About Intrac

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.

We ensure an unwavering commitment to ensuring the highest level of integrity in the conduct of business activities and attention to the principles of social and environmental compliance.

We work with a strong sense of integrity to maintain its credibility and the trust of Customers, partners, employees and towards all stakeholders.

We see to it that all persons operating within us adhere to the principles of fairness and diligence in the performance of their duties. Under no circumstances may the interest or advantage of the Company induce and/or justify unlawful or otherwise unlawful behavior by employees. To this end, we further hold management accountable, who must demonstrate through their actions the importance of adhering to the Company's rules.

Every employee is required to report conduct that is deemed contrary to the law or the Code of Business Ethics to his or her superior. If a superior is involved in the matter, or has been unable or unwilling to adequately handle the violation, the employee must still report the case to the General Management and/or the Board of Directors as well as to the Supervisory Board appointed under the organizational management model in accordance with Legislative Decree 231/01. In assignments undertaken on behalf of third parties, we undertake to ensure proper behavior of employees and to adhere to the instructions received as to the concrete methods of action.

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.

Application of the principles of the Code of Ethics is required of all suppliers of goods and services who must accept it in full.

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

The choice of suppliers of goods or services is based not only on an economic evaluation of the offer, but also on an analysis of the subject's reliability and technical competence. The products and/or services provided must conform to the technical requirements of our Company. In carrying out our activities, we may also use third parties on a continuous basis for the execution of certain works or the provision of certain services. In such a case, the relationships are governed by the general terms and conditions of the contract, which the third party must declare that it has read in full. These conditions expressly stipulate that said party must make use of employees, duly hired, paid according to the relevant CCNL. The third party, moreover, must provide the documentation indicated in the general conditions of the contract in order to certify its technical and professional suitability, documentation attesting to the compliance with safety regulations of the means and accident-prevention equipment used and the professional training of the personnel employed in the work, and any other information suitable for documenting compliance with the legal requirements regarding the protection of the safety and health of workers and the environment. The third party also undertakes not to divulge to anyone confidential or other information of which it has become aware in the course of the relationship.

The third party as contractor/subcontractor may neither assign the contract to a third party nor subcontract the performance of the work without written authorization from INTRAC S.p.A. In case of authorization to subcontract, the contractor shall be directly responsible for the performance of any subcontractors or any other suppliers, technicians or auxiliaries in general, as well as for the punctual compliance by the subcontractor with all the legal regulations provided for and the obligations arising from the Contract.

We contribute to the dissemination and awareness of issues related to the protection of the Environment, managing in an eco-friendlymanner the activities we carry out in compliance with current regulations, both at our headquarters and at each site where we practice business activities. We constantly strive to minimize the environmental impact of all our activities.

Our environmental objectives are to:

• comply with legal requirements in environmental matters;
• continuously improve environmental performance;
• improve the environmental awareness of all employees;
• reduce energy consumption;
• reduce unwarranted waste of resources;
• cooperate with suppliers to avoid environmental risks.

Employees and suppliers are expected to deal with environmental issues in a professional manner, contributing to the development and utilization of all opportunities in the economic sector to contribute to the creation of a more sustainable society.

We at INTRAC respect and promote the fundamental human rights of all those who work for our Company (employees, suppliers, contractors, subcontractors), who should not suffer physically or psychologically as a result of their work.

All our employees are free to peacefully and legally join associations of their choice, and have the right to collective bargaining.

We do not accept, and obviously do not prosecute, child labor except in the forms permitted by national and international laws.

No employee should be discriminated against because of his or her race, color, sex, sexual preference, marital status, pregnancy and maternity or paternity, religion, political opinion, nationality, ethnic or social origin, social status, disability, age, union membership.

Every employee must know the basic terms and conditions of his or her employment.

The highest priority must always be given to workers' health and safety in the workplace even when this, due to the nature of the services provided is temporarily exercised abroad.

We ensure the protection of safety and health in the workplace according to the following principles and criteria:

• avoid risks;
• assess risks that cannot be avoided;
• combat risks at the source;
• adapting work to people, particularly with regard to the design of workplaces and the choice of work equipment and working and production methods, especially to mitigate monotonous work and repetitive work and to reduce the effects of such work on health;
• take into account the degree of technical development;
• replace what is dangerous with what is not dangerous or is less dangerous;
• pursue prevention, aiming to establish a set of consistent standards/behaviors that integrate the best technique, organization and working conditions, and social relations;
• give priority to collective protective measures over individual protective measures;
• provide adequate and constant information, education and training of workers.

Due to the introduction in the INTRAC system of administrative liability for environmental offences and for crimes of homicide and culpable injury in the field of occupational safety committed both by top management and by persons subject to the direction of others in our interest or to our advantage, we decided to adopt the so-called organizational model suitable for preventing the commission of such offenses under Articles 6 and 7 of Legislative Decree 231/2001.

Moreover, the adopted organizational model complies with the indications contained in Article 30 of Legislative Decree 81/2008. This Code therefore coordinates with and is further implemented in the behavioral protocols drawn up within the organizational model, which must be complied with by all persons operating in the areas/functions deemed to be at risk of crime.

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.

In order to ensure the full implementation of the code of ethics, specific internal regulatory provisions have been drawn up to which all individuals operating in the corporate environment must adhere, as well as the penalty system in case of non-compliance with the same rules.

The regulations mentioned are:

• the regulation that constitutes an integral part of the model of organization ex D.Lgs. 231/2001 of which INTRAC has decided to equip itself, in order to prevent and contrast the commission, also indirect, from the c.d. subjects in position "apical" or "subordinate"in the interest or for the benefit of our Company. The regulation, in compliance with the requirements of the former D.Lgs. 231/2001, also includes the sanction apparatus (c.d. disciplinary regulation for safety);
• the Internal regulations dedicated to the rules concerning the behavior of all our employees and related sanction apparatus.  The addressees of the safety regulations are both employees of the Company and collaborators, such as agents, consultants, suppliers of goods and services, para-subordinates and self-employed persons.