NDRC Staff Code of Conduct

NDRC is committed to providing the highest standards of customer service delivery. This Code of Conduct for NDRC employees.

Ethical Standards

The Company requires you to display a primary duty of care to NDRC in respect of professional ethics. You must protect confidential business information to ensure continued business success and growth. It is the policy of NDRC to consistently conduct its business with honesty and integrity and in compliance with all legal and ethical standards, together with established NDRC policies. You are required to conform to a high standard of ethics in relation to business activities with colleagues, customers and suppliers.

Confidentiality

1

You are required to protect NDRC confidential business information and not disclose it to other parties. Other than when your job clearly requires it, you may not remove any documents or items belonging to NDRC or which contain any confidential information from NDRC’s premises at any time without proper authorisation.

2

If you disclose intellectual property rights/programme design/research or any other confidential business information while employed, or after ceasing to be employed, you will be subject to disciplinary action up to and including dismissal and legal action, even if you do not actually benefit from the disclosed information.

3

The above includes, but is not limited to, NDRC’s electronic communications infrastructure. At all times, you must behave with honesty and integrity and respect the rights and privacy of others in relation to electronic communication and information. It is your responsibility to safeguard NDRC information assets by understanding and complying with all policies in this area. NDRC reserves the right to monitor all electronic communication and files. Personal data must be treated with the utmost confidentiality and only for the purposes intended in accordance with GDPR law and NDRC’s Privacy Policy. Should you suspect that a data breach has occurred you must report it immediately according to NDRC’s Data Breach Policy.

4

Copyright in all writing, materials, processes, etc. created and produced by you while employed by NDRC are vested in NDRC for the full period of the copyright, including extensions and renewals thereof.

5

Upon termination of your employment, you shall immediately deliver up to NDRC all manuals, employee handbook, letters, notes, notebooks, reports and all other materials held by you. They remain at all times the property of NDRC.

Equality and Respect

NDRC is committed to policies and practices that protect the dignity of employees, provide equality of opportunity for all and promote respect for others at work. You are required to take personal responsibility to comply with these policies, behave in a non-discriminatory way and not participate in any acts of inappropriate behaviour, harassment or bullying. You must have due regard for the health and safety of yourself, your colleagues and NDRC’s workplace in general.

Conflicts of Interest

You are not allowed engage in, or be connected with, any outside business or organisation which conflicts with the interests of NDRC. You must declare in writing any potential conflict of interest that might affect your impartiality in carrying out your duties. Subject to expressed written permission, employees may be entitled to pursue other business activities/financial interests outside normal working hours.

Gifts

You must not accept gifts or favours from customers or suppliers which could compromise them or you. The Financial Policies and Procedures Manual (FPPM) sets out full details on NDRC’s hospitality and entertainment policies.

Protected Disclosures

You have a duty to promptly report to the CEO or Chairman of the Board any evidence of any improper conduct or practice of which you are or become aware. Improper conduct means any illegal, fraudulent, dishonest, negligent or otherwise unethical action arising in connection with the Company’s business. The Company’s Protected Disclosure Policy sets out full details on this subject.

Breach of this Code

Breaches of this Code of Conduct, other employee policies and procedures, and other NDRC procedures will be regarded as a breach of discipline and will be dealt with in accordance with NDRC’s disciplinary procedure, which is set out in detail in the Employee Handbook.