About Intrac

We pay particular attention to creating shared value for our stakeholders, with the goal of promoting a sustainable and resilient economic, social, and environmental system. We recognize our impact on the social and environmental context in which we operate and are committed to generating long-term value for the company, our people, customers, suppliers, communities, and the environment.

We believe that innovation, the development of new products and services, and responsible behavior can help address global challenges such as climate change and social inequalities. We consider these corporate objectives to be achievable through fair and impartial action by employees and collaborators, in full compliance with environmental protection, workplace safety, and health regulations.

We align the content of this Code with the context in which we operate, placing stakeholder engagement at the core of our approach to identifying and sharing key development directions and market trends, assessing both opportunities and risks arising from the evolution of the industry.

Our actions are guided by this Code, which is an integral part of our vision of responsibility and commitment to supporting sustainable development and contributing to the achievement of the goals set by the UN 2030 Agenda.

We pay special attention to the satisfaction of our Customers, with the intention of providing in the field of activity in which we operate products of the highest standard of quality, competitive and with a guarantee of maximum professionalism.

We believe that these corporate objectives necessarily pass through the fair and impartial action of employees and collaborators and compliance with regulations on environmental protection and occupational health and safety.

INTRAC S.p.A. is committed to ensuring compliance with social responsibility principles, focusing on key areas such as Human Rights and the promotion of Diversity.
INTRAC S.p.A. respects and promotes the fundamental human rights of all individuals working for the company (employees, suppliers, contractors, subcontractors), ensuring that they do not suffer any physical or psychological harm due to their work. Specifically:

• Child Labor: INTRAC S.p.A. does not accept or endorse child labor, except in forms permitted by national and international laws. The company is also committed to not establishing and/or terminating working relationships with any entities in the supply chain that employ child labor in violation of local regulations.
• Forced Labor: INTRAC S.p.A. rejects all forms of forced, compulsory, or bonded labor, as well as any form of physical or psychological coercion, committing never to employ such practices either directly or within its supply chain.
• Harassment: the company does not tolerate sexual, personal, or any other form of harassment or offense. It requires everyone to respect the dignity, privacy, and rights of individuals.
• Discrimination: INTRAC S.p.A. opposes any form of discrimination, defined as any distinction, exclusion, or preference that results in denying or altering equal employment or professional opportunities. The company operates without discrimination based on race, culture, ideology, gender, physical condition, morals, religion, or any other factor.
• Work relationships: INTRAC S.p.A. encourages the professional development and growth of each employee, guided by the principles of fairness and equal opportunities. It is committed to ensuring non-discrimination throughout all stages of employment (hiring, termination, training, remuneration, promotion, and transfer). The company also ensures that hiring decisions are based on candidates' skills, abilities, and knowledge, aligning with the required job profile while respecting each employee’s needs.
• Freedom of association: INTRAC S.p.A. recognizes the right of workers, without distinction and without prior authorization, to join organizations of their choice in compliance with the law. It also supports collective bargaining and constructive dialogue with trade union representatives.
• Adequate working conditions: the company promotes a work environment based on values such as trust, dialogue, mutual respect, employee well-being, and work-life balance. It ensures fair remuneration, guaranteeing the applicable national minimum wage and dignified working hours in compliance with legal limits on working hours. The company also establishes transparent and objective incentive systems with achievable goals.
• Diversity and inclusion: INTRAC S.p.A. recognizes each individual’s right to express their uniqueness and creativity at work, valuing diversity and personal characteristics as drivers of innovation and essential contributions to the company's growth.
• Health and safety at work: the company protects and promotes workers' health and safety by implementing risk prevention measures and fostering a corporate culture that complies with applicable legal requirements and additional subscribed safety and hygiene regulations. INTRAC S.p.A. continuously improves processes to minimize workplace accidents and occupational illnesses. Additionally, it requires all entities in its supply chain to adhere to the highest standards of health and safety and to comply with relevant national regulations.
• Local communities: INTRAC S.p.A. considers the expectations of local communities, contributing to their development while respecting their culture and environmental heritage.
  
  

We operate according to the principles established by current privacy legislation, respecting the rights of those concerned to the protection of their personal data. The management of the computer system aims to ensure maximum confidentiality and security of personal data that for whatever reason and/or cause are known and processed by the Company.

We are committed to raising awareness and promoting environmental protection by managing our activities sustainably and reducing their environmental impact.

Our main commitments are to:

• comply with legal requirements in environmental matters;
• continuously improve environmental performance;
• enhance the environmental awareness of all employees;
• reduce energy consumption;
• minimize unnecessary waste of resources;
• collaborate with suppliers to prevent environmental risks.
  
  We expect employees and suppliers to address environmental issues professionally, fostering the development and adoption of sustainable solutions to contribute to a more responsible society.

INTRAC S.p.A. is committed to ensuring the highest level of integrity in business activities while upholding the principles of legality, social responsibility, and environmental protection.
Working with a strong sense of integrity is crucial to maintaining our credibility and the trust of customers, partners, employees, and all stakeholders.

We ensure that everyone operating within INTRAC adheres to the principles of fairness and diligence in performing their duties. Under no circumstances can the company’s interests justify unlawful behavior by employees. For this reason, we further empower management, which must demonstrate through its actions the importance of complying with company rules.

Every employee is required to report to their superior any conduct deemed contrary to the law or the Corporate Code of Ethics. If the superior is involved in the matter or has been unable or unwilling to handle the violation properly, the employee may still report the case to the General Management and/or the Board of Directors, as well as to the Supervisory Body appointed under the organizational and management model pursuant to Legislative Decree 231/01. Reports can also be made through the reporting channels regulated by EU Directive 2019/1937.

To uphold the principles expressed, INTRAC S.p.A.:

• fosters a corporate culture based on transparency, integrity, and trust;
• involves all employees and collaborators in actively and responsibly combating illegal activities;
• removes barriers that may hinder or discourage reporting by promoting awareness of the procedures to follow.

Given the introduction of corporate administrative liability for crimes committed by senior executives or employees under the direction of others, in the interest or to the advantage of the company, INTRAC S.p.A. has adopted an organizational and management model aimed at preventing such offenses in accordance with Articles 6 and 7 of Legislative Decree 231/2001.

This Code of Ethics is therefore coordinated with and further implemented through the behavioral protocols developed within the organizational model, which must be followed by all individuals operating in areas or functions considered at risk of criminal offenses.

All suppliers of goods and services are required to comply fully with the principles of this Code of Ethics.

Relationships with third parties are managed according to principles of maximum cooperation, availability, professionalism, and transparency.

The selection of suppliers is based not only on a technical and economic evaluation of their performance but also on their full compliance with applicable legislation, as well as their integrity and reliability.

Supplier relationships are governed by contracts that protect the interests of both parties while ensuring compliance with the principles of this Code of Ethics.

The company has implemented a compliance control system to ensure adherence to the principles outlined in this Code of Ethics and the set of protocols it has adopted. The internal control system is based on continuous monitoring and a verification plan carried out by an evaluation group with expertise, independence, and impartiality.

The external control system is ensured through periodic audits conducted by third parties (Board of Statutory Auditors, External Auditors, Supervisory Body, Certification Bodies), which report directly to the Board of Directors.

Failure to comply with this Code of Ethics, its principles, or the company's protocols will result in the application of the company's sanctioning framework against violators.

The founding principles and objectives expressed in the preceding points have been stated and summarized in the company's Integrated Policy document, which is reproduced below:

"The Management of INTRAC, following a timely analysis of the context and the expectations of the stakeholders, has become aware of the impact that its activities have on the employees, the environment, the local communities and the Customers with whom it interacts. This awareness leads to assuming and declaring its Social and Environmental responsibility by ensuring that the long-term development of the organization is sustainable and reflects the values and expectations of employees, the Company, Customers and stakeholders in general.

INTRAC's Management, aware of the impact exerted by its activities on employees, the environment, local communities and the Customers with whom it interacts, has identified the main social and environmental trends likely to affect its activities in the coming years and for which it intends to play a proactive role as a responsible Company.

For this reason, INTRAC wanted to integrate into its Quality System what are also environmental objectives and those related to the protection of workers' health and safety to be achieved.

INTRAC, in managing its activities, has adopted an organization by related processes, characterized by a systematic approach to the issue of risk, identification and analysis of context factors as well as stakeholders relevant to its strategic objectives.

INTRAC establishes that its policy is documented, implemented, maintained and communicated to all personnel working on behalf of the organization, that it is regularly reviewed and updated, and that it is made publicly available on the company's website and intranet.

INTRAC, through the provision of its products and services, wants to pursue maximum customer satisfaction, respecting the expectations and rights of all parties involved, while simultaneously seeking maximum environmental efficiency and the protection of workers' health and safety.

The Management of INTRAC is committed to the implementation of the following principles:

• consider the Customer at the center of all company activities;
• monitor the quality of the product and service provided, "including" examining complaints received, recording non-conformities and implementing relevant corrective actions;
• reduce all forms of bureaucratization;
• pread a culture of quality, safety and environment among its employees by promoting responsible behavior;
• interpreting quality, respect for the environment and occupational health and safety as a personal responsibility and duty of each and every INTRAC employee and all "interested parties", depending on the achievement of the goals set by the Management;
• to define behavioral rules, with the related apparatus of sanctions, inherent in the aspects of safeguarding occupational health and safety and the environment (disciplinary regulations for Safety and the Environment) to which all persons working in the company context must adhere;
• continuously improve the integrated quality, environment and safety management system by designing and implementing innovative products and services in compliance with applicable mandatory standards while aiming to optimize productivity;
• setting measurable goals and objectives and meaningful indicators;
• comply with social, environmental, worker health and safety regulations;
• comply with other requirements subscribed to by the organization;
• prevent accidents, injuries, occupational diseases and environmental damage, including through periodic monitoring and control activities carried out by competent personnel;
• train and sensitize all company staff and those who work in it on the protection and enhancement of the environment, prevention of accidents, occupational diseases and the effects of their activities on the same, on the product and processes;
• promote synergy with suppliers in order to identify and achieve mutually beneficial common goals by requiring contractors working on behalf of the company to adopt criteria for the protection of the environment and the health and safety of workers equivalent to those of its own organization;
• containing energy consumption and waste production in all production departments;
• ensure internal communications, between the different levels and functions of the organization regarding aspects inherent to the management system by fostering the involvement and awareness of all personnel in the organization;
• ensuring external communications to provide appropriate responses to requesting third parties.