At Top Way, we are committed to conducting our business with the utmost integrity, transparency, and ethical responsibility. Our reputation has been built on trust, and we recognize that maintaining the highest standards of conduct is critical to our continued success. This Anti-Bribery and Corruption Policy outlines Top Way’s position on bribery and corrupt practices, and applies to all employees, directors, consultants, agents, contractors, and third parties representing or acting on behalf of the company across all operations and geographies.

Understanding Bribery and Corruption

Bribery and corruption undermine ethical business practices and compromise fair competition. Bribery involves offering, promising, giving, or accepting anything of value—whether monetary or otherwise—with the intention of improperly influencing an individual’s actions or decisions. Corruption refers more broadly to the abuse of entrusted power for personal or corporate gain.

Bribes may come in many forms, not just direct payments. Gifts, travel, entertainment, hospitality, or favors can constitute bribery if used to influence business outcomes. Even the perception of such influence can damage Top Way’s reputation and stakeholder trust.

Legal and Reputational Risk

In accordance with the laws of the Kurdistan Region and Iraq—as well as international anti-bribery laws—both individuals and organizations found guilty of bribery may face serious legal penalties, including fines, imprisonment, and disqualification from contracts. For Top Way, a breach would also carry significant reputational and financial risks. We maintain zero tolerance for any form of bribery or corrupt behavior within our organization or supply chain.

Top Way’s Commitment

Top Way strictly prohibits:

• The offering, giving, requesting, or receiving of any bribe or corrupt inducement, in any form and for any purpose.

• Engaging in such practices with any individual or organization, whether public or private, domestic or international.

• Any conduct that could improperly influence business decisions, secure unfair advantages, or create a conflict of interest.

This policy applies equally to all employees, management, and third parties working with or on behalf of Top Way. All business activities must be conducted with integrity, in compliance with this policy and all applicable laws.

Guidance and Oversight

Determining whether an action constitutes bribery is not always straightforward. If there is any uncertainty about a business interaction, gift, or request, employees are required to consult their Department Head, the Legal and Compliance Officer, or the Ethics & Integrity Committee. Top Way will investigate any suspected breaches thoroughly and take disciplinary action where warranted, which may include dismissal and legal prosecution.

Your Responsibility

Every employee has a duty to prevent, detect, and report any activity that may involve bribery or corruption. Concerns or suspicions must be raised promptly through the appropriate reporting channels, including the Legal and Compliance Department. Confidentiality and protection from retaliation are assured for all employees acting in good faith.