Upholding Integrity, Accountability, and Excellence at Top Way

Why Corporate Compliance Matters

Top Way’s reputation as a trusted and principled organization has been built over time through consistent ethical conduct, sound decision-making, and a strong commitment to corporate responsibility. This legacy can be undermined in an instant by the misconduct of even a single individual. For this reason, our commitment to ethical business practices is not optional — it is foundational.

The Corporate Compliance Policy sets the expectations for all employees, executives, consultants, and business partners acting on behalf of Top Way. It provides a clear framework that helps safeguard our integrity, ensure lawful conduct, and promote a culture of transparency and accountability across all levels of the organization.

This policy does not attempt to anticipate every scenario, nor does it replace country-specific laws or industry regulations. In cases where local legal requirements impose stricter obligations, those higher standards shall prevail.

Potential Consequences of Non-Compliance

Unethical or unlawful behavior can expose Top Way to serious consequences, including but not limited to:

• Criminal prosecution and penalties

• Regulatory fines and sanctions

• Civil litigation and compensatory damages

• Exclusion from government or commercial tenders

• Loss of business partnerships and reputational damage

• Adverse market or investor perception

Additionally, employees involved in violations may face disciplinary actions, including suspension, dismissal, civil liability, or criminal charges.

No action taken in violation of this policy can be justified as being “in the company’s interest.” Any perceived short-term benefit is outweighed by the long-term harm to Top Way’s reputation and operations.

Top Way competes in the marketplace based on innovation, value, and integrity — never through compromise or questionable conduct. Employees who refuse unethical requests will be fully supported, and no retaliation will be tolerated.

A Practical Guide for Ethical Conduct

Operating in diverse, fast-paced environments means our employees may encounter varying standards, expectations, or unclear situations. This policy is designed to serve as a practical reference in daily business decisions and should be read in conjunction with local laws and departmental protocols. Employees should always seek clarity from management, the Compliance Team, or Legal Affairs in case of uncertainty.

Top Way’s Principles of Business Conduct

1. We Commit to Fair Competition – No Antitrust Violations
   Engaging in anti-competitive behavior, such as price fixing or market manipulation, is prohibited. Top Way maintains zero tolerance for actions that breach competition laws.

2. We Conduct Business with Integrity – No Corruption
   We prohibit any form of bribery, kickbacks, or undue influence. Employees must never offer, solicit, or accept anything of value intended to improperly influence a business decision.

3. We Prioritize Health, Safety, and Environmental Responsibility
   Top Way is committed to operating sustainably and lawfully. No employee may take actions that endanger public health, the environment, or workplace safety.

4. We Promote Respect and Equal Opportunity – No Discrimination
   Discrimination or harassment based on race, gender, age, religion, disability, or any protected status is strictly prohibited. Our culture is one of inclusivity, dignity, and professionalism.

5. We Maintain Clear Boundaries Between Personal and Professional Interests
   Employees must avoid conflicts of interest. Outside activities or relationships that could impair judgment or influence company decisions must be disclosed and managed appropriately.

Employee Responsibilities Under This Policy

This policy applies to all employees, officers, and representatives of Top Way. Compliance is not optional — it is a fundamental condition of employment. All personnel are expected to:

• Understand and adhere to this policy and all applicable laws

• Proactively identify and avoid potential compliance risks

• Seek guidance when unclear about a situation

• Report any known or suspected violations without delay

Top Way offers confidential and anonymous channels for reporting compliance concerns. Retaliation against individuals who report in good faith is strictly prohibited.

If an employee is involved in a potential violation but voluntarily discloses it and assists in an investigation, this cooperation may be considered when determining consequences.

Compliance Oversight and Governance

The Board of Directors of Top Way has appointed a Group Compliance Officer, who reports directly to senior leadership. The Compliance Officer works closely with Legal, Internal Audit, and Risk Management to:

• Monitor adherence to compliance obligations

• Investigate reports of non-compliance

• Recommend training and corrective action

• Promote a culture of ethical conduct throughout the organization

All employees must familiarize themselves with this policy, participate in mandatory training sessions, and review their conduct regularly. Supervisors bear additional responsibility for leading by example and supporting compliance initiatives within their teams.

Corporate compliance is not a box to check — it is a shared commitment to doing what is right, even when no one is watching. By upholding these principles, we protect not only Top Way’s legacy but also our shared future.