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ITEM 16B. CODE OF ETHICS

Nuvini has adopted a code of ethics, which is applicable to all of Nuvini’s directors, officers, employees and partners. Nuvini’s code of ethics is publicly available on its investor relations website. Nuvini intends to disclose future amendments to, or waivers of, its code of conduct on the same page of its corporate website. Nuvini’s website address is www.nuvini.co. Information contained on Nuvini’s website is not incorporated by reference into this annual report, and investors should not consider information contained on Nuvini’s website to be part of this Annual Report or in deciding whether to invest in Nuvini Ordinary Shares. A copy of the code of ethics is filed herewith as Exhibit 11.1.

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