providing them with an inclusive work environment. To this end, Novolyze considers all applicants regardless of background when recruiting.

Even if respecting diversity, beyond the commitments and tools in place in the company, is above all an individual matter, Novolyze will ensure that everyone within our organization promotes and implements equal treatment and the prevention of discrimination. It is the responsibility of each employee to improve their practices for a better collective performance.

 

4. PROTECTION OF THE PLANET

4.1. ENVIRONMENTAL MANAGEMENT

As a responsible company, we develop our business in a way that respects the planet by reducing our environmental footprint. Our environmental policy is based on a management system that aims to control the major environmental challenges we face. We are therefore committed to defining objectives to improve our environmental performance, to deploying and monitoring their achievements through appropriate indicators and to implementing processes to ensure a controlled environmental management.

 

4.2. PRESERVATION OF NATURAL RESOURCES

Although the products and services offered by Novolyze to its customers are primarily aimed at ensuring the safety of their products, Novolyze is also committed to reducing the emissions inherent in their industrial activities as much as possible. It is also in this continuity that Novolyze is committed to controlling our own energy consumption, reducing the associated CO2 emissions – through regular monitoring of the energy performance of our activities and the implementation of reduction programs – and reducing the overall carbon footprint of our value chain. As a matter of example, Novolyze promotes remote services through the utilization of technology as much as possible in order to cut down non-essential travel.

Novolyze is also committed to preserving water resources, again by regularly monitoring consumption and controlling wastewater discharge and limiting their impact (e.g., by promoting the use of environmental-friendly products).

Novolyze also strives to implement environmental-friendly good practice to limit noise, visual and olfactory pollution, and air pollution.

Novolyze is also committed to reducing waste associated with our activities and to ensuring that waste is sorted and recycled as much as possible according to the channels available in the localities where we operate.

 

Last Updated: May 9, 2022