At Top Way, we uphold the highest standards of professionalism, safety, and respect across all aspects of our business. We are fully committed to providing a workplace that is free from all forms of sexual harassment, ensuring that all employees, contractors, clients, and partners are treated with dignity and equality.

Sexual harassment not only undermines the integrity of the working environment but also constitutes a violation of the law and our core values. This policy outlines our corporate stance, legal obligations, expectations of conduct, response mechanisms, and support structures to prevent, address, and remediate any incidents.

1. Definition of Sexual Harassment

Sexual harassment is any unwelcome sexual advance, request for sexual favors, or other verbal or physical conduct of a sexual nature when:

• Submission is made a condition of employment;

• Submission or rejection is used to make employment decisions;

• The conduct unreasonably interferes with work performance or creates an intimidating, hostile, or offensive working environment.

2. Examples of Sexual Harassment

Sexual harassment may include but is not limited to:

• Inappropriate touching, gestures, or physical contact;

• Sexual jokes, comments, innuendo, or emails;

• Repeated and unwanted romantic advances;

• Displaying sexually explicit materials in the workplace;

• Comments about a person’s appearance or private life;

• Sending suggestive or inappropriate messages;

• Threatening retaliation if sexual favors are refused.

3. What Is Not Sexual Harassment

Reasonable and consensual workplace interactions that are respectful and appropriate are not considered harassment. Performance feedback, constructive criticism, or professional communication—when conducted respectfully—do not constitute harassment.

4. Legal Standing

Sexual harassment is a violation of:

• Iraqi Labor Law and relevant KRG provisions,

• International labor conventions, and

• Top Way’s internal Code of Ethics.

All employees, regardless of rank or seniority, are legally and professionally accountable.

5. Situations Where Sexual Harassment Can Occur

Sexual harassment may take place:

• Within office premises;

• During work-related travel or field operations;

• At work-sponsored events, conferences, or training programs;

• In digital communication and virtual platforms associated with work.

6. Consequences of Policy Breach

Violations of this policy will lead to disciplinary action, including but not limited to:

• Verbal or written warnings;

• Mandatory training;

• Suspension or demotion;

• Termination of employment;

• Referral to law enforcement or external legal channels if warranted.

7. Responsibilities of Management and Staff

Management:

• Lead by example in promoting respectful behavior;

• Ensure all staff are trained and aware of this policy;

• Take all complaints seriously and act promptly;

• Maintain strict confidentiality.

Employees:

• Comply with this policy and demonstrate respectful behavior;

• Report any incidents or concerns;

• Cooperate with investigations;

• Avoid retaliation against any complainant.

8. Support & Reporting Mechanisms

Employees can seek advice or file a complaint through:

• Top Way Human Resources Department

• Designated Sexual Harassment Compliance Officers

• Confidential reporting channels (anonymous if desired)

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All complaints will be treated with confidentiality, fairness, and urgency.

9. Internal Complaint Procedure

Top Way’s formal complaint mechanism is designed to:

• Reinforce our zero-tolerance stance;

• Prevent escalation;

• Handle cases promptly, confidentially, and consistently;

• Minimize harm to the complainant;

• Protect against retaliation.

Procedure includes:

• Clearly documented and accessible process;

• Informal and formal resolution options;

• Fair, timely internal investigations;

• Oversight by trained personnel;

• Recordkeeping and reporting to executive leadership.

10. External Complaint Options

In addition to internal mechanisms, individuals may lodge a complaint directly with:

• KRG Ministry of Labor & Social Affairs

• Iraqi Human Rights Commission

• Top Way Legal Office, which will guide complainants through external legal procedures.

11. Preventative Measures at Top Way

a. Executive-Level Commitment

Senior leadership demonstrates zero tolerance and allocates resources to eliminate sexual harassment.

b. Clear Policy Communication

• Regular updates and staff-wide distribution;

• Translated versions for multilingual access;

• Inclusion in onboarding processes;

• Promotion at staff meetings and online platforms.

c. Ongoing Education

• Regular staff and leadership training sessions;

• Case-based learning and interactive workshops;

• Posters and brochures in shared spaces.

d. Accountable Management

• Evaluation of management on handling discrimination;

• Required qualifications for leadership roles include knowledge of harassment prevention.

e. Positive Work Culture

• Banning of offensive material (digital or printed);

• Technology use policies;

• Periodic environment audits.

12. Employer Liability

Top Way may be held liable regardless of awareness, especially if effective prevention and response mechanisms are absent. Liability can only be mitigated if:

• There’s a strong prevention program in place;

• Prompt corrective action is taken;

• The complaint process is clear, accessible, and effective.

13. Legal Compliance & Staff Obligations

All staff must:

• Prevent harassment in any form;

• Act when they observe misconduct;

• Avoid retaliation or peer pressure;

• Understand that ignorance of the law is not a defense.

14. Distribution of Policy Materials

All Top Way employees receive:

• "Sexual Harassment is Forbidden at Top Way" statement;

• Legal and practical explanation of rights and procedures;

• Instructions on internal and external complaint channels;

• Assurance of protection from retaliation.

15. Summary of Options for Addressing Harassment

Top Way supports several avenues for addressing concerns:

• Informal resolution via facilitated dialogue;

• Formal complaint to HR or Compliance Officers;

• External legal action through relevant authorities;

• Access to counseling and support resources.

For guidance, support, or to file a report, please contact your department’s HR representative or our Corporate Compliance Office directly.