Code of Ethics




I. GENERAL PART

PREMISE

Intrac S.p.A. (hereinafter also referred to as the "Company" and / or "Company") historically was formed as a brand in 1997. The origin is Arneg Spa, leader in the production of refrigerated counters for large and small distribution, commercial shelving and cold cells.

In 1997 the management understands the importance of making a differentiation of production, granting to the Company a distinct visibility. From this idea the factory INTRAC was born, whose name is the acronym of "International Rack".

Since 1999 Intrac is placed in the Rovigo plant, over an area of over 100,000 square meters of which 45,000 are covered, for production department, offices and showroom.

The production ranges from commercial shelves for each product sector, both for specialized and non-specialised sales points, to standard and customised cash desks.

The sheet metal processing plants are of advanced design, the moulding and profiling lines are among the most modern on the market, and the epoxy powder coating plant meets the most strict environmental safety regulations. 

The Company has become aware of the impact of the activities carried out by its organization on employees and collaborators, on the environment, on local communities and on the customers with whom it interacts.

This awareness has led the Company to assume and declare its commitment and its social and environmental responsibility ensuring that the long-term development of the organization is sustainable and reflects the values and expectations of employees and collaborators, of the Company, of the Customers and stakeholders in general.

Intrac has identified the main social and environmental trends likely to have effects on its activities in the coming years and for which it intends to play a proactive role as a responsible company.

For this reason Intrac has included in its integrated management system both the quality objectives and those of an environmental, energetic and protection of workers' safety and health.

The Company has started the process for obtaining the certification of its management system for Safety and Health at Work, in compliance with the OHSAS 18001 reference standard, integrating it with the part concerning product certification and constituting, for these aspects, a System of Integrated Management. This System ensures the compliance of the Company with the current regulations on safety and health at work in all production processes, as well as relations with third parties, and to start a process of continuous improvement.

Operating in accordance with the Safety and Health at Work Management System forms the basis of the Company's ethical principles.

 

1. Corporate mission.

Intrac pays special attention to the satisfaction of its Customers, and is committed to supplying top quality, highly competitive and professional products to the sector it serves.

Intrac believes that its corporate objectives can only be achieved through the correct and impartial behaviour of its employees and collaborators and through respect for legislation governing environmental protection and occupational health and safety.

 

2. Responsibility and correctness.

Intrac is constantly committed to ensuring the highest level of integrity in the execution of all Company activities and in complying with the principles of respect for the community and the environment.

Working with a strong sense of integrity is crucial to maintaining the Company’s credibility and the good faith of Customers, partners, employees and stakeholders.

Intrac takes great care to ensure that all individuals working within the organisation comply with the principles of correctness and diligence in fulfilling their roles. In no case are interests or advantages of the Company permitted to induce or justify illicit behaviour by employees, or behaviour that violates applicable law.

Intrac has given its management full responsibility for ensuring compliance with these principles and requires managers to demonstrate, through their own actions, the importance of conformity to Company rules.

Employees are required to inform their manager of conduct they believe to be in contrast with the law or with this Corporate Code of Ethics. If the manager is himself involved in such conduct, or is unable to or decides not to take action, the employee must report the matter to General Management and/or the Board of Directors, and to the Supervisory Body designated under the organisational model imposed by Legislative Decree 231/01.

Whenever Itrac undertakes work for third parties, it guarantees the correct behaviour of its employees as well as compliance with instructions received regarding working methods.

 

3. Privacy and confidentiality.

Intrac operates in accordance with the principles established by current data privacy legislation, and respects the confidentiality of individuals’ personal data. The Company’s IT system is managed in a way that ensures maximum confidentiality and security for personal data revealed to and processed by the Company for any reason and/or cause.

 

4. External relations. 

All suppliers of goods and services are required to apply the principles of this Code of Ethics and must agree to do so.

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

Suppliers of goods or services are selected not only on the basis of an economic evaluation of their offering but on the basis of an analysis of their reliability and technical competence. Products and services supplied must conform to Intrac’s technical requirements.

Intrac may use third parties to help to perform its activities, on a continuous basis for certain services or on a temporary basis for others. In either case, relations are regulated by the general conditions of supply that third parties must declare to have fully accepted. Such conditions expressly require suppliers to use only personnel who are legally employed and paid according to the relevant national labour contract. Third parties must provide Intrac with the documentation listed in the general conditions of supply to permit verification of their technical and professional suitability as well as documentation proving the conformity of the safety equipment used to applicable safety standards, documentation proving the professional qualification of the personnel involved, and all information useful to documenting respect for legislation governing occupational health and safety and environmental protection. Third parties must further refrain from divulging confidential information or data acquired during the course of the working relationship.

Contracting or sub-contracting parties may not cede their work contract to others, nor sub-contract its execution without written authorisation from Intrac S.p.A. If sub-contracting is authorised, contractors are directly responsible for the work performed by sub-contractors and all other technical or auxiliary suppliers, for the compliance of sub-contractors with all legal requirements, and for their fulfilment of all obligations deriving from the contract.

 

5. Protection of the environment.

Intrac promotes and raises awareness about themes related to environmental protection by managing activities entrusted to the Company in an ecologically compatible manner and in conformity to applicable legislation, at the Company’s own premises and at other sites where activities are carried out.

Intrac constantly strives to minimise the impact of its activities on the environment.

Intrac environmental objectives are:

  • To respect legal requirements relevant to the environment

  • To continuously improve environmental performance

  • To raise the environmental awareness of all employees

  • To reduce energy consumption 

  • To reduce unjustified wastage of resources

  • To collaborate with suppliers in order to prevent environmental risks

Employees and suppliers are required to deal with environmental aspects in a professional manner, by helping to generate and seize economic opportunities that contribute to the creation of a more sustainable society.

 

6. Workforce ethics, protection and safety.

Intrac respects and promotes the fundamental human rights of all those who work for the Company (employees, suppliers, contractors and sub-contractors), and acts to ensure that they do not suffer any physical or psychological injury through their work.

All Intrac employees are free to join peaceful and legal associations of their choosing and also have the right to negotiate collectively.

Intrac does not accept and obviously does not exploit child labour in any form other than those permitted by national and international law.

No employee must suffer discrimination as a result of race, colour, sex, sexual preferences, marital status, pregnancy, maternity or paternity, religion, political opinion, nationality, ethnic or social origin, social status, invalidity, age, or union membership.

All employees are fully informed of the terms and conditions of their employment.

Maximum priority is always given to the health of workers and to safety in the workplace, even when, because of the nature of the Company’s services, work has to be performed outside the Company.

Intrac guarantees occupational health and safety according to the following principles and criteria:

a) Avoid risks;

b) Evaluate risks that cannot be avoided;

c) Counter risks at source;

d) Adapt work to human needs, especially by designing work stations and selecting equipment and working and production methods that attenuate the monotony of repetitive jobs and reduce the effects of such jobs on workers’ health;

e) Monitor developments in technology;

f) Replace anything hazardous with non-hazardous or less hazardous alternatives;

g) Focus on risk prevention by defining a set of standards and rules to integrate best practices, the organisation of work, working conditions and social relations;

h) Prioritise collective protection measures over individual protection measures;

i) Ensure adequate and constant information, training and development of workers.

 

7. Prevention of criminal actions by representatives of the Company (Legislative Decree 231/2001).

In response to the introduction in law of corporate responsibility for offences of causing death or serious injury in the field of occupational health and safety, committed by managers or others under their control in the interests of or to the advantage of a company, Intrac S.p.A. has adopted an organisational model that prevents such crimes from being committed, in accordance with articles 6 and 7 of Legislative Decree 231/2001.

The organisational model adopted also conforms to the requirements of article 30 of Legislative Decree 81/2008.

The present Code of Ethics is therefore also managed and applied through the rules of conduct established by the organisational model, to which all persons working in areas/functions considered at risk of criminal actions must conform.

 

8. Integrated Company Policy.

The founding principles and objectives expressed above are clarified and summarised in Intrac’s Integrated Policy Document, which is reproduced below.

“As a leading international player, Intrac is well aware of the impact of its activities on employees, the environment, and the local communities and Customers with which the Company interacts.

This awareness has led Intrac to assume social and environmental responsibility and to ensure that its long terms development is sustainable and reflects the values and expectations of employees, the Company, Customers and stakeholders in general.

Intrac has identified the main social and environmental aspects that are likely to affect its activities in coming years, and for which the Company assumes responsibility.

For this reason Intrac has included in her Quality system also the objectives related to the environement and health safety for workers.

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

Intrac ensures that its Company Policy is documented, implemented, maintained and communicated to all personnel working in the name of and on behalf of the Company, and further ensures that this policy is regularly reviewed, updated and published on the Company website and corporate intranet.

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

The Intrac Management undertakes to implement the following principles:

  • to consider the customer at the centre of all company activities;

  • to monitor the quality of the product and the service provided, "even" by examining the complaints received, recording the non-conformities and implementing the relevant corrective actions;

  • to reduce all forms of bureaucratization;

  • to spread among its collaborators the culture of quality, safety and the environment, promoting responsible behaviour;

  • to interpret quality, respect for the environment and safety and health at work, as a personal responsibility and duty of each individual employee of Intrac and all the "interested parties", according to the achievement of the goals established by the Management;

  • to define behavioural rules, with the related sanctioning apparatus, concerning the aspects of safeguarding health and safety at work and the environment (disciplinary regulation for Safety and the Environment) to which all the subjects operating in the company context must comply;

  • to continually improve the integrated quality, environment and safety management system, designing and implementing innovative products and services in compliance with the applicable mandatory standards and, at the same time, aiming at optimizing productivity;

  • to define measurable objectives and targets and significant indicators;

  • to comply with the social, environmental, safety and health regulations of workers;

  • to observe the other requirements undersigned by the organization;

  • to prevent accidents, injuries, occupational diseases and environmental damage, also through periodic monitoring and control activities carried out by competent personnel;

  • to train and sensitize all the company staff and those operating in the field of protection and enhancement of the environment, prevention of accidents, occupational diseases and the effects of their activity on the product, and on the processes;

  • to promote synergy with suppliers, to identify and achieve mutually beneficial common objectives 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 their organization;

  • to minimise energy consumption and waste production in all production departments;

  • to guarantee internal communications between the various levels and the different functions of the organization regarding the aspects related to the management system, favouring the involvement and awareness of all the organization's personnel; 

  • ensure external communications to provide adequate responses to requesting third-party institutions."

 

II. SPECIAL PART

In order to ensure the full implementation of the code of ethics, specific internal regulatory provisions have been drawn up, to which all the subjects operating in the company context must abide and a system of sanctions in case of non-compliance with the same rules.

The regulations mentioned are:

  1. the Security Regulation which forms an integral part of the organizational model according  to Legislative Decree 231/2001, which the Company has decided to adopt, in order to prevent and oppose the commission, including indirect ones, by the subjects in managing  or subordinate positions, of serious and very serious crimes of murder and culpable injuries in the interest or for the benefit of the Company. The regulation for safety in compliance with the requirements of the former Legislative Decree 231/2001, also includes the sanctioning apparatus (disciplinary regulation for safety).
  2. the internal regulation dedicated to the rules concerning the behavior of all employees within the Company and its related sanctioning system.

The recipients of the security regulation are both employees of the Company and collaborators, such as agents, consultants, suppliers of goods and services, subordinate and self-employed.

 

 



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