Toll Employees

Compliance & Policies

This policy sets out the Skylink network criteria design for global code of ethics.

Global Code of Ethics – Statement from the C.E.O & President

Effective: 20 January 2020

Overview

This policy establishes Skylink Network’s Global Code of Ethics and defines the standards for integrity, transparency, and ethical conduct across all operations.

Skylink Network’s core values are built on trust and integrity, along with continuous development, openness, and transparency. In achieving our commercial objectives, all activities must align with these values, the organization’s vision, and its core business practices.

Scope

This policy applies to all individuals working with Skylink Network in any capacity, including full-time, part-time, temporary employees, contractors, and associated business partners.

It extends to all companies and individuals connected with the Skylink Network. All partners are expected to adhere to similar ethical standards when conducting business with Skylink.

Principles

Anti-Bribery & Facilitation Payments

  • Skylink complies with all applicable local and international laws in the countries in which it operates.
  • Bribery, kickbacks, and facilitation payments are strictly prohibited in any form, whether direct or indirect.
  • Employees must not offer, give, or accept any improper financial or non-financial advantage.
  • In situations involving coercion or extortion (including threats of business loss or harm), employees must report the matter immediately to management.

Gifts and Hospitality

  • Skylink restricts the acceptance or offering of gifts or benefits that may influence business decisions or compromise impartiality.
  • Reasonable and proportionate hospitality may be exchanged in the normal course of business as a gesture of goodwill.
  • The total value of gifts, entertainment, or gratuities must not exceed USD 50 (or equivalent), unless prior written approval is obtained.

Principles

Anti-Bribery & Facilitation Payments

  • Skylink complies with all applicable local and international laws in the countries in which it operates.
  • Bribery, kickbacks, and facilitation payments are strictly prohibited in any form, whether direct or indirect.
  • Employees must not offer, give, or accept any improper financial or non-financial advantage.
  • In situations involving coercion or extortion (including threats of business loss or harm), employees must report the matter immediately to management.

Gifts and Hospitality

  • Skylink restricts the acceptance or offering of gifts or benefits that may influence business decisions or compromise impartiality.
  • Reasonable and proportionate hospitality may be exchanged in the normal course of business as a gesture of goodwill.
  • The total value of gifts, entertainment, or gratuities must not exceed USD 50 (or equivalent), unless prior written approval is obtained.

Note:

All transactions exceeding approved limits must be recorded and maintained for audit purposes.

Vendor Selection & Business Partners

  • Skylink engages with global logistics providers, agents, consultants, subcontractors, and suppliers who meet recognized standards, including ISO-certified partners.
  • All business relationships must be conducted with transparency, fairness, and accountability.
  • Partners are expected to adhere to ethical standards consistent with Skylink’s policies, including anti-bribery and fair labor practices.
  • Where non-compliance is identified, Skylink will seek corrective action; if unresolved, the relationship may be terminated.
  • All fees and commissions must represent legitimate and justified compensation for services rendered.

Fair Competition

  • Skylink competes fairly and complies with all applicable competition and anti-trust laws.
  • All representations regarding services must be accurate, truthful, and not misleading.

Conflict of Interest

  • Employees must avoid situations where personal interests conflict, or appear to conflict, with company interests.
  • Employees must not engage in competing activities or assist competitors using company knowledge.
  • Business dealings with related parties (family or personal connections) must be disclosed and approved in advance.
  • Ownership of shares in publicly traded companies is permitted, provided no conflict exists.
  • Any conflict of interest must be reported to HR or Compliance.

Records and Books

  • Skylink maintains accurate and complete records of all business transactions.
  • Records must be retained in accordance with legal and regulatory requirements.

Charitable Donations

  • Donations must serve legitimate public purposes and be fully documented.
  • Skylink does not make contributions to political parties or government officials.

Seeking Guidance and Reporting

  • Employees are encouraged to seek guidance from HR or Compliance when in doubt.
  • Any suspected violation must be reported promptly and in good faith.

Responsibility

This policy is implemented by the Human Resources Department and Compliance Administrator.

Senior management is responsible for ensuring that this policy is effectively communicated, understood, and enforced across all levels of the organization.

Compliance and Review

The Administration is responsible for monitoring compliance and evaluating performance against defined objectives.

This policy is subject to periodic review to ensure alignment with legal, regulatory, and organizational requirements.

Infringement of this Policy

Skylink Network is committed to conducting business in compliance with all applicable laws and the highest ethical standards.

Any violation of this policy may result in disciplinary action, including termination of employment or contract.

Employees will not be penalized for reporting concerns in good faith, even if such reports are not substantiated after investigation.

Further Information

For further guidance, contact the Human Resources Department or Compliance Administrator.