Top Way QHSE Policy Statement

At Top Way, we are fully committed to protecting the health, safety, and well-being of our employees, clients, contractors, and the communities in which we operate. Since 2014, our reputation has been built on professionalism, integrity, and a strong culture of safety and responsibility. We aim to achieve excellence in Quality, Health, Safety, and Environmental (QHSE) performance across all operations, including construction, logistics, procurement, manpower supply, and fuel delivery.

We recognize our duty to safeguard—so far as is reasonably practicable—all individuals who may be affected by our activities and services. This includes workers, clients, visitors, the public, and users of our sites and facilities. Our goal is simple: no harm to people, no damage to the environment, and uncompromising quality in everything we do.

Top Way adheres to all relevant local, national, and international legislation, and actively cooperates with enforcing authorities and stakeholders to ensure that all our operations promote a safe, ethical, and environmentally responsible work culture.

Our QHSE Objectives

• Deliver world-class quality services efficiently and safely.

• Eliminate work-related injuries and environmental harm.

• Promote continual improvement in QHSE performance.

• Ensure transparent communication and employee consultation.

• Comply with applicable laws, industry standards, and client expectations.

• Empower every employee and contractor to act responsibly and stop unsafe work.

Our Commitment to Achieving These Goals

Top Way will:

• Implement and Maintain a QHSE Management System
  Aligned with ISO 9001:2015, ISO 45001:2018, and ISO 14001:2015 standards to monitor, improve, and manage risks in our daily operations.

• Comply with Legal and Client Requirements
  We follow all applicable laws, regulations, and contract-specific QHSE standards, and apply responsible practices where legislation is absent.

• Minimize Risk Through Practical Control Measures
  We assess and reduce safety and environmental risks to As Low As Reasonably Practicable (ALARP) levels.

• Promote Ownership of QHSE Across All Levels
  Every employee, supervisor, and contractor is responsible for safe performance on the job. Safety is everyone’s duty.

• Train and Empower Employees
  We provide regular training, tools, and support to ensure all personnel are competent and capable of maintaining high QHSE standards.

• Encourage Safe Behavior
  All staff are encouraged to report hazards, near-misses, and unsafe behavior without fear of retaliation.

• Conduct Regular Drills and Emergency Preparedness Activities
  To ensure readiness and a rapid, effective response to emergencies.

• Continuously Monitor, Audit, and Improve QHSE Systems
  Through internal audits, incident analysis, corrective actions, and performance reviews.

• Engage Stakeholders and Partners
  We work closely with our employees, clients, contractors, and regulators to share responsibility and raise industry standards.

Top Way Employee Training Program

Introduction

Top Way believes that training is essential to achieving operational excellence and protecting our workforce. Our employee training program ensures every staff member—from new hires to senior supervisors—is equipped with the skills, knowledge, and mindset needed to work safely, efficiently, and ethically.

This program also ensures we meet all legal and regulatory requirements across Iraq and the Middle East and comply with best practices in environmental protection, workplace safety, and quality control.

STEP 1: Define Core Training Topics

We categorize our employee training topics into the following core areas:

• Company Overview and Employee Handbook
  (Vision, mission, ethics, and workplace policies)

• Role-Specific Job Requirements
  (Duties, responsibilities, technical requirements)

• QHSE and Safety Training
  (Emergency procedures, hazard communication, PPE)

• Quality Assurance Procedures
  (Standard Operating Procedures, compliance, QA tools)

• Regulatory Compliance
  (Environment, waste management, emissions, ISO standards)

• Employee Development and Certifications
  (Technical skill-building, leadership training, HSE courses)

• Preventive Maintenance and Housekeeping
  (Cleanliness, upkeep of tools/equipment, safety zones)

STEP 2: Develop a New Employee Training Checklist

Upon onboarding, each employee is guided through a structured training process based on their job type and safety risk level. A New Employee Training Checklist outlines:

• Introduction to the company

• Health & safety protocols

• Role expectations and SOPs

• PPE issuance and training

• Emergency contacts and evacuation plans

• Site-specific hazards and reporting structure

For some roles, introductory awareness may suffice. For technical positions or those involving hazardous work, in-depth and certified training is mandatory.

STEP 3: Deliver Training Using Multi-Format Resources

Training is delivered using a mix of tools to ensure understanding across languages and learning styles:

• Instructor-led sessions

• Video tutorials and digital modules

• Safety handbooks and printed guides

• Practical hands-on training and demonstrations

• Periodic quizzes and certification exams

Training topics may include:

• Fire safety and emergency escape plans

• Material safety data sheets (MSDS)

• Proper equipment handling and use of tools

• Preventive maintenance routines

• Clean workplace standards (5S or equivalent)

• Spill prevention and countermeasures

STEP 4: Performance Monitoring and Continued Development

Managers and supervisors evaluate employees’ understanding and practical performance regularly. The process includes:

• 30-day review after onboarding

• Individual performance improvement plans

• Bi-annual assessments for skill gaps

• Certification renewals and refresher training

• On-site coaching for specific job tasks

• Leadership development and team-building sessions

Documentation is maintained for all training, and audits are performed by internal QHSE or HR officers.

Ongoing Commitments

• Confidentiality & Ethics Training: Employees are instructed on how to handle sensitive information and avoid conflicts of interest.

• Environmental Awareness: Staff working with fuel, oils, or chemicals receive annual training in spill prevention and pollution control.

• Supervisory Skills: Team leads are trained in time management, communication, and incident reporting.

• Emergency Response Drills: Regular drills ensure readiness for fires, spills, injuries, and other site-specific risks.

• Continuous Improvement: Feedback from trainees is collected to refine materials, delivery methods, and frequency.

Conclusion

Top Way’s QHSE and training systems are more than compliance tools—they are the foundation of our performance, our reliability, and our reputation. Every employee plays a vital role in upholding these standards.

We do not compromise safety or ethics for short-term gain. Our commitment to excellence is shared by our team, guided by leadership, and reflected in the trust our clients place in us every day.