At Novar, we conduct our business with integrity, transparency and respect for people and the environment. This page sets out our commitments on ethics, legal compliance and privacy. It also explains how employees, partners and other stakeholders can raise concerns or report suspected misconduct. Together, these principles support responsible decision-making and help us build trust within our organisation and in the wider society in which we operate.
At Novar, ethical conduct is fundamental to how we operate and make decisions. Our commitments are based on the following principles:
Our Code of Ethics forms the foundation of Novar’s corporate culture and applies to all employees, directors, and representatives of Novar. It provides guidance on expected behaviour and ethical decision-making, including:
The Code of Ethics supports a safe environment in which concerns can be raised without fear of retaliation.
You can download the comprehensive Code of Ethics for detailed guidance.
Novar expects high ethical, legal, and sustainability standards throughout its value chain. All EPC (Engineering, Procurement, and Construction) parties are required to sign Novar’s Supplier’s Code of Conduct as a condition for collaboration.
By signing this Code, suppliers commit to:
If a supplier has an equivalent internal code of conduct, it may be submitted to Novar for review. Where full compliance is not yet possible, suppliers are required to provide a corrective action plan.
You can download the comprehensive Supplier’s Code of Conduct for detailed guidance.
Novar encourages employees, former employees, applicants, suppliers, contractors, and other external stakeholders to report concerns or suspected violations of our ethical standards, internal policies, or legal obligations.
All reports are handled confidentially and investigated thoroughly and promptly, in accordance with the Dutch Whistleblower Protection Act (Wet bescherming klokkenluiders).
Reports may relate to, for example:
Internal reporting
Reports are received and assessed by a designated compliance function within Novar. Complaints or disclosures can be submitted by internal and external parties via our Contact page or by email at complaints@novar.nl
Anonymous reporting
It is possible to submit an anonymous complaint or disclosure by omitting personal details such as your name, email address, or telephone number. Please note that anonymity may limit the application of hoor en wederhoor (the right to be heard), which may make a full investigation more difficult.
If anonymity is important, we recommend creating a separate anonymous email account for submitting your report. Novar does not trace IP addresses when reports are submitted via email or through the contact page.
External reporting
You are not required to report internally first. If you prefer, or if internal reporting is not appropriate, you may also report concerns to an external authority, such as Huis voor Klokkenluiders – https://www.huisvoorklokkenluiders.nl
Novar strictly prohibits any form of retaliation against individuals who report concerns in good faith. This includes, but is not limited to, dismissal, demotion, intimidation, or any other form of disadvantage.
In line with Dutch law, if a reporter experiences disadvantage after making a report, the burden of proof lies with the employer to demonstrate that such disadvantage is unrelated to the report.
All reports are handled with due care for privacy and confidentiality. The identity of the reporter is protected and shared only where strictly necessary and permitted by law. Personal data is processed in accordance with the Algemene Verordening Gegevensbescherming (AVG).
