Top Way Code of Ethics

At Top Way, we believe that long-term business success is rooted in integrity, transparency, and a deep commitment to ethical behavior. Since our founding in 2014, we have built our reputation on principles of trust, fairness, accountability, and mutual respect. These values are not only embedded in our corporate strategy but reflected in our daily decisions, interactions, and operations. This Code of Ethics serves as a guiding framework for every officer, director, employee, partner, and affiliate representing Top Way—across Iraq, the Middle East, and beyond.

We recognize our responsibility to uphold the highest standards of conduct in everything we do. Whether delivering fuel, managing procurement, supplying manpower, or executing major infrastructure projects, we are committed to doing so lawfully, ethically, and professionally. We believe that how we do business is just as important as what we deliver.

1. Personal and Professional Integrity

Top Way expects all personnel to perform their duties with honesty, objectivity, and integrity. Every action we take should reflect our corporate values and protect the trust we’ve earned from our clients, partners, and communities. We do not compromise our principles for short-term gain or under competitive pressure.

Each employee is a representative of our brand. We hold ourselves accountable not only for outcomes but for the way we reach them. Dishonesty, negligence, or any form of misconduct undermines our reputation and our mission—and will not be tolerated.

2. Conflict of Interest

All officers, directors, and employees must avoid situations that present—or could appear to present—a conflict between personal interests and the interests of Top Way. A conflict may arise when personal relationships, financial investments, or external business activities interfere with one’s ability to make objective decisions on behalf of the company.

Employees must not:

• Engage in any business that competes with Top Way without prior written approval.

• Represent Top Way in a transaction involving individuals or organizations with which they have a personal connection.

• Use company resources, information, or opportunities for personal benefit.

It is the responsibility of each team member to disclose any potential conflict of interest to management so that it may be properly reviewed and addressed.

3. Anti-Bribery and Corruption

Top Way maintains a strict zero-tolerance policy on bribery, corruption, and unethical inducements. We do not offer, give, solicit, or accept bribes, kickbacks, or anything of value with the intent of influencing a business decision or gaining an unfair advantage. This applies to dealings with public officials, private companies, contractors, vendors, and third parties.

Offering or accepting gifts, gratuities, or entertainment must be reasonable, transparent, and in line with local customs and legal regulations. Any gift that could compromise—or appear to compromise—professional judgment must be declined.

We strictly adhere to local and international anti-corruption laws and expect our partners, suppliers, and subcontractors to do the same.

4. Confidentiality and Data Protection

Employees, contractors, and affiliates may have access to confidential, proprietary, or sensitive business information in the course of their work. This may include strategic plans, client records, employee data, supplier agreements, pricing structures, or technical specifications.

All such information must be:

• Treated with discretion.

• Stored securely and shared only with authorized individuals on a need-to-know basis.

• Never disclosed to outside parties without proper authorization.

• Never used for personal gain or to benefit another company or entity.

We also respect and protect the privacy of personal information shared with us by clients, partners, and employees, complying fully with applicable data protection regulations.

5. Insider Information and Securities Trading

Employees and directors must not use material, non-public information obtained through their work to trade securities or advise others to do so. This includes information that could impact the value of Top Way, its affiliates, or any business we work with.

Until such information is disclosed publicly, employees must not:

• Share it with anyone outside the company.

• Buy or sell related securities.

• Encourage others to take financial actions based on that information.

Insider trading is illegal and unethical—and violators may be subject to termination, civil penalties, and criminal prosecution under Iraqi and international law.

6. Fair Competition and Business Practices

Top Way believes in fair competition based on quality, reliability, and integrity—not deception or unfair tactics. We do not tolerate:

• The use of false, misleading, or exaggerated statements about our competitors.

• The unauthorized collection or use of competitor trade secrets.

• The misrepresentation of our capabilities, pricing, or contracts.

We respect the competitive landscape and aim to outperform others through performance—not unethical advantage.

7. Reporting and Accountability

Employees are encouraged—and expected—to speak up when they observe behavior that may violate this Code of Ethics. Concerns about illegal, dishonest, or unsafe conduct should be reported to a supervisor, manager, or designated ethics officer without fear of retaliation.

Top Way ensures that:

• All reports are treated confidentially and investigated thoroughly.

• Whistleblowers are protected from any form of reprisal.

• Disciplinary actions are fair and appropriate to the nature of the offense.

Our leadership team is committed to resolving ethical concerns promptly, transparently, and in accordance with company policy and applicable law.

8. Equal Opportunity and Non-Discrimination

Top Way fosters an inclusive, respectful, and diverse workplace. We provide equal opportunities to all individuals—regardless of race, gender, religion, age, disability, or background—and we do not tolerate harassment or discrimination in any form.

We support the professional development of our employees and are committed to building a safe, respectful, and collaborative work environment where everyone can thrive.

9. Health, Safety & Environmental Responsibility

Protecting the health and safety of our team, our partners, and the public is a fundamental priority. We comply with all occupational safety standards and maintain strict protocols for site safety, equipment use, emergency response, and environmental protection.

All employees are expected to:

• Follow safety procedures and use protective equipment.

• Report hazards, incidents, or unsafe behavior immediately.

• Participate in safety training and drills.

• Act responsibly to minimize environmental impact in every operation.

Top Way believes safety and sustainability are not checkboxes—they are core to our identity as a responsible business.

10. Disciplinary Actions and Enforcement

Violations of this Code of Ethics will result in consequences that may include disciplinary action, reassignment, suspension, termination, or legal proceedings. Disciplinary decisions consider the severity of the breach, whether the violator self-reported, and the level of cooperation provided during the investigation.

We expect all employees to:

• Read, understand, and follow this Code.

• Seek guidance when uncertain about ethical decisions.

• Take personal responsibility for maintaining Top Way’s ethical standards.

At Top Way, ethics are not just a policy—they are a culture. We believe that doing the right thing, even when it’s difficult, is the foundation for building trust with our clients, empowering our workforce, and contributing to the region’s progress. Every project we deliver, every partnership we form, and every challenge we solve is an opportunity to lead by example.

We are proud to hold ourselves—and one another—to the highest standards. Because strong ethics aren’t just good business—they’re the Top Way.