Financial Conflict of Interest (FCOI) Policy

Effective Date: April 2025

Purpose

At NOVABLOC™, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct. This Financial Conflict of Interest (FCOI) Policy is designed to identify, manage, and disclose any financial interests that could directly or indirectly affect, or appear to affect, the objectivity and credibility of our research, development, communications, and decision-making.

Scope

This policy applies to all NOVABLOC™ employees, officers, contractors, consultants, and any collaborators involved in activities that could impact research, regulatory matters, or public disclosures.

Definition of Financial Conflict of Interest

A Financial Conflict of Interest exists when a financial interest could reasonably be expected to influence an individual’s professional judgment or actions on behalf of NOVABLOC™.

Examples of financial interests include (but are not limited to):

  • Ownership of stock, stock options, or other equity interests in entities related to NOVABLOC™ business

  • Receipt of consulting fees, honoraria, or other personal compensation from related entities

  • Intellectual property rights and interests (such as patents or royalties)

Disclosure Requirements

Individuals covered by this policy must disclose any relevant financial interests:

  • At the time of engagement with NOVABLOC™

  • Annually thereafter

  • Within 30 days of acquiring or discovering a new financial interest

All disclosures will be reviewed by NOVABLOC™ leadership to determine whether a conflict exists and to establish any necessary management plans.

Management of Conflicts

If a Financial Conflict of Interest is identified, NOVABLOC™ may take measures including, but not limited to:

  • Requiring disclosure of the conflict in publications or public statements

  • Restricting involvement in certain projects or decisions

  • Divestiture of conflicting financial interests

  • Other actions deemed appropriate to ensure objectivity and integrity

Compliance

Failure to comply with this policy may result in corrective action, up to and including termination of involvement with NOVABLOC™ projects or activities.

Questions

If you have any questions regarding this policy or your obligations under it, please contact <INSERT EMAIL ADDRESS>

NOVABLOC™ remains committed to advancing our mission with the highest level of trust, objectivity, and accountability.