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Item 16B. Code of Ethics

The Company has adopted a written code of conduct that applies to all Company employees, including the Company’s directors, principal executive officer, principal financial officer and principal accounting officer.

You may review our code of conduct on our website: https://www.novami.com/, under “Investors/Corporate Governance”. Information contained on, or that can be accessed through, our website does not constitute a part of this Annual Report.

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