Novabase SGPS

Number of executive and non-executive members and percentage by gender

The Novabase Board of Directors includes a total of 9 directors, of which seven are non-executive members. For the 2024-2026 term, 33.3% the company's directors are female, thus meeting the minimum stipulated by Portuguese Law no. 62/2017 of 1 August, including one female member with special responsibilities pursuant to No. 1 of Article 407 of the Companies Code. The breakdown of executive and non-executive members of the Board of Directors and respective diversity and independence is provided in greater detail in point 18 of the Corporate Governance Report.

Representation of salaried and other employees

Novabase Group has no representation of salaried or other employees in its governing bodies.

Identity and responsibilities of administrative bodies

The members of the Novabase administrative body have a variety of skills, academic qualifications and professional backgrounds, with varying degrees of relevance to the main areas of Novabase business. For more information regarding the identity and responsibilities of each administrative body please see points 19 and 26 of the Corporate Governance Report.

Experience relevant to the sectors, products and geographical locations of the company

The professional qualifications and other relevant information for each member are listed in the Corporate Governance Report, in points 19 (Board of Directors Members), 33 (Audit Committee Members) and 68 (Remuneration Committee Members).

Description of the role of management in governance processes, controls and procedures used in follow-up, management and auditing

Pursuant to Article 14 of the Novabase Articles of Association, the Board of Directors is responsible for managing the company's business and it has exclusive and full powers of representation.

The Board of Directors is generally responsible for exercising the broadest of powers in pursuing the company's interests and business within the limits of the law, its articles of association and the decisions of the General Meeting.

For more information regarding the role of the Board of Directors in the governance processes please see point 21 of the Corporate Governance Report.

In 2024, Novabase Group continued to prioritize Sustainability and include it in its strategy.

The company maintained its Sustainability Committee, which is supervised by a Director, and it is considered highly relevant when it comes to decision-making.

The Board of Directors is informed at least quarterly with respect to the development and implementation of policies, actions and meeting sustainability targets.

Novabase's Remuneration Committee is appointed by the General Meeting and it is charged with establishing the remuneration of each member of the governing bodies, in accordance with the Remuneration Policy approved at the General Meeting of 25 May 2021. Point 69 of the Corporate Governance Report contains more details regarding the policy and structure of the remuneration of the company's governing bodies.

Novabase Group is solidly committed to due diligence in all of its operations, ensuring that all of its corporate processes and decisions are conducted with integrity, transparency and responsibility. Accordingly, a structured approach is undertaken in order to identify, assess and mitigate risks related to human rights, environmental impact and corporate governance, protecting the interests of Novabase shareholders and those of other stakeholders, providing access to clear information about how risks and opportunities are managed with respect to Group business.

The table below lists key information relating to sustainability due diligence as conducted by Novabase:

Novabase Group is subject to normal market risk and the specific risk that underlies its business. Novabase believes that risk management policy is crucial to conducting and developing a business that historically has exhibited higher risk appetite, keeping in mind how intrinsically necessary it is in such a dynamic and disruptive sector.

Novabase also employs internal control procedures and systems that are used to prevent and manage risk within its organization and activities.

Additional information regarding internal control and risk management at Novabase can be found in Part I, Letter C., Section III. 'Internal Control and Risk Management' of the Corporate Governance Report for the year 2024.

Information regarding the business activity and organization of Novabase Group is available for consultation in the 2024 Annual Report and Accounts (Notes to the Consolidated Financial Statements for the Year ended 31 December 2024), along with the Corporate Governance Report for the 2024 financial year (Part I, Section B., Point 21).

The business model is described in Part I Letter B., Section II. 'ADMINISTRATION AND SUPERVISION (Board of Directors, Executive Board of Directors and the General and Supervisory Board)' of the Corporate Governance Report for the 2024 financial year.

The first year in which Novabase Group undertook its double materiality analysis was 2024. Considering the complexity of the ESRS principles regarding double materiality and the assessment requirements, the Group decided to limit the number and groups of stakeholders involved in the assessment of our impacts, risks and opportunities relating to sustainability exclusively within the company itself, namely internal specialists and executive and non-executive members of the Board of Directors.

Collection of the responses allowed the most significant impacts to be identified, as well as any possible risks and opportunities associated with the company's activities, as explained in further detail below, 'Material impacts, risks and opportunities and their interaction with strategy and business model'.

Taking into account the business model and the double materiality assessment of 2024 undertaken by Novabase Group, the following ESRS topics were identified as non-material and were therefore excluded from this Sustainability Statement: ESRS E2 – Pollution; ESRS E3 – Water and Marine Resources; ESRS E4 – Biodiversity and Ecosystems; ESRS E5 – Resource use and circular economy.

As regards ESRS E1 – Climate Change, potential risks, impacts and opportunities related to climate were analysed and it was concluded that the Group business model is exposed to a low direct level of climate risks, impacts and opportunities, and in 2024 it was not considered material. However, and given the importance of the topic to Novabase, the risks, impacts and opportunities related to climate change combined with the increase in regulations, clients' increasing demands for sustainable services and trends in digital infrastructures, may make the topic material.

For the double materiality exercise conducted in 2024 and considering the aforementioned complexity of the ESRS principles and the assessment requirements, along with the more specific involvement of the stakeholders in this first exercise, the assessment of impacts, risks and opportunities (IROs) for the topics ESRS S2 – Workers in the value chain and ESRS S3 – Affected communities, were considered to be non-material. However, the Group is continuing to pursue the actions and policies it has already implemented in the past and which are aligned with these topics, as further described below in the sub-chapter 'Social'.

The table below lists a summary of the impacts, risks and opportunities related to sustainability which Novabase identified as being material during the double materiality assessment process conducted in 2024. For the year under review, IROs were identified as being material whenever materiality and/or financial impact were at least 2.5 on a scale of 1 to 5. For each topic assessed as being material, sub-topics with which the identified IROs are related are specified, also specifying, in the case of impacts, whether they are positive/negative and real/potential. In all cases and as described in the following chapters, the indicated IROs, although material, are considered manageable and monitored by company management and are not considered to be a source of concern.

In the Value Chain classification, the IROs identified as material in the table below refer to Own Operations of Novabase Group for ESRS S1 and Own Operations and Downstream for ESRS S4. For all material IROs identified the time frame is short and medium term.

The results of the materiality assessment were presented and approved by the Novabase Group Board of Directors.

In the coming financial years Novabase will continue to improve its double materiality process, persistently monitoring the identified material IROs and the company shall remain aligned with the best European practices for sustainability reporting.

Double Materiality is a core concept of the CSRD

When taking into account both financial materiality, which analyses how environmental, social and governance (ESG) factors can affect Novabase's financial position, and impact materiality, which focuses on the effects of Novabase activities on the environment and society, double materiality ensures that all relevant aspects of sustainability are duly reported and managed.

As such, Novabase has undertaken an internal analysis to identify Impacts, Risks and Opportunities (IROs) that will be assessed on the basis of double materiality.

Methodology

In 2024 Novabase undertook its first double materiality analysis in line with the guidelines laid out in the Corrigendum to Commission Delegated Regulation (EU) 2023/2772 of 31 July 2023 (supplementing Directive 2013/34/EU of the European Parliament and of the Council as regards sustainability reporting standards), as well as the Group's interpretation of the standards.

With the aim of obtaining a clear vision of the economic, strategic and sustainability dynamics of Novabase Group, the company was analysed in detail. Accordingly, the analysis began with an assessment of the impact (from the inside out) of the effects of Novabase operation on the environment and society, followed by a financial assessment (from the outside in), where the focus was on external trends pertaining to topics related to Sustainability and how they impact or can impact Group business.

The impact assessment took into account both positive and negative impacts, considering both real and potential ones as regards Sustainability. As regards financial assessment, potential risks and opportunities associated with Sustainability were assessed. With respect to financial assessment, potential risks and opportunities associated with Sustainability that could have a positive or negative impact on the company business were assessed.

As such, various aspects essential to the better understanding of the structure and operation of the Group were covered, including the business model, its regulatory and legal framework, identification of client, partner and supplier segments, the mapping of financial flows, characterization of the main operating activities and identification of the main stakeholders that are affected or potentially affected – positively or negatively – by Novabase operations.

On the basis of the initial assessment, a structured list of impacts, risks and opportunities (IROs) was drafted, which served as the basis for subsequent assessment of material topics.

The IROs and topics are in accordance with the ESRS standards, ensuring compliance with the regulatory requirements and ensuring transparent reporting that complies with the best European sustainability practices.

Impact Materiality

According to ESRS, a sustainability issue is material from the point of view of impact when it pertains to real or potential material impacts, positive or negative, of the company on the people or on the environment within short, medium and long time frames. Impacts include those related to operations and the value chain upstream and downstream from the company, namely via its products and services, along with its commercial relations.

In accordance with ESRS guidelines, three parameters were used to score the Severity of our real impacts:

• Scale: how severe is the negative impact or up to what point is the positive impact beneficial to people or to the environment;

• Scope: how disseminated are negative or positive impacts. In the case of environmental impacts, the scope can be understood to be the extension of the environmental damage or a geographic perimeter. In the event of an impact on people, the scope can be understood to be the number of people that are negatively affected;

• Irreparable character of the impact: if and the extent to which the negative impacts can be corrected, i.e. return the environment or the affected persons to their previous state.

The severity of real negative impacts was determined on the basis of equal weighting of the three aforementioned parameters, while for real positive impacts the severity resulted from the same score only among the parameters Scale and Scope.

For potential impacts (positive and negative) an additional parameter was included:

• Probability: This is a measure of the expectation of the occurrence of an impact, which ranges from rare events to highly probable occurrences.

For potential positive and negative impacts, the Severity and Probability were weighted equally. In the case of potential negative impacts on Human Rights, the Severity of the impact supersedes the Probability of its occurrence.

The classification of the materiality of the impact varies between 1 (very low) and 5 (very high).

Financial Materiality

According to ESRS, a sustainability issue is material from a financial point of view if it triggers or is likely to trigger material financial effects on the company. Identification of risks (negative contribution) and opportunities (positive contribution) that affect or may potentially affect Novabase Group financial performance in the short, medium or long term was the starting point for analysing financial materiality, the existence of dependencies on natural and social resources having been considered sources of risks or financial opportunities, where dependencies can:

• influence the company's capacity to continue to use or obtain the resources necessary for its processes, as well as the quality and establishment of the prices of those resources;

• affect the company's capacity to trust in the relationships that are necessary for their business processes under acceptable conditions.

Having identified the risks and opportunities, Novabase determined which of them are material for the purposes of communicating information in accordance with ESRS. The classification was based on a combination of the following:

i. Probability of occurrence, which is defined as the measure of expectation that a financial impact will occur, ranging from rare events to highly probable events;

ii. Potential size of the financial effects that are determined on the basis of suitable thresholds, the company having broken it down into the following parameters:

a. Financial position: impact on the company's financial situation and/or performance, including cash flow, based on the amount of costs, sanctions and or lost profits in terms of the company's EBITDA;

b. Continuity of the business: the dependencies were assessed by taking into account the interruption of critical commercial processes in terms of number of days and may have an impact in at least two forms:

• They can affect the capacity of the entity to continue to use or obtain the resources necessary to their business processes, as well as the quality and price of those resources;

• They can affect the company's capacity to continue to trust in the relationships necessary to their processes under acceptable terms;

c. Access to financing: impact on Novabase's capacity to obtain capital from investors, banks or other financial institutions, and the cost to the company in obtaining that capital;

d. Reputation: impact on the company's reputation and on the perception of its market value on the part of its various stakeholders;

e. Human capital: impact on performance, relationship and commitment of the employees to the organization, namely with respect to retention and rotation, as well as in terms of reputation and attraction of talents and competencies.

Similar to the classification of impact materiality, the magnitude of financial materiality varies between 1 (very low) and 5 (very high).

Working conditions

Novabase's activity and the conduct of its employees is governed by legislation applicable in the relevant jurisdictions and by the Novabase Code of Conduct (published on the corporate website), a document that has been approved internally and which has been implemented at the Group since 2011 with the aim of guiding the conduct of Novabase professionals in accordance with the values cultivated by the Group, not only in its relationships with clients, but also the principles and rules that, broadly speaking, govern Novabase's relationships with its other stakeholders.

The Code of Conduct covers topics that range from integrity, transparency, respect, health and safety, information use, intellectual property, use of resources, social and environmental responsibility to managing conflicts of interest, corruption and bribery, including also human rights and application of these principle to the hiring of third parties.

Our ethical concerns extend to our suppliers and partners. The principles and rules described in the Novabase Code of Conduct are to be strictly complied with by each Partner or Supplier who works with Novabase and who is incorporated into its daily processes. Novabase includes a commitment of compliance with the Novabase Code of Conduct in its contracts with suppliers.

Novabase is committed to offering a safe and healthy work environment in accordance with local and international health and safety standards. The company's activity is managed in accordance with the Integrated Management System and Novabase companies are audited by its financial auditors and its certifications of Quality (ISO 9001), Environmental Management (ISO 14001) and Occupational Health and Safety (ISO 45001) are renewed annually after internal and external audits, the latter conducted by the certifier entities.

The Novabase Group Human Rights Policy reinforces its commitment to internationally recognized human rights principles. It is applicable to all employees, partners, suppliers and all other Novabase Group stakeholders, and it is in line with the company's values and legal standards in all the locations where the company operates.

Novabase ensures that all its labour practices, including remuneration, working hours, and benefits, comply with local and international legislation wherever the company operates.

Gender equality and equal pay for equal work

Novabase continued to make diversity, equality and inclusion an integral part of its global strategy. We believe in equal opportunity and in mutual respect, regardless of ethnicity, gender, religion, ideology, social origin or sexual orientation. These differences that make us who we are, along with a multiplicity of points of view, tend to improve the quality of decision-making processes, contributing to greater intellectual and cultural enrichment, not to mention a better representation of reality and of those involved in it.

The company incorporates management of diversity, equality and inclusion as an integral part of its global strategy, maintaining these values across all talent management processes at our organization. This commitment applies to all companies that are part of the Group and to all the operating locations.

The Group also believes in the need to increase awareness with regard to policies for integrating women and eliminating obstacles that stand in the way of equal opportunity and non-discrimination on the basis of sex, gender and identity. Professional growth should be valued in terms of the competences, capacities and knowledge of our people, regardless of their sex, gender and identity.

We believe that the diversity of our governing bodies contributes to better performance and greater competitiveness at Novabase. We are thus committed to promoting the following policy:

• Comply with Portuguese Law no. 62/2017 of 1 August because gender diversity leads to different management styles and complementary approaches;

• As regards age, we favour a balance that includes experience and maturity on the one hand, and youth and energy on the other, as a means of ensuring dynamism and keeping up with the fast-paced innovation our sector (information technology);

• In terms of academic qualifications and skills, in addition to those involving technology, several areas of knowledge should be present, given the growing importance of multi-disciplinarity in team performance.

The IT sector continues to be dominated by men. At Novabase Group this indicator has remained stable over the past years. In 2024 the breakdown of men and women remained at 68% and 32%, respectively. These numbers have trended favourably over the years, thus confirming the efficacy of our policies and actions.

As regards remuneration practices, Novabase actively promotes a culture of equity, whether it is in terms of hiring, using comparative market studies, or whether it is in terms of internal policies, using performance and recognition assessment tools, analysing individual and collective contributions as differentiating factors.

Novabase has submitted a new version of its Gender Equality and Diversity Plan, whereby it has identified the measures and practices implemented in 2024 and defined the measures and practices to be developed in 2024/2025.

Training and developing of competences

Novabase sees the training of its employees as a fundamental aspect of development and competitiveness in the current labour market. The Learning Path applies to all employees and consists of a training program that includes various courses that they can complete freely or sequentially, depending on their needs.

In 2024, the training offered with regard to diversity increased, becoming essential to maintaining an environment that is inclusive and respectful of differences, with courses such as Preventing Unconscious Bias, Understanding (dis)ability and taking steps forward, ESG Wake up Call, or Cultural Awareness at Middle East.

The favourable trend in this indicator aligns with the commitment that Novabase Group made in 2023 with regard to ODS 10 ('Reducing Inequality'), strengthening Novabase's commitment to developing practices and policies that promote diversity, equality and inclusion in the workplace, as further described below.

Working Conditions

Novabase has implemented a series of measures that seek to establish well-being and a balance between the professional, family and personal life of its employees.

Some actions that took place in 2024: General Practice Medical Consultations and Psychology Consultations free of charge, with the aim of helping everyone who needs these services, with a guarantee of individual privacy. Other events included a healthy breakfast in partnership with 'Celeiro', chair massage sessions and a webinar on mental health.

Novabase ensures and has its own principles and policies that relate specifically to (i) respect for human rights, (ii) collective bargaining and (iii) guaranteeing the absence of child or forced/obligatory labour. More specifically, the Group has implemented training programs for all employees regarding topics such as equality, diversity, and prevention of harassment. Novabase also has anonymous reporting channels available, as explained in point 'S1-3 — Processes to remediate negative impacts and channels for own works to raise concerns'.

In terms of the value chain, Novabase has implemented a process that defines the rules that are to be followed by suppliers when a supply of services contract is signed and executed between them and Novabase, as explained in point 'ESRS G1-2 – Management of relationships with suppliers'.

The Celfocus Employee Net Promoter Score (e-NPS) offers fundamental insights into the commitment and well-being of employees, and into aspects that are crucial to the sustainability of Novabase business. The score fell to 20 in 2024, after being at 23 in 2023. Although this was a slight drop, it continues to reflect the strong work culture that we have built together. Our commitment remains firm with respect to fostering an all-encompassing and supportive environment, working constantly to improve employee experience and encouraging future improvement.

Gender equality and equal pay for equal work

In view of strengthening Novabase's commitment to developing practices, policies and actions that promote diversity, equality and inclusion in the workplace, in May 2023 we signed the Portuguese Charter for Diversity, an initiative set forth by the Portuguese Association for Diversity and Inclusion in partnership with the High Commission for Migration. In 2024, Novabase Group, through its trademark Celfocus, became a member of the Inclusive Community Forum (ICF).

The Gender Equality, Inclusion and Diversity Plan includes a series of measures based on internal and diagnostic measures that seek to promote equal treatment and opportunity between men and women, eliminating all discrimination related to sex, gender or identity.

With these implemented practices, Novabase remains aligned with all legal and regulatory requirements that apply to its business activity, some of which we have highlighted below:

• Cabinet Resolution no. 20/2112 of 8 March 2012 made it mandatory for all entities of the State corporate sector to adopt an equality plan in view of achieving equal treatment and opportunity between men and women, eliminating discrimination and facilitating reconciliation between personal, family and professional life. This obligation was later extended to publicly traded companies, stipulating in Article 7 that it is mandatory to annually produce equality plans that 'contribute to achieving effective equality of treatment and opportunities between men and women, promoting and eliminating discrimination on the basis of sex and fostering reconciliation between personal, family and professional life';

• Portuguese Law no. 62/2017 also stipulates in Article 5, no. 1 that with regard to publicly traded companies, quotas representing both genders are to be 20% as of the first elective general meeting that takes place after 1 January 2018, and 33.3% as of the first elective general meeting that takes place after 1 January 2020, with respect to all the directors (executive and non-executive) that are part of the administrative bodies;

• The Labour Code, Sub-section III and Sub-section IV – Articles 23 to 65, which addresses the topic of gender equality, namely through general positions regarding equality and non-discrimination, prohibition of harassment, equality and non-discrimination on the basis of sex and parenthood;

• Through Portuguese Law no. 60/2018 of 21 August, the Assembly of the Portuguese Republic approved measures to promote wage equality between women and men for work that is equal or of equal value, using four types of information, assessment and correction mechanisms, having come into force on 21 February 2019.

Novabase follows up on the implementation of all policies and actions, in accordance with its governing model, revising it whenever it deems appropriate..

Training and development of competences

Novabase continues to implement the Second Life Program for equipment reaching the end of its professional life, directed at Novabase Group employees, the latter being able to use the equipment within a family context and thus help reduce digital inequality. In 2024, 120 computers and 15 monitors were sold.

We witnessed a positive trend with regard to volunteer hours in 2024. Through the program 'Acting with a purpose' Novabase has shown its commitment to noble causes and to promoting positive social change, reinforcing its dedication to sustainability and social well-being.

We also highlight participation in the following charitable initiatives:

• We strengthened our commitment to environmental responsibility, contributing to the recycling of electrical equipment and toners. Having collected 744 kg via HappyGreen, we continued to support initiatives that promote sustainability and re-using of resources. This effort reflects our dedication to a more sustainable future, thereby helping to preserve the environment.

• As part of the Papel por Alimentos (Paper for Food) campaign, 2354 kg of paper was donated to the Food Bank. This initiative constitutes not only a significant environmental contribution by promoting recycling and reducing waste, but also has a positive social impact, given that the paper that is collected will be converted into food to help families in need. This gesture is part of our commitment to sustainability and solidarity.

• Nespresso issued a certificate proving the delivery of 477 kg of Nespresso capsules for recycling during the year.

We highlight the following for 2025:

• Participation in the Technovation Girls Program with mentorship of young female students as part of the development of social sustainability projects;

• Development of training programs regarding ESG, construction of inclusive environments and prevention of unconscious biases or understanding of deficiency;

• Promotion and monitoring of use of inclusive language in all means of internal and external communication;

• Using language that is inclusive and non-discriminatory with regard to gender or any other factors when writing job offers;

• Establishment of a partnership with Eurofirms, an employment agency for disabled persons, and sponsorship of training at Code for All for a person with disability;

• Access to the PWN Lisbon – Professional Women's Network, namely 'breakfasts with role models' and training programs/workshops involving individual development of women with high potential at an initial and intermediary level of their careers;

• Launch, analysis and disclosure of Celfocus People Survey to everyone, along with a survey specifically targeting the perception of diversity and inclusion in the work environment;

• Participation in programs and initiatives with external entities, such as PWIT – Portuguese Women in Tech;

• Initiatives for sharing knowledge and/or discussion forums regarding inclusive work practices and with a focus on mental health.

Through these measures, Novabase seeks to mitigate the main risks associated with its sector of activity, which includes a high degree of talent rotation, which can hinder the capacity for innovation and growth, as well as retaining highly specialized professionals in a competitive market. Diversity and inclusion are fundamental challenges, given that the absence of effective policies can result in less collaborative and innovative work environments.

Pursuant to Portuguese Law no. 93/2021of 20 December and the Recommendations of the Portuguese Institute for Corporate Governance regarding the governance of publicly traded companies and taking into account the fostering of a responsible and compliant culture, Novabase has adopted a system for reporting irregular practices (known as SPI) that may occur within the Group.

Since 2019, Novabase Group has implemented a specific procedure regarding conduct in the event of workplace harassment, which is considered unacceptable by Novabase.

The company's own labour force is an essential of Novabase operations. As such, various indicators are monitored in order to limit any negative impacts, manage risks and take advantage of opportunities.

With regard to the social pillar, 2024 saw an overall upward trend for the target indicators established by Novabase in 2023, for the short, medium and long term:

For 2025, the company will continue to strengthen this progress, consolidating the achieved results and spurring on new initiatives aligned with its strategic objectives.

In 2024 no specific targets have yet been set. The Group continues to assess its initiatives and respective results, taking into account the policies implemented at Novabase.

Number of employees according to gender

The IT sector continues to be dominated by men. At Novabase Group this indicator has remained stable over the past years. In 2024 the breakdown of men and women has remained at 68% and 32%, respectively. These numbers have trended positively in recent years, confirming the efficacy of the policies and actions that have been implemented.

Breakdown according to age

[Age breakdown chart showing distribution across age ranges]

Rotation of the talent force

The rotation ttm of Novabase Group fell to 10.6% (11.5% in 2023), in line with a downward trend that has been taking place since 2022, due to the proactive management of our talent and changes in the backdrop of the market.

Percentage by gender

In 2024 the breakdown of men and women remained at 68% and 32%, respectively. These numbers have trended positively over the past years, confirming the efficacy of the policies and actions implemented.

Breakdown of Women/Men per career level

[Chart showing gender breakdown by career level]

Novabase deeply values the continuing vocational training of its employees, recognizing it as a cornerstone for individual growth, innovation and the company's competitiveness in the current demanding labour market. Investing in the development of technical and behavioural competences not only helps to keep up with technological change and sector trends, but also helps to put internal talent to good use, promoting a constant culture of learning and excellence.

In 2024 the average number of training hours per employee was 31 and it involved a greater percentage of employees.

Work accidents

The work environment at Novabase Group is not characterized by frequent work injuries, given that the nature of its activities does not require significant physical exertion by its employees or service suppliers.

In 2024 the number of work accidents with and without sick leave included the categories of Client Facilities/Travel and Office/Home-Work, 5 accidents having been registered.

Absenteeism rate

In 2024 the absenteeism rate for medical consultations was 1.32%, falling below the set target of 2.81%. This result denotes good management and follow-up of occupational medicine.

As regards remuneration practices, Novabase actively promotes a culture of equity, whether it is in terms of hiring, using comparative market studies, or whether it is in terms of internal policies, using performance and recognition assessment tools, analysing individual and collective contributions as differentiating factors. In 2024, there are still salary gaps at some career levels.

Additional information regarding remuneration may be consulted in the Novabase Board of Directors Report regarding remuneration.

All incidents and complaints are processed via the proper channels that are in place for such purposes within the Group. In 2024 no serious incidents or complaints regarding disrespect for human rights were registered.

Novabase Group adopts a structured approach in order to ensure protection of consumers and end-users, guaranteeing security, accessibility and the quality of the digital services rendered by Novabase. The Group has implemented wide-reaching policies regarding data ethics, privacy, cybersecurity, and business continuity, as proven by the certifications ISO/IEC 27001 (Information Security), ISO/IEC 27701 (Private Information) and ISO 22301 (Business Continuity).

In addition to the implemented policies, continuing vocational training and adoption of rigorous guidelines for developing and managing systems serve to reinforce Novabase's commitment to earning the trust and satisfaction of its consumers and end-users.

The company regularly monitors the satisfaction of its clients and that of its staff in relation to internal services and other topics of interest to management. These satisfaction surveys serve to collect feedback regarding the user experience, perceived risks and the potential impacts of the services rendered by the company.

Collection of feedback through client surveys is considered a first step toward correcting the negative impacts associated with the services rendered. After analysing the severity, Novabase implements the corrective measures appropriate to each situation.

Novabase has implemented a pro-active approach for mitigating risks and maximizing opportunities associated with the services it provides. In order to reduce negative impacts, the Group has adopted rigorous privacy and security policies, ensuring data protection and compliance with regulations via internal and external audits, the latter conducted by certifier entities.

No specific targets have been set for 2024 as of yet. The Group continues to assess its initiatives and respective results, taking into account the policies implemented at Novabase.

Novabase Group, as a company working within the information technologies sector, is guided by solid ethical principles based on integrity, transparency and corporate responsibility.

All Group policies incorporate and demand a high standard of environmental, social and ethical conduct founded on policies, codes and practices that are recognized by the market and aligned with legislation applicable where the company is present.

The Board of Directors annually reviews the policies that are in effect and they are adjusted if need be.

Cabinet Resolution no. 37/2021 of 6 April approved the National Anti-Corruption Strategy 2020-2024, which calls on all the sectors, including the private business sector, to take part in the collective effort to prevent corruption, focused essentially on preventing corruptive phenomena.

According to this strategy, businesses must accept the central nature of their role in promoting and defending ethics in the relationships between the public and private sectors and in the commercial relationships within the private sector, where corruption also takes place.

Adoption and implementation of compliance programs by businesses has been considered a path toward greater engagement by the private sector in combatting corruption and preventing practices that run counter to company standards, that go against the company or use the company by not adopting such programs.

In accordance with the General Corruption Prevention Regime, Novabase has adopted and implemented a Standards Compliance Program in order to prevent, detect and penalize acts of corruption and related offences that are committed against or via the entity. This regime includes:

i. Plan for the Prevention of Risks of Corruption and Related Offences; ii. Code of Conduct; iii. Training Program; and iv. Reporting Channel.

i. Plan for the Prevention of Risks of Corruption and Related Offences

Novabase, aware of the risks, even if they are only potential, has used the Plan for the Prevention of Risks of Corruption and Related Offences to identify them within the specific eco-system where Novabase operates and address them by implementing a business culture that is based on core values of legality, loyalty, trust and ethics. Novabase approved the plan in 2021 and published it on the website.

ii. Code of Conduct

The Code of Conduct describes the behaviours, principles and values that everyone should adopt when performing their professional duties, namely: acting with integrity, adopting ethical and correct behaviour, repudiating all acts of corruption or related offences, taking informed decisions and complying with legal and regulatory obligations.

The Code of Conduct is directed at everyone who works with or for Novabase, namely employees, subcontracted persons, suppliers and partners.

Novabase has implemented a process throughout the Group with the aim of ensur