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Information regarding Adopted Policies

A. INTRODUCTION | NOVABASE GROUP

Under Article 508-G of the Commercial Companies Code, in accordance with the wording introduced via Decree-Law no. 89/2017 of 28 July, which transposed to Portuguese rule of law Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014, NOVABASE has outlined in the present document sufficient information for comprehending the evolution, performance, position and impact of the group’s activities, at the very least in reference to environmental and social issues, its employees, gender equality, non-discrimination, respect for human rights, preventing corruption and attempted bribery in relation to NOVABASE Group during the financial year ended 31 December 2020.

Information pertaining to NOVABASE Group activity and corporate organization may be consulted in the Annual Report and Accounts 2020 (Notes to the Consolidated Financial Statements for the year ended 31 December 2020), along with the Corporate Governance Report for the financial year 2020 (Part I, Section B., Point 21).

B. BUSINESS MODEL

This information is described in Part I, Letter B., Section II. “ADMINISTRATION AND SUPERVISION (Board of Directors, Executive Board of Directors, and General and Supervisory Board)” of the Corporate Governance Report for the 2020 financial year.

C. MAIN RISK FACTORS

NOVABASE Group is subject to regular market risks and the specific underlying risks of the activities it undertakes. NOVABASE believes that its risk management policy is absolutely essential to running and developing a business that has historically been known for its greater appetite for risk, an intrinsic necessity in such a dynamic and disruptive sector.

NOVABASE also implements procedures and internal control systems used to prevent and manage risk related to its organization and activities.

Additional information regarding internal control and risk management at NOVABASE is available in Part I, Letter C., Section III. “Internal Control and Risk Management” in the Corporate Governance Report for the 2020 financial year.