POL - Management System Policy

1. Purpose
2. Scope
3. Normative References
4. Terms and Definitions
5. Roles and Responsibilities
6. Management System Commitments and Objectives
7. Archiving and Updating
8. Reference Documents

This policy sets out the intentions and commitments of the Top Management of Top Light Italia Srl with regard to quality, establishing the guiding principles, strategic directions and values underpinning the Quality Management System (QMS). Through this document, the organization communicates to all employees, customers, suppliers, business partners and other interested parties its vision regarding service quality, customer satisfaction and continual improvement.

This policy provides the framework for establishing quality objectives and developing the associated improvement programmes, ensuring alignment between day-to-day operational decisions and the company's strategic directions in the marketing and distribution of automotive lighting components, driver assistance devices and wiper blades.

This policy applies to all activities carried out by Top Light Italia Srl at its registered office located at Viale Bartolomeo D'Alviano, 43, 36100 Vicenza (VI), and its operational premises located at Via Ponte D'oro, 8, 36015 Schio (VI), Italy. It encompasses the entire workforce, including sales, logistics, warehousing, administrative and support functions, as well as procurement, storage, distribution and customer service processes relating to products marketed under the Toplight and DQP brands.

• ISO 9001

• Quality Policy: The intentions and direction of an organization related to quality, as formally expressed by its Top Management.
• Quality Management System: The part of an organization's management system focused on achieving results in relation to quality objectives, with the aim of meeting the needs, expectations and requirements of interested parties.
• Top Management: A person or group of people who direct and control an organization at the highest level.
• Continual Improvement: A recurring activity aimed at enhancing the ability to fulfil requirements.
• Quality Objective: A result to be achieved in relation to quality, established by the organization and consistent with its Quality Policy.
• Interested Party: A person or organization that can affect, be affected by, or perceive itself to be affected by a decision or activity.
• Requirement: A need or expectation that is stated, generally implied or obligatory.
• Context of the Organization: The combination of internal and external factors that may affect an organization's approach to developing and achieving its objectives.

• Top Management: Establishes, approves and maintains the Quality Policy, ensuring its continued alignment with the organization's context and strategic directions.
• Management System Manager: Supports Top Management in drafting and updating the policy, coordinates its communication throughout all levels of the organization and periodically assesses the continued adequacy of the document.

Organizational Context and Corporate Identity

Top Light Italia Srl, established in 2016 and operating in the wholesale distribution of automotive lighting components, driver assistance devices and wiper blades, recognizes the quality of the services provided to its B2B customers as a cornerstone of its competitiveness.

The organization markets its products under the Toplight and DQP brands, serving spare parts distributors, wholesalers, repair workshops and independent automotive service centres in both the domestic and international automotive aftermarket.

The company's ethical values are founded on compliance with the law, transparency in business relationships, fair and ethical conduct towards customers, suppliers and employees, and social responsibility.

Top Management promotes an organizational culture in which these values guide every decision and every interaction with interested parties.

Management Commitments

Through this policy, the Top Management of Top Light Italia Srl undertakes the following commitments:

• Customer Satisfaction: The organization strives to achieve the highest level of satisfaction among its B2B customers through on-time deliveries, product conformity with technical and type-approval requirements, the availability of a comprehensive product range, competitive pricing, and effective, responsive after-sales support.
• Compliance with Applicable Requirements: Top Light Italia Srl is committed to fulfilling requirements arising from applicable legislation, relevant automotive type-approval regulations, contractual customer requirements and the needs of relevant interested parties, while fostering a culture of legal compliance at every level of the organization.
• Continual Improvement of the QMS: The organization adopts a systematic approach to improving its performance, based on data analysis, monitoring of process performance indicators, internal audit findings, management of nonconformities and periodic management reviews, ensuring that the QMS remains consistently suitable, adequate and effective.
• Risk and Opportunity Management: Top Management promotes the identification, assessment and management of risks and opportunities that may affect the organization's ability to achieve its objectives, implementing proportionate mitigation measures and pursuing opportunities for growth and innovation.
• People Development and Empowerment: Top Light Italia Srl recognizes that the skills and motivation of its personnel are essential factors in delivering high-quality services. The organization is committed to ensuring safe working conditions, promoting professional development and ensuring that roles and responsibilities are clearly defined and communicated.

Strategic Directions

This policy supports and reinforces the organization's strategic directions, which include:

• Consolidating and differentiating the range of automotive lighting and visibility products;
• Expanding into the retrofit LED conversion kit segment in response to the increasing adoption of LED technology in the automotive aftermarket;
• Broadening the range of high-efficiency LED products to support the transition towards low-emission vehicles;
• Developing the company's presence in the commercial and industrial vehicle segment (24 V);
• Expanding the B2B e-commerce channel;
• Strengthening customer service and specialized technical support as a competitive advantage over generalist distributors.

Framework for Quality Objectives

This policy provides the framework for establishing quality objectives.

These objectives are derived from the analysis of the organization's internal and external context, the assessment of risks and opportunities, the outcomes of management reviews and the measured performance of business processes.

Each objective is formally documented, specifying the resources allocated, implementation timelines, monitoring indicators and assigned responsibilities, in accordance with the provisions of the procedure PRO – Objectives and Planning to Achieve Them.

Communication of the Policy

This policy, classified as a public document, is made available and maintained as documented information within the QMS. Top Management ensures that the policy is communicated throughout all levels of the organization through the channels established in the procedure PRO – Documented Information Management Procedure, so that it is understood and implemented by all personnel. The document is also made accessible to external interested parties, including customers, suppliers, business partners, certification bodies and other relevant stakeholders, without restrictions on access.

The policy is updated upon the initial implementation of the QMS, following a management review that identifies the need for revision, in the event of significant changes to the internal or external context, or whenever the company's strategic directions are modified. Following each update, the Management System Manager repeats the communication process, informing personnel at the relevant organizational levels and updating external communication materials accordingly.

This policy is maintained in digital format within the QMS document management system, with periodic backups, access controls and safeguards against unauthorized modifications. The Management System Manager reviews the document for continued adequacy at least annually, during management reviews or whenever significant changes occur in the regulatory framework, organizational structure or business processes. Any amendment is subject to the same formal approval process by Top Management as that required for the initial issuance.
Superseded versions are archived separately to ensure historical traceability, while the updated version replaces the previous one within the document management system.

• PRO – Management Processes
• PRO – Objectives and Planning to Achieve Them
• PRO – Documented Information Management Procedure
• Context Analysis

Date - 17 July 2026

Author - Laura Matteazzi

Approved by – Dario Salvagno