Code of Business Conduct and Ethics

Purpose

This Code is designed to:

• • Promote honest and ethical conduct, including fair dealing and ethical handling of conflicts of interest
• • Promote full, fair, accurate, timely, and understandable disclosure in reports and documents filed with regulatory authorities
• • Promote compliance with applicable governmental laws, rules, and regulations
• • Protect the Company's legitimate business interests, including confidential information and assets
• • Deter wrongdoing and promote accountability for adherence to the Code
• • Provide guidance for recognizing and resolving ethical issues

Applicability

All directors, officers, employees, contractors, and agents are required to read, understand, and comply with this Code. Violations of this Code may result in disciplinary action, up to and including termination of employment or service, and may also result in civil or criminal liability.

Equal Opportunity and Non-Discrimination

NDB is committed to providing equal employment opportunities and maintaining a workplace free from discrimination and harassment. We do not tolerate discrimination based on:

• • Race, color, or national origin
• • Religion or religious beliefs
• • Sex, gender identity, or sexual orientation
• • Age or disability
• • Veteran or military status
• • Genetic information
• • Any other characteristic protected by applicable law

Harassment-Free Workplace

NDB prohibits all forms of harassment, including:

• • Sexual harassment, including unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature
• • Harassment based on any protected characteristic
• • Bullying, intimidation, or abusive conduct
• • Retaliation against individuals who report harassment or participate in investigations

Health and Safety

We are committed to providing a safe and healthy work environment. All employees must:

• • Follow all safety policies, procedures, and regulations
• • Report unsafe conditions or practices immediately
• • Refrain from working under the influence of alcohol or illegal drugs
• • Comply with all nuclear safety and radiation protection requirements
• • Participate in required safety training programs

Respectful Communication

All employees are expected to communicate professionally and respectfully with colleagues, customers, suppliers, and other stakeholders. Profanity, derogatory comments, and disrespectful behavior are not acceptable.

Common Conflicts of Interest

Outside Employment and Business Activities

• • Employees may not engage in outside employment or business activities that compete with the Company
• • Outside activities must not interfere with job performance or Company responsibilities
• • Employees must disclose outside employment that may create a conflict of interest

Financial Interests

• • Employees may not have significant financial interests in competitors, customers, or suppliers
• • Directors and officers must disclose all financial interests that may create conflicts
• • Family members' financial interests may also create conflicts that must be disclosed

Related Party Transactions

• • Transactions with family members or entities in which employees have an interest must be disclosed
• • All related party transactions must be approved by the Audit Committee
• • Transactions must be on terms no less favorable to the Company than could be obtained from unrelated parties

Corporate Opportunities

• • Employees may not take personal advantage of opportunities discovered through Company resources or position
• • Business opportunities related to the Company's business must be disclosed to the Company
• • Employees may not compete with the Company for business opportunities

Gifts and Entertainment

• • Employees may not accept gifts, entertainment, or other benefits that could influence business decisions
• • Nominal gifts of minimal value (under $100) may be accepted if they do not create an obligation
• • All gifts and entertainment must be disclosed if they exceed nominal value
• • Cash or cash equivalents may never be accepted

Disclosure and Approval

Any potential conflict of interest must be promptly disclosed in writing to:

• • Employees: Your immediate supervisor and the Legal Department
• • Officers: The Chief Executive Officer and the Audit Committee
• • Directors: The Board of Directors through the Nominating and Governance Committee

Confidential Information

Employees have access to confidential and proprietary information that is critical to the Company's success. This information must be protected and may include:

• • Trade secrets and proprietary technology
• • Research and development information
• • Business strategies and plans
• • Financial information and projections
• • Customer and supplier information
• • Employee personal information
• • Nuclear technology and safety information

Obligations

All employees must:

• • Maintain confidentiality of all proprietary information during and after employment
• • Use confidential information only for legitimate business purposes
• • Not disclose confidential information to unauthorized persons
• • Protect confidential information from unauthorized access or disclosure
• • Return all confidential information upon termination of employment
• • Comply with all confidentiality and non-disclosure agreements

Intellectual Property

All inventions, discoveries, and creative works developed using Company resources or related to the Company's business belong to the Company. Employees must:

• • Promptly disclose all inventions and discoveries to the Company
• • Assign all rights to inventions and intellectual property to the Company
• • Cooperate in obtaining patents, copyrights, and other protections
• • Respect intellectual property rights of others

Data Security and Privacy

NDB is committed to protecting personal data and complying with data protection laws. Employees must:

• • Follow all information security policies and procedures
• • Use strong passwords and protect login credentials
• • Report security incidents or data breaches immediately
• • Comply with GDPR, CCPA, and other data protection regulations
• • Only collect and use personal data for legitimate business purposes

Nuclear Regulatory Compliance

As a nuclear technology company, NDB is subject to extensive regulatory oversight. All employees must:

• • Comply with all Nuclear Regulatory Commission (NRC) requirements
• • Follow radiation safety and protection procedures
• • Maintain accurate records required by nuclear regulations
• • Report any nuclear safety concerns immediately
• • Participate in required nuclear safety training

Securities Laws and Insider Trading

NDB is committed to compliance with securities laws. Employees must:

• • Not trade Company securities while in possession of material non-public information
• • Not tip others or recommend trading based on inside information
• • Comply with the Company's Insider Trading Policy
• • Obtain pre-clearance for trades as required by Company policy
• • Report all securities transactions as required

See the Company's Insider Trading Policy for detailed requirements.

Anti-Corruption and Bribery

NDB prohibits bribery, corruption, and improper payments. Employees must:

• • Not offer, promise, or provide anything of value to government officials to obtain business advantages
• • Comply with the Foreign Corrupt Practices Act (FCPA) and UK Bribery Act
• • Not make facilitation payments or "grease payments"
• • Conduct due diligence on third-party agents and intermediaries
• • Maintain accurate books and records of all transactions

Export Controls and Trade Compliance

NDB's nuclear technology is subject to export control laws. Employees must:

• • Comply with U.S. export control laws and regulations
• • Obtain required licenses before exporting controlled technology
• • Screen customers and transactions against restricted party lists
• • Not share controlled technical data with foreign nationals without authorization
• • Comply with economic sanctions and embargoes

Antitrust and Competition

NDB is committed to fair competition. Employees must:

• • Not engage in price fixing, bid rigging, or market allocation with competitors
• • Not share competitively sensitive information with competitors
• • Compete fairly and ethically in the marketplace
• • Comply with antitrust and competition laws in all jurisdictions

Environmental Compliance

NDB is committed to environmental protection. Employees must:

• • Comply with all environmental laws and regulations
• • Follow waste management and disposal procedures
• • Report environmental incidents or violations immediately
• • Support the Company's sustainability initiatives

How to Report

Employees may report concerns through any of the following channels:

Anonymous Reporting

Employees may report concerns anonymously through the Ethics Hotline or online reporting portal. While anonymous reports are accepted, providing contact information helps facilitate investigation and follow-up.

Non-Retaliation Policy

NDB strictly prohibits retaliation against anyone who:

• • Reports suspected violations in good faith
• • Participates in an investigation
• • Refuses to participate in suspected wrongdoing

Retaliation includes adverse employment actions such as termination, demotion, harassment, or discrimination. Any retaliation will result in disciplinary action, up to and including termination.

Investigation Process

All reports will be:

• • Treated seriously and investigated promptly
• • Handled confidentially to the extent possible
• • Investigated by qualified personnel
• • Resolved with appropriate corrective action if violations are confirmed

Consequences of Violations

Violations of this Code may result in:

• • Disciplinary action, up to and including termination of employment
• • Termination of business relationships with contractors or agents
• • Civil or criminal liability
• • Damage to professional reputation
• • Financial penalties or restitution