1. Introduction

At Top Way, we recognize and uphold the fundamental dignity, freedom, and equality of every individual. Our commitment to human rights is central to our identity as a responsible, values-driven company operating across diverse regions and industries. We are fully aligned with the Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, and the International Labour Organization (ILO) Core Conventions.

This Human Rights Policy establishes the framework through which Top Way commits to respecting and promoting human rights throughout our business operations, supply chains, and stakeholder interactions.

2. Scope and Applicability

This policy applies to:

• All Top Way employees, including temporary and part-time staff;

• Contractors, subcontractors, and suppliers;

• Business partners and other entities acting on behalf of Top Way;

• All operations in countries where we conduct business.

All individuals covered under this policy are expected to uphold these principles as part of their daily responsibilities and professional conduct.

3. Our Commitments

Top Way is committed to:

a. Respect for Human Dignity

We treat all individuals with fairness, dignity, and respect—regardless of race, gender, age, religion, ethnicity, disability, national origin, sexual orientation, or any other protected status.

b. Safe and Healthy Working Conditions

We provide a safe, clean, and healthy workplace in accordance with international safety standards. We actively monitor working conditions and take immediate steps to mitigate risks to health and well-being.

c. Freedom of Association

We respect the rights of employees to freely associate, organize, and bargain collectively in accordance with applicable laws and international norms.

d. Fair Labor Practices

We prohibit all forms of forced labor, human trafficking, and child labor. We support fair wages, reasonable working hours, and equitable treatment across all roles.

e. Non-Discrimination and Equal Opportunity

Top Way maintains a zero-tolerance approach to discrimination, harassment, and victimization in any form. We promote diversity and inclusion across all levels of the organization.

f. Right to Privacy

We respect the privacy of our employees and stakeholders. We ensure personal data is collected and processed responsibly, transparently, and securely.

g. Access to Remedy

We ensure that individuals whose rights may be adversely affected by our operations have access to effective grievance mechanisms and remedies.

4. Human Rights in Our Supply Chain

Top Way expects all suppliers and contractors to operate in alignment with this policy. We actively assess and monitor our supply chains to identify potential human rights risks, including but not limited to:

• Exploitative labor practices

• Unsafe working conditions

• Discrimination or abuse

• Environmental degradation that impacts communities

Suppliers found to be in violation of our standards may be subject to corrective action, suspension, or termination of contracts.

5. Governance and Oversight

The Board of Directors is responsible for overseeing Top Way’s human rights strategy. Day-to-day implementation is managed by our Ethics & Compliance Team, in collaboration with Human Resources, Legal, and Procurement.

We have designated Human Rights Compliance Officers in each business unit to monitor performance, provide training, and ensure adherence.

6. Due Diligence and Risk Management

Top Way integrates human rights due diligence into its business processes, including:

• Risk assessments during new market entry, acquisitions, or partnerships

• Regular audits and supplier evaluations

• Employee and partner training programs

• Incident reporting and grievance mechanisms

We continually assess, mitigate, and report on human rights risks and impacts related to our operations.

7. Training and Awareness

We provide targeted human rights training to all employees, particularly those in leadership, operations, procurement, and compliance roles. This training includes:

• Understanding human rights risks

• Recognizing unethical practices

• Responding to and reporting violations

• Promoting a culture of integrity and respect

8. Reporting Mechanisms

All employees, partners, or stakeholders are encouraged to report suspected human rights violations through:

• Our confidential grievance hotline

• The HR Department or Ethics & Compliance Office

• Anonymously, through our whistleblower platform

Reports are treated with confidentiality and non-retaliation, and each case is investigated promptly and thoroughly.

9. Continuous Improvement

We are committed to the ongoing improvement of our human rights practices. We:

• Monitor the effectiveness of this policy

• Benchmark our practices against global standards

• Engage with stakeholders and civil society

• Publish updates on human rights efforts in our Corporate Responsibility Reports

10. Conclusion

Top Way’s success is built not only on innovation and operational excellence but also on our unwavering respect for human rights. We hold ourselves and our partners accountable to the highest ethical standards and believe that upholding human rights is essential to sustainable business.

By working together—employees, suppliers, communities, and leadership—we can foster a culture where human dignity is respected, voices are heard, and every individual has the opportunity to thrive.