1) What is Topcity Code Of Conduct?
Topcity promotes innovation through its commitment to ethical and responsible business conduct. Topcity’s ethical culture is built upon accountability to the core ethical values of Fairness, Honesty, Integrity, Respect and Responsibility which guide how Topcity personnel work with colleagues, business partners and the communities in which Topcity does business to fulfill Topcity’s Purpose & Values.

 

The Topcity Group Code of Conduct is the cornerstone of Topcity’s ethics and compliance program and underlines a shared obligation to enhance and advance Topcity’s ethical culture and protect Topcity’s reputation. The Code applies to all Topcity board members, officers and employees (“Topcity Group personnel”).

2) What is topcity's Core Ethical Values?
Topcity updates the Code from time to time, as part of its continued effort to maintain the Code’s effectiveness and provide clear direction and resources on relevant topics.

Topcity also recognizes its responsibility as a member of a global society and the Code reflects principles set out in global ethical guidelines, which include (among others):

 

• (1).Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises
• (2).The United Nations Global Compact
• (3).The United Nations Universal Declaration of Human Rights
• (4).The Guiding Principles on Business and Human Rights and Sustainable Development Goals (SDGs)

 

Topcity also participated in the formulation of (and updates of) and observes the standards in the Charter of Corporate Behavior of Business,These standards are also embodied in the Code.

The Code confirms that Topcity must be true to its core ethical values in every aspect of its businesses operations and includes guidance on key risk areas.

 

• Accurate recordkeeping

• Anti-corruption/bribery

• Antitrust / fair competition

• Avoiding conflicts of interest

• Diversity / discrimination / equal employment opportunity / fair employment / proper workplace conduct

• Fair dealing (fair business practices)

• Privacy (e.g., data privacy of employees, customers, consumers) and cyber security

• Protection of human rights

• Financial integrity and anti-fraud

• Speaking up / no retaliation

• Tax law compliance

• Workplace health and safety

3) What is the Code Implementation for Topcity?
The Code was adopted by the Topcity Corporation Board of Directors and by senior leadership at all affiliates of Topcity Corporation (the “Topcity Group” or the “Topcity Group companies”). Topcity Group leaders are responsible for promoting the Code as part of ongoing commitment to improving Topcity’s culture of ethical decision making.

 

The Code, which is available on Topcity’s website and on each Topcity Group company’s intranet, has been translated into 10 languages to help ensure that it is clearly understood by the employees and relevant third parties. Topcity will provide additional translations as may be necessitated by changing workforce demographics.

 

All Topcity Group employees and selected third party staff are required to complete Code of Conduct training within 90 days of hire or the commencement of provision of service. Topcity also provides in-depth refresher training on at least one Code of Conduct topic every year, with additional targeted training provided more frequently based on the results of risk assessments.