BUSINESS CONDUCT, COMPLIANCE AND ETHICS PROGRAM

Employee Relations — Respecting the Rights of Employees

Novation is committed to equal employment opportunity. We offer a drug-free work environment to all qualified applicants without regard to race, religion, color, sex, age, national origin, sexual orientation, disability, marital status, veteran status or any other category protected by applicable law. Equal employment opportunity includes hiring, training, promotion, transfer, demotions and termination.

Illegal Drugs and Alcohol

Novation is committed to maintaining a drug- and alcohol-free environment for its employees that is in compliance with applicable state and federal laws. Accordingly, the unlawful or unauthorized possession, use or dispensation of controlled substances or alcohol is prohibited on Novation premises and at Novation-sponsored functions.

Open Door Policy

All supervisors and managers should maintain an “open door policy” that permits any employee to voice concerns or ask questions relating to Novation’s business. Employees are encouraged to take such matters to their direct supervisor, but if the supervisor cannot help or is part of the problem, the employee is welcome to speak with another member of management or the Human Resources Department. The Compliance Department is an additional resource for all employee complaints or questions relating to these Standards or Novation’s compliance with governing laws and regulations. In order to assure that employees speak up promptly so that their concerns can be addressed, it is Novation’s policy that no one will be retaliated against for raising, in good faith, what they believe to be a genuine issue or concern.

Sexual Harassment and Workplace Violence

Novation is committed to providing its employees with an environment that encourages efficient, productive and creative work. To demonstrate this commitment, the company strictly prohibits workplace violence and sexual or other harassment of any employee by other employees, contract personnel or vendors. Violence against or harassment of employees occurring in the workplace or in other settings in which the employees may find themselves in connection with their employment is unlawful and will not be tolerated.