Code of Conduct

This Code is designed to reinforce the values of service, commitment, reliability, and integrity. It applies to all GOLDWAY employees worldwide regardless of position, and serves as a guideline for interactions with colleagues, customers, suppliers, and all stakeholders.

Management sets legal and ethical expectations and leads by example. Ethical concerns raised by employees are regarded not as challenges to authority, but as honest business communication, and management is responsible for addressing them promptly.

While not every situation can be defined, ask yourself the following when facing a dilemma:

• Is my decision legal and compliant with company policies?
• Does it protect GOLDWAY’s reputation and ethical standards?
• Can I confidently explain my decision in a meeting or to my family?
• "Is this truly the right thing to do?"

GOLDWAY does not tolerate any form of retaliation against employees who report concerns in good faith. Those involved in retaliation will be subject to disciplinary action, and confirmed violations of this Code may result in strict measures, including termination of employment.