Terms & Conditions and Policies
Acceptable Use Policy
You must use the Services in compliance with, and only as permitted by, applicable law. The use of our Services in conjunction with other tools or resources in furtherance of any of the unacceptable uses described herein is also prohibited. In the event of any violation of this Acceptable Uses Policy, Topuz & Partners may, in its sole discretion, do one or more of the following:
(i) Suspend (temporarily or permanently) ore terminate your use of the Services;
(ii) Block your access to the Services;
(iii) Remove or delete content from your account(s); or
(iv) Communicate such violation to impacted third parties and/or law enforcement authorities (where appropriate and subject to applicable law).
Capitalised words not defined in the Acceptable Uses Policy are defined in the Terms of Use or Governing Services Agreement (as applicable).
You are responsible for your Content, Customer/Patient Data, conduct, and communications with others while using the Services unless provided otherwise by the law, such as data protection legislation. You must comply with the following requirements when using the Services. If we become aware of Content or Data that falls outside the bounds of what is acceptable under this policy, we may remove it and report it. We also take steps to prevent uses of our Services that are contrary to the spirit of this policy.
(a) You must not use the Services to commit an unlawful activity or use the Services for activities where use or failure of the Services could lead to physical damage, death, mental harm, or personal injury;
(b) You must not provide any Minor, defined as any individual under the age of 18 (or under a higher age as provided in certain countries or territories) with any access to the Services, whether as a Respondent or Creator (as defined in our Privacy Notice);
(c) You must not purchase, use, or access the Services for the purpose of building a competitive product or service or for any other competitive purposes;
(d) You must not misuse our Services by interfering with their normal operation or attempting to access them using a method other than through the interfaces and instructions that we provide;
(e) You may not circumvent or attempt to circumvent any limitations that Topuz & Partners imposes on your use of our Services or your account(s) (such as by opening up a new account to create or distribute a survey, form, application, or questionnaire that we have closed for a violation of our terms or policies);
(f) Unless authorised by Topuz & Partners in writing, you may not probe, scan, or test the vulnerability or security of the Services or any Topuz & Partners or any of its affiliates systems or networks;
(g) Unless authorised by Topuz & Partners in writing, you may not use any automated system or software to extract or scrape data from the websites or other interfaces through which we make our Services available;
(h) You may not deny others access to, or reverse engineer, the Services, or assist anyone else to do so, to the extent such restriction is permitted by law;
(i) You may not store or transmit any viruses, malware, or other types of malicious software, or links to such software, through the Services;
(j) You may not use the Services to infringe the intellectual property rights of others;
(k) Unless authorised by Topuz & Partners in writing, you may not resell or lease the Services;
(l) We may offer content like images or video that are provided by third parties. You may use that material solely in your Content or Operations. Topuz & Partners may modify or revoke that permission at any time in our sole discretion. In using such material, you may not imply that your Content, Customer Data, or use of the Services are affiliated with or run or endorsed by any company, product, brand, or service depicted in that material unless you have obtained their permission.
(m) You may not engage in abusive or excessive usage of the Services, which is usage significantly in excess of average usage patterns of reasonable users similar to you, including any usage that adversely affects the speed, responsiveness, stability, availability, or functionality of the Services for other users. Topuz & Partners will endeavour to notify you of any abusive or excessive usage to provide you with an opportunity to reduce such usage to a level acceptable to Topuz & Partners which no longer causes such adverse effects.
(n) You must use a valid email address to register an account. You may not register accounts using a disposable or temporary email address, “bots,” or other unauthorised automated methods;
(o) You may not host or transmit content that is or contains false, inaccurate, or intentionally deceptive information that is likely to cause harm to the public or adversely affect the public interest (including health, safety, election integrity, and civic participation);
(p) If Topuz & Partners determines, in its sole discretion, that your usage of the Services causes damage to our brand or reputation, or results in an excessive volume of complaints, Topuz & Partners, has the right to suspend or terminate your use of our websites and the Services.
(q) If we become aware that the individuals you have referred to us for research purposes do not meet the requirements to be a referee (i.e., someone who is not a minor and has used your services [ideally over the last 12 months] or someone who is not a minor and is professionally qualified to comment on the quality of your services), we will give you the opportunity in writing to modify the list of referred people within a timeframe deemed appropriate by the relevant research analyst. If you do not respond to our research analysts’ requests, we will have no obligation to you to attempt to survey or interview the individual not meeting our requirements or positively seek out a replacement.
We strive to protect the security of all our users. We take specific measures to ensure respondents are not misled by surveys/forms/applications/questionnaires/interviews used for fraudulent or malicious purposes. We will suspend any use of the Services or remove any Content or Data which comes to our attention that:
(a) publishes a person’s identifying information without their consent;
(b) is intended to deceive or mislead Topuz & Partners, the individuals it contacts, its business partners or the public e.g., trying to manipulate the research process against, including links to websites with malicious software such as malware;
(c) promotes or recruits for pyramid schemes, multi-level marketing campaigns, or work-from-home and other false earning scams;
(d) knowingly and artificially boosts or inflates a website or webpage’s search engine ranking or reputation, including by offering or selling social media “likes”, followers, reviews, comments, or similar services; or
(e) hosts content that is downloadable, live-streamed, or merely intended to solicit clicks to other sites.
Referees/Respondents provide responses and information with the expectation that their information and personal data will be handled respectfully and not abused. Accordingly, you are responsible for complying with all applicable data protection laws and regulations with respect to any data that you submit to or collect through our Services.
We encourage you to disclose your privacy practices when you use the Services and, if you do, we require you to act in accordance with those practices.
You must not, directly or indirectly, impersonate others or misrepresent your affiliation with others when using the Services.
(a) Emails you send via the Services must have a valid reply-to email address owned or managed by you. You may not use a “no reply” address as the sender email address;
(b) Text messages you send via the Services should include your company name or otherwise identify you as the sender;
(c) You may only use the Services to send emails and text messages to people who have opted in to, or otherwise validly consented to, receiving communications from you, the sender through that medium.
(d) You must not utilise the Services to send any email or text messages in a way not permitted by or compliant with applicable law, carrier compliance requirements or industry standards, or to any recipient who has opted out, unsubscribed, or otherwise objected to receiving such messages from you or another party on whose behalf you may be commissioned.
(e) You must not use the Services to send emails with deceptive subject lines or false or misleading header information.
(f) Email messages sent in connection with our Services must contain an “unsubscribe” link that allows subscribers to remove themselves from your email messages. You acknowledge and agree that you will not hide, disable, or remove or attempt to hide, disable, or remove the opt-out link from the email invitation. You will actively manage and process unsubscribe requests received by you directly within ten days of submission and update your email lists and address books to reflect the unsubscribe requests.
(g) You are responsible for ensuring that the email messages or text messages you send in connection with our Services do not generate a number of spam complaints or bounce rates in excess of industry standards. If Topuz & Partners determines that your level of spam complaints or bounce rate is higher than industry standards, Topuz & Partners, at its sole discretion, has the right to suspend or terminate your use of our Services and websites. If you receive low response rates, high abuse rates, or high bounce rates, or we receive complaints associated with your use of our Services, we may request additional information regarding your mailing lists to investigate and attempt to resolve the problem, or in some cases we may suspend or remove your privileges.
(h) Text message invitations you send via our Services must have a valid reply “Stop”. You must not use any of our communication tools to access or allow access to emergency services.
If we believe you are violating any of these prohibitions, we may suspend (temporarily or permanently) or terminate your account(s).
You may not use our Services to bully or harass others, in furtherance of any criminal activity, or in violation of any applicable law.
You may not include graphic violent material or pornography in connection with the use of our Services.
You may not under any circumstances share, transmit, upload, or store materials that constitute any of the following to our platform or to our company and affiliates including in communications: unlawful pornography; material that shows a child engaging in or depicted as engaging in sexually explicit activity, for example, child sexually exploitative material (including material which may not be illegal child sexual abuse material but which nonetheless sexually exploits or promotes the sexual exploitation of minors); or materials that are otherwise indecent.
Please respect the intellectual property rights of others. You must have the appropriate rights to use any Content or Data. It is your responsibility to determine what rights you need, to obtain and maintain those rights, and to understand how you are permitted to exercise those rights. You may include Content, including any third-party logos, brands and other indicia of source, (a) to the extent permitted as a fair use or otherwise under applicable law, and (b) so long as the use does not (i) cause confusion as to the origin or sponsorship of a good or service, (ii) imply sponsorship or endorsement by the trademark owner where none exists, or (iii) inaccurately describe a product or service. We recommend that you seek independent legal counsel if you have questions about your use of content or intellectual property owned by a third party.
If you suspect that someone’s use of our Services is in violation of this policy, please contact us immediately by filing an abuse report and we will investigate the matter. You can do so by reaching out to legal@globaldoctorreview.com AND info@globaldoctorreview.com. Please include any relevant evidence and copy both email addresses.
Code of Business Conduct and Ethics
We are an organisation guided by a strong set of values. These values are not merely aspirational words—they serve as fundamental principles that shape the way we operate. They reflect what we expect of ourselves and one another, influencing our decisions and defining our culture. We use them as a benchmark for success and a compass for our actions.
This Code of Business Conduct and Ethics (the “Code”) was adopted to further the Company’s commitment to conducting its business with honesty and integrity. This Code applies to all the employees, independent contractors, officers and directors (all of whom are referred to collectively as “team members”) of Topuz & Partners and its affiliates (collectively, the “Company” or “Topuz & Partners”).
The purpose of this Code is to ensure and promote:
– Fair and accurate financial reporting;
– Ethical conduct and adherence to all applicable laws, rules, and regulations;
– Timely internal reporting of any breaches of this Code, as outlined herein;
– Honest and ethical behaviour, including the responsible management of actual or perceived conflicts of interest;
– A culture founded on honesty and accountability; and
– The prevention of misconduct.
This Code provides a set of guiding principles, and the Company expects all team members to exercise sound judgement in consistently upholding the high ethical standards to which the Company is firmly committed.
Team members are required to familiarise themselves with the policies set out in the Code and to ensure they fully understand and comply with them. The Company’s internal legal counsel is responsible for interpreting and applying these policies in specific circumstances and holds the authority to provide definitive guidance where needed.
Should team members have any questions regarding the Code or the appropriate course of action in a given situation, they should consult the internal legal counsel. Where necessary, the internal legal counsel may seek advice from the Company’s external legal counsel or the Board of Directors (the “Board”).
This Code should be read in conjunction with all other policies relevant to a team member’s role. Any decision regarding the application of this Code to the Company’s officers or directors may only be made by the Board.
Team members are responsible for the accurate and complete reporting of financial information within their respective areas of responsibility. They are also expected to promptly inform senior management of any financial or non-financial information that may be material to the Company. The Company places great importance on this responsibility and expects all team members to ensure that financial reports are full, fair, timely, and accurate.
All individuals involved in the Company’s financial reporting process—including, but not limited to, the principal executive officer, principal financial officer, and other senior personnel with similar responsibilities (collectively referred to as “Senior Financial Officers”)—must develop a thorough understanding of the Company’s business and financial operations. They must not knowingly misrepresent, or encourage others to misrepresent, facts concerning the Company to any party, whether internal or external, including independent auditors, regulatory authorities, and self-regulatory organisations.
The Company’s books, records, accounts, and financial statements must be maintained with reasonable detail and must accurately, fairly, and completely reflect the transactions and events to which they relate. These records must comply with applicable legal requirements and align with the Company’s system of internal controls. All Company assets must be properly and transparently accounted for.
The establishment of undisclosed or unrecorded accounts or funds is strictly prohibited. No false or misleading entries may be made in the Company’s records under any circumstances, and no disbursement of Company funds or assets may occur without proper documentation and authorisation. Misclassification of transactions by account, business unit, or accounting period is not permitted. Each team member is personally responsible for ensuring they are not involved in the creation or approval of any false or misleading accounting entries.
A conflict of interest arises when an activity or personal interest is incompatible with, or contrary to, the best interests of the Company. Decisions and actions taken by team members in the course of their employment or association with the Company should always prioritise the Company’s interests, rather than being influenced by personal relationships or the prospect of personal gain. Team members must never use—or attempt to use—their position within the Company to secure improper personal benefits.
Directors must be informed of their under sections 170-177 and 182 Companies Act 2006 and warrant that they understand the scope of their duties vis-à-vis the company.
Any situation, transaction, or relationship that may result in an actual or potential conflict of interest must be disclosed to the Company and should be avoided, unless expressly approved by the Company.
The following are examples of conflicts of interest that must be avoided:
(i) Family Relationships: Team members must not conduct business on behalf of the Company with family members or with organisations associated with a family member, unless the relationship has been fully disclosed and authorised by the Company. The arrangement must also constitute a genuine, arm’s-length transaction. “Family members” include spouses, parents, children, siblings, in-laws, step-relatives, individuals in an intimate relationship, and any other person (excluding tenants or team members) sharing the same household.
(ii) Interests in Other Businesses: Team members must not accept compensation of any kind for services provided to the Company from sources other than the Company itself. Furthermore, they must not hold any undisclosed, material financial interest in any competitor, supplier, customer, or business partner of the Company.
(iii) Improper Conduct and Activities: Team members must refrain from engaging in activities or conduct that conflict with the Company’s interests, or that may significantly damage or disrupt the Company’s relationship with any third party, including prospective or current business partners or contractual counterparts.
(iv) Gifts and Hospitality: This Code does not prohibit modest, appropriate, and customary hospitality to or from third parties, where such courtesies help to foster goodwill. However, care must be taken, particularly when dealing with public officials, who may face legal restrictions on accepting benefits—including non-cash items such as meals, travel, or entertainment.
Business customs surrounding gifts and hospitality vary across countries, regions, and industries. What may be appropriate in one context may be unacceptable in another. The key consideration should be whether the gift or hospitality is, in all circumstances, reasonable and proportionate—not lavish or extraordinary—from the perspective of both the giver and recipient. Importantly, the intent behind the gift must be carefully considered. No gift or hospitality should be given or accepted with the expectation—explicit or implied—of favourable treatment or a business advantage in return.
Gifts, hospitality, or entertainment may be permissible if all of the following conditions are met:
– They are offered in the normal course of business;
– There is no intention to influence a third party improperly or to secure or reward any improper business advantage;
– They are not offered or received in exchange for any favour or benefit, whether explicit or implicit.
– They comply with UK and applicable local law;
– They do not include cash or a cash equivalent;
– They must be properly recorded and disclosed, and not paid personally to avoid any approval or disclosure requirements;
– Taking into account the reason for the gift or hospitality, they are of an appropriate type and value in the applicable country/region and given at an appropriate time;
– They are given openly and in the Company’s name, not secretly;
– They are not given or received frequently between the same individuals; and
– Gifts or hospitality should not be offered to public officials or government representatives, or politicians or political parties, without the prior approval of the Company’s General Counsel.
Personal Use of Company Assets. Team members may not use Company assets, labour, or information for personal use, other than incidental personal use, unless approved by the Company.
Unless otherwise specified in the Company’s certificate of incorporation or bylaws, team members have a duty to act in the best interests of the Company and to advance its business objectives whenever an opportunity arises to do so.
Team members must not exploit, or direct a third party to exploit, any business opportunity that comes to their attention through the use of Company property, information, or their position within the Company—unless the opportunity has first been offered to the Company and formally declined.
More broadly, team members must not use Company resources, confidential information, or their role within the organisation for personal benefit. Additionally, they are prohibited from directly or indirectly engaging in business activities that compete with the Company during the course of their employment, or as otherwise restricted under any contractual agreement with the Company.
We recognise that the boundary between personal and corporate benefit may sometimes be unclear, and that certain activities may yield both. In such instances, team members must ensure that any use of Company assets or services for purposes not exclusively benefiting the Company is pre-approved by the appropriate Company representative.
Directors must warrant that they understand the strict capacity-centric approach of English common law regarding the exploitation of any property, information or opportunity.
All team members have a duty to protect the Company’s assets and to ensure their efficient and appropriate use. Any suspected incidents of fraud or theft must be reported immediately to the team member’s line manager or other appropriate Company personnel for investigation.
In the course of their work, team members may become privy to confidential or proprietary information relating to the Company, its customers, suppliers, or business partners. Such information includes any non-public details that could harm the relevant company or benefit its competitors if disclosed.
Subject to the “Protected Activity Not Prohibited” section below, team members are expected to:
(i) Maintain the confidentiality of any such information entrusted to them by the Company;
(ii) Use the information solely for authorised business purposes and in accordance with any restrictions set by the disclosing party;
(iii) Limit the sharing of this information—both internally and externally—to individuals who require access for legitimate business reasons and who are bound by comparable confidentiality obligations;
(iv) Avoid any unauthorised disclosure unless required by law or with express Company authorisation.
This obligation to protect confidential information continues even after a team member’s employment with the Company has ended. If there is any uncertainty about whether information is considered confidential, team members should seek clarification from the Company’s internal legal counsel.
Also subject to the “Protected Activity Not Prohibited” section, any approach by members of the financial community, media, or other external organisations seeking a comment or statement on behalf of the Company must be referred to a member of the Company’s communications team. Enquiries relating to business performance, regional activities, pricing, supplier relationships, new products or technologies, legal disputes, or any other aspect of the Company’s operations should likewise be directed to the communications team.
The Company has a history of succeeding through honest business competition. The Company does not seek competitive advantages through illegal or unethical business practices. Each team member should endeavour to deal fairly with the Company’s customers, service providers, suppliers, competitors, and team members. No team member should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any unfair dealing practice. Any questions regarding such business practices should be directed to the Company’s internal legal counsel.
All team members are expected to comply with all applicable laws when performing their duties on behalf of the Company and must refrain from any form of unlawful conduct.
It is the responsibility of each team member to be familiar with the laws, regulations, and rules relevant to their specific role and area of responsibility. Where a legal requirement is in conflict with a Company policy outlined in this Code, the law must take precedence. If there is any uncertainty regarding the applicability or interpretation of a particular law, guidance should be sought from the Company’s internal legal counsel.
Below is a brief overview of key legal areas that team members should be mindful of:
A. Competition Law
Competition laws and regulations across the globe are designed to encourage a competitive marketplace and prohibit activities that hinder trade. Generally, actions taken in collaboration with other companies that restrict competition may violate competition and/or consumer protection laws. Certain competition violations, particularly agreements with competitors, are criminal offences and can result in significant fines and prison sentences for the individuals involved. Additionally, actions by an individual company, particularly in market segments where it holds a dominant position, may violate antitrust laws if they effectively exclude competition through unfair means.
The Company is committed to adhering to laws governing fair competition in all of its activities. Any conduct that undermines this commitment is unacceptable. As the laws in this area are complex, team members should seek guidance from internal legal counsel before taking any action when appropriate.
B. Health, Safety & Environment
The Company is dedicated to conducting its business activities in a manner that promotes the protection of people and the environment, to the extent practicable. Compliance with all applicable laws, rules, and regulations governing health, safety, and the environment is a responsibility shared by management and team members across all functions.
C. Fair Employment Practices
The Company aims to maintain a work environment where all individuals are treated with respect and dignity. Every individual has the right to work in a professional atmosphere that promotes equal employment opportunities, free from discriminatory practices, including harassment.
The Company expects all team members to treat colleagues in a respectful and professional manner, fostering working relationships that are free from bias, prejudice, and harassment. The Company prohibits discrimination or harassment based on race, caste or perceived caste, religion, religious creed (including religious dress and grooming practices), colour, sex (including pregnancy, childbirth, breastfeeding, or related medical conditions), nationality, ethnic or national origin, ancestry, immigration status, citizenship, age, physical or mental disability, medical conditions (including genetic information or characteristics, or those of a family member), military service or veteran status, marital or family care status, sexual orientation, family medical leave, gender (including gender identity, gender expression, transgender status, or sexual stereotypes), political views or activity, status as a victim of domestic violence, sexual assault or stalking, or any other classification protected by applicable federal, state, or local law.
Any team member found to have discriminated against another team member may be subject to disciplinary action, up to and including termination of employment or their relationship with the Company.
The Company prohibits retaliation or reprisals against any individual for making complaints, reporting incidents of discrimination, or participating in investigations related to discrimination. Additional information regarding the Company’s equal employment, anti-discrimination, and harassment policies can be found in the Employee Handbook.
D. Political Activities
The Company does not make contributions to political candidates or political parties. Team members engaging in political activities do so in their capacity as private citizens and not as representatives of the Company. A team member’s personal decision to make, or refrain from making, political contributions will not influence their compensation, job security, or opportunities for advancement.
E. Foreign Corrupt Practices and and Anti-bribery Laws
Team members may only transact business on behalf of the Company in foreign markets and with foreign government officials in accordance with the Company’s established policies regarding foreign corrupt practices and/or any applicable law, including the United Kingdom Bribery Act of 2010. Team members must never engage in any bribery, kickbacks or other types of corruption when dealing with customers, suppliers or other third parties regardless of local practices or competitive intensity. Specifically, team members must never directly or indirectly via a third party make or provide a payment (including cash or any other items of value such as meals, gifts, travel, entertainment, etc.) to a foreign official or government employee to corruptly influence the foreign official or government employee, obtain or retain business for the Company or to acquire any improper advantage.
If a team member is unaware of the legal rules involving these activities, he or she should consult with the Company’s inside legal counsel before taking any such action. For more information about the FCPA and the rules governing providing things of value to foreign officials, please reference our Global Anti-Corruption Policy, which can be found on the Company’s internal website, or contact our internal legal counsel.
A. Seeking Guidance
Team members are encouraged to seek guidance from their managers, the Company’s human resources team, the internal legal counsel, or other appropriate Company personnel when uncertain about the best course of action in a particular situation. In most instances, any questions concerning the Code should be directed to the Company’s internal legal counsel.
B. Reporting Violations
If a team member becomes aware of or suspects a violation of this Code, or of applicable laws and regulations (including concerns regarding accounting, internal accounting controls, or auditing matters), they must report it immediately to the Company’s internal legal counsel. For information about making anonymous reports, please refer to the “See Something, Say Something” policy.
All reports will be kept confidential to the extent possible, except where disclosure is required to investigate the report or mandated by law. The Company strictly prohibits any form of retaliation for making good-faith reports of violations or potential violations.
C. Investigations
All reported violations will be promptly and thoroughly investigated. It is crucial that the person reporting the violation does not attempt to investigate it themselves. Team members are expected to fully cooperate with any authorised investigation, whether internal or external, into reported violations. They should never withhold, tamper with, or fail to communicate relevant information during such investigations.
Additionally, team members are expected to maintain and safeguard the confidentiality of any investigation, unless otherwise required by law. Making false statements or misleading internal or external auditors, investigators, legal counsel, Company representatives, regulators, or government entities can result in immediate termination of employment or other relationships with the Company, and may also be a criminal offence subject to severe penalties.
D. Sanctions
Team members who violate this Code may face disciplinary action, up to and including termination of employment. Team members or officers who direct, approve, or have knowledge of conduct in violation of this Code, but fail to report it promptly, may also be subject to disciplinary measures, including termination. Any director who violates this Code or directs or approves conduct in violation of this Code will be subject to actions determined by the Board.
Furthermore, violations of certain provisions of this Code may be illegal, subjecting the team member, officer, or director to civil and criminal liability.
E. Disclosure
Nothing in this Code or any other Company agreement or policy is intended to prevent or restrict the disclosure of confidential information to any relevant government, regulatory, or self-regulatory agency, including disclosures under UK whistleblower regulations, as amended, and the associated rules.
Any amendment or waiver of any provision of this Code must be approved in writing by the Board or, where appropriate, its delegate(s), and promptly disclosed in accordance with applicable laws and regulations. Any waiver or modification of the Code for a Senior Financial Officer will be disclosed to stockholders promptly, if required by applicable law or the rules of the relevant stock exchange.
The Company continuously reviews and updates its policies and reserves the right to amend this Code at any time for any reason.
Nothing in this Code limits or prohibits team members from engaging for a lawful purpose in any “Protected Activity.”
“Protected Activity” includes: (i) filing and/or pursuing a charge, complaint, or report with, or otherwise communicating, cooperating, or participating in any investigation or proceeding that may be conducted by any government agency, department or commission, court or tribunal; and/or (ii) discussing or disclosing information regarding unlawful acts in the workplace, such as harassment, discrimination, or any other conduct that the team member reasonably believes to be unlawful. In relation to such Protected Activity, team members are permitted to disclose documents or other information as authorised by law, without the need to notify or seek authorisation from the Company.
However, notwithstanding the above, team members are required to take all reasonable precautions to prevent any unauthorised use or disclosure of the Company’s trade secrets, proprietary information, or confidential information that does not pertain to unlawful acts in the workplace or activities otherwise protected as specified herein.
Protected Activity does not encompass the disclosure of any communications protected by the Company’s legal advice privilege or litigation privilege. Any provisions in this Code or any other document that suggest team members have the right to engage in Protected Activity, which conflict with or contradict this section, shall be overridden by the terms of this Code.
For clarity, nothing in this Code should be construed as impairing or limiting any team member’s participation in legally protected activities, including (i) forming, joining, or supporting trade unions, (ii) engaging in collective bargaining through representatives chosen by the team members, (iii) discussing wages, benefits, or terms and conditions of employment, and (iv) discussing or raising concerns regarding working conditions for the purpose of mutual aid or protection of the team member or the Company’s current or former team members.
All new team members must sign an acknowledgment form confirming that they have read this Code and that they understand and agree to comply with its provisions. Signed acknowledgment forms will be kept in team member personnel files. Failure to read this Code or to sign an acknowledgement form does not excuse any person from the terms of this Code.
Integrated Management System Policy
Topuz & Partners Ltd regards information security and the confidentiality of personal data as a corporate responsibility and, in this context, undertakes to:
(a) Protect the confidentiality, integrity, and availability of all information assets within the organisation;
(b) Conduct all information security and personal data processing activities in compliance with applicable legal requirements, contractual obligations, and international standards (ISO/IEC 27001 and ISO/IEC 27701);
(c) Identify, assess, and effectively manage risks within the scope of the Information Security Management System (ISMS) and Privacy Information Management System (PIMS),
Ensure that personal data is processed in a fair, transparent, and lawful manner;
(d) Raise awareness of information security and privacy among all employees and relevant stakeholder;
(e) Uphold the principles of trust, responsibility, and accountability in information exchange with internal and external stakeholders;
(f) Carry out regular reviews, audits, and continuous improvement activities to ensure the effectiveness of the systems;
(g) Develop effective management processes to respond to any complaints, requests, or breaches relating to the protection and confidentiality of personal data.
Batuhan Topuz, Director
01/09/2025
