THE NOVAVAX COMPLIANCE HELPLINE

Novavax is an organization with strong values of responsibility, transparency, and integrity. Our policies and Code of Conduct, contain guidelines for complying with applicable laws and regulations as well as conducting business with the highest ethical standards.

REPORTING COMPLIANCE VIOLATIONS AND CONCERNS

If you see or suspect any illegal or unethical behavior or policy violation, or you have a question about what to do in a certain situation, you have a responsibility to speak up. Remember, an issue cannot be addressed unless it is brought to someone’s attention. However, you choose to raise your concern, please do not hesitate to use the Compliance Helpline. Our helpline is available 24 hours a day and language translation is available. All calls and reports submitted are handled promptly and discreetly, and Novavax will review and investigate each matter promptly and accordingly. You may call or submit your concern online. You may report your concern anonymously, although it is most helpful for Compliance to be able to communicate freely with you.

The Company shall determine whether violations of this Code have occurred and, if so, shall determine the disciplinary measures to be taken against any employee who has violated this Code. In the event that the alleged violation involves an executive officer or board member the Chief Executive Officer and the Board of Directors, respectively, shall determine whether a violation of this Code has occurred and, if so, shall determine the disciplinary measures to be taken against such officer or director.

Novavax is committed to fostering an environment that is open and transparent and require all our employees to always strive for honest communication. Any report or information that you submit must be made in good faith. This does not mean that you must be certain or correct when you raise a concern, but it does mean that you believe the concern you are raising is legitimate and the information you are providing is accurate.

For general compliance questions or for questions relating to raising a concern, please feel free to contact us at corporatecompliance@novavax.com.

See the EthicsPoint FAQs for more information.