Code of Conduct

Compliance with Laws

The Company’s commitment to integrity begins with compliance with laws, rules and regulations in business operations.

• Competition

  The Company makes independent pricing and marketing decisions and does not cooperate or unlawfully coordinate activities with competitors. The Company does not offer or solicit improper payments or gratuities in connection with the purchase or sale of goods or services, nor does the Company participate in or support illegal boycotts of specific customers.

• Intellectual Property

  The Company does not purchase or improperly seek to acquire competitors’ trade secrets or other proprietary or confidential information. The Company does not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

• Selective Disclosure

  The Company does not selectively disclose (whether in one-on-one or small-scale discussions, meetings, presentations, proposals or otherwise) any material non-public information regarding the Company, securities, business activities, plans, financial status, results of operations or any development plans.

• Health and Safety

  The company always strives to maintain a healthy and safe working environment.

Avoid Conflicts of Interest

The Company must avoid any relationship or activity that may impair, or even appear to impair, the ability to make objective and fair decisions in the performance of work. Employees must never use Company assets or information for personal gain or take advantage of any opportunities for themselves through position and power at the Company.

Confidential Information and Proprietary Rights

The Company protects its confidential information, as well as non-public information that its employees, customers and other business partners entrust to the Company. INTRACO does not disclose confidential and non-public information without a valid business purpose and appropriate authorization.

Create a Culture of Open and Honest Communication

Employees should feel comfortable speaking their mind, especially on issues related to ethics. It is the responsibility of the manager to create an open and supportive environment where employees feel comfortable raising such questions.

The Company investigates all reported cases of questionable or unethical behavior. In any case, where inappropriate behavior is discovered, the Company will take appropriate measures. Management does not tolerate retaliation against employees who raise genuine ethical concerns in good faith.

Use of Company Resources and Questions about Media

Company resources, including time, material, equipment and information, provided for use in the company’s business. However, occasional personal use is allowed as long as it does not affect work performance or cause disruption to the workplace.

No employee is allowed to issue press releases without permission from management

Set Metrics & Report Results Accurately

The Company ensures that all information disclosed in financial reports and public documents is complete, fair, accurate, timely and understandable. This obligation applies to all employees, including all financial executives, who have any responsibility for the preparation of such reports, including drafting, reviewing and signing or certifying information contained therein. No business objective of any kind is an excuse for misrepresentation or falsification of records.

Employees create, maintain and handle records as part of the normal course of business in accordance with all Company policies and guidelines, as well as all legal and regulatory requirements.

Action From Senior Leadership

Managers must be responsible for promptly responding to ethical questions or concerns raised by employees and taking appropriate steps to resolve them. Managers should not view employees’ ethical concerns as a threat or challenge to their authority but as a welcome alternative form of work communication.

Advocate for Substance over Form

Employees must have the courage to tackle difficult decisions and make tough choices, secure in the knowledge that the Company is committed to doing the right thing. Sometimes this means doing more than what the law requires.

Health and Safety

The company always strives to maintain a healthy and safe working environment. A safety program and countermeasures and emergency response procedures have been implemented to share with all employees regarding workplace safety.

Create Trust and Credibility

The Company’s success depends on the trust and confidence earned from employees, customers and shareholders. Trust is earned by following through on commitments, demonstrating honesty and integrity, and achieving corporate goals through honorable behavior.

Respect for Individuals

The Company is committed to creating a fair and respectful working environment that brings out the full potential in each individual, thereby directly contributing to the Company’s success.

No discrimination of any kind and no abusive, insulting or harassing behaviors are allowed in the Company.