Intellitronika, operating in the sector of design, development, distribution, and maintenance of software applications; provision, support, and maintenance of hardware and software through a contact center; integration of hardware and software into IT systems; provision of hosting services and hardware assembly, through the adoption and effective implementation of a Corporate Management System, is committed to pursuing the following objectives:

Quality and environment

  • Systematically implement the principles and requirements set out in the Quality and Environmental Management System documentation.
  • Understand the needs and expectations of its Customers and stakeholders and ensure that they are met.
  • Operate in compliance with environmental protection and social responsibility requirements, which constitute a fundamental part of civil life, with reference to the principles of prevention and continuous improvement.
  • Comply with laws, standards, and regulations, legal requirements, and other applicable requirements relating to the sectors in which the Company operates.
  • Increase its professionalism, improving its external image.
  • Identify risks/environmental aspects arising from its activities and their significant impact, and eliminate risks, based on knowledge acquired through technological progress, or, where this is not possible, reduce them to a minimum, preferably by acting on their root causes.
  • Monitor processes, risks/opportunities, and environmental aspects/impacts.
  • Avoid waste and unnecessary consumption of energy and natural resources, including water.
  • Whenever possible, adopt environmental criteria in the selection of packaging and consumable materials.
  • Limit waste generation, with particular reference to hazardous waste, promoting reuse, recycling, and recovery where possible.
  • Monitor and reduce CO₂ emissions into the atmosphere.
  • Adopt the best techniques and procedures for emergency prevention and control.
  • Increase awareness levels to ensure effective prevention actions.
  • Communicate environmental performance transparently to the local community, customers, and all stakeholders in order to build and strengthen trust in the activities and products/services offered.
  • pursue an open and constructive approach toward the public, Public Authorities, and stakeholders.

Anti-Corruption Prevention

In recent years, the fight against corruption has become increasingly important, and almost all countries, both at the local level and through international agreements, have promoted regulatory frameworks aimed at discouraging corrupt practices.

Intellitronika rejects and opposes all forms of corruption in the broadest sense of the term, meaning any form of abuse for private gain or misconduct, including promise, inducement, instigation, request, or offering of incentives or other benefits as a reward to a person for acting or refraining from acting, whether such actions are due or undue.

The Company has defined this “Anti-Corruption Policy” (hereinafter the “Policy”) in order to minimize the risk of engaging in active and passive corruption, committing to preventing and countering unlawful conduct in the performance of its activities, adopting among its core values that of corporate ethics, through which it promotes messages of loyalty, fairness, transparency, honesty, and integrity.

Intellitronika has established this anti-corruption policy by defining the objectives and principles it intends to follow, actively contributing to the fight against corruption and conflicts of interest. This is achieved by implementing a set of rules, elements, people, and actions:

  • Adoption and dissemination of the Code of Ethics, which expresses the principles of conduct to which all personnel and all those who have relations with the Company must adhere.
  • Adoption and dissemination of the Anti-Corruption Policy, which defines the commitment to achieving anti-corruption objectives.
  • Adoption and dissemination of the Conflict of Interest Policy, which requires the obligation for all business partners to declare any potential conflict of interest.
  • Adoption of the Model 231, which defines the set of internal organizational rules and procedures to prevent the commission of crimes, including corruption-related offenses.
  • Strengthening of the internal control system with specific measures to prevent, counter, and detect both external and internal corrupt acts.
  • Establishment of a Supervisory Body to oversee the adequacy and implementation of the organizational, management, and control model.
  • Establishment of the Anti-Corruption Function tasked with supervising and ensuring the implementation and functioning of the anti-corruption management system in all its forms.
  • Creation of a protected reporting channel to be used for any suspicion of attempted, actual, or alleged corrupt acts.
  • adoption of rules that protect and guarantee the protection of the reporting individual.
  • Training, information, and communication regarding the measures implemented by the Company, areas for improvement, and reporting tools.
  • Provision of specific sanctions for violations of the control system for the prevention and fight against corruption and of the adopted organizational model.

Objectives of the Anti-Corruption Policy

This Anti-Corruption Policy aims to achieve the following objectives:

  • Prohibit corruption and ensure the highest level of compliance with national and international anti-corruption regulations.
  • Ensure the sustainability, integrity, and transparency of its business by combating any form of misconduct.
  • Contribute to the promotion of a business culture based on loyalty, integrity, honesty, competition, and transparency as fundamental elements of work.
  • Promote and develop ethics in economic relations to safeguard the market, combating all forms of illegality.
  • Adopt the anti-corruption management system as an effective tool to combat corrupt practices, requiring continuous commitment and leadership from Management and strengthening the control system at every level of the Organization.
  • Develop and foster awareness among all stakeholders of the commitment to preventing and combating corruption.
  • Create an integrated control system that is easily understandable, implementable, and monitorable, ensuring the effectiveness and efficiency of its preventive function.
  • Promote and develop a commitment to the continuous improvement of the anti-corruption management system.
  • Recognize the need for due diligence on stakeholders in order to reduce the risk of corruption, with increasing levels of depth depending on the level of potential risk.
  • Encourage the reporting of any suspected attempted, actual, or alleged corrupt act through dedicated channels and procedures which, while respecting the protection of the Company’s reputation and image, allow, on the one hand, investigations and assessments of their validity and the implementation of effective countermeasures and, on the other hand, ensure protection for the reporting party against any form of retaliation.

Compliance Function for Anti-Corruption Prevention

Intellitronika has established and appointed a specific Compliance Function for Anti-Corruption Prevention, assigned to Attorney Patrizia Giusti, endowed with autonomous powers and resources, with the task of supervising, ensuring the implementation, and ensuring the functioning of the anti-corruption management system.

The Compliance Function for Anti-Corruption Prevention is assigned the following functions:

  • Verify the update status of the management system documentation.
  • Monitor, measure, analyze, and evaluate the performance of the system.
  • Monitor the implementation status of anti-corruption measures.
  • Assess the suitability, adequacy, and implementation of prevention measures.
  • Provide Top Management and the Governing Body with reports containing information on the performance of the management system (implementation status and effectiveness of actions taken, opportunities for improvement).
  • Receive reports of attempted, alleged, or actual corruption.
  • Send specific information to the Supervisory Body where it becomes directly aware of facts, acts, or situations relating to the risk of corruption-related offenses.
  • Evaluate reports received regarding corruption acts or violations of the anti-corruption prevention system and conduct investigations.
  • Provide guidance to organizational resources on the functioning of the management system and reporting procedures.

Gender Equality

Intellitronika recognizes gender equality as an essential element of civilization and the affirmation of universal human rights, as well as a strategic factor for increasing value creation and company development. In order to achieve and maintain gender equality within the company, Intellitronika commits management, employees, and all stakeholders to adopt practices, language, and behaviors that pursue this objective and enhance personal diversity.

To achieve this objective, Management has defined a corporate gender equality policy, committing to:

  • Apply human resource management and development practices that promote an inclusive culture of professional growth, ensuring equal opportunities for all personnel.
  • Communicate internally and externally, including through marketing and advertising activities, the commitment to pursuing gender equality, enhancing diversity, and supporting women’s empowerment, increasing awareness of women’s capabilities as well as their ability to participate in and share responsibilities equally with men and within society, freeing themselves from cultural and social assumptions and predefined roles.
  • Ensure organizational governance aimed at defining appropriate organizational safeguards and gender equality in top-level corporate leadership.
  • Implement HR processes related to the different stages of the employee lifecycle based on principles of inclusion and respect for diversity.
  • Provide opportunities for the growth and inclusion of women within the company, promoting education, training, personal development, and autonomy.
  • Ensure gender pay equity.
  • Protect parenthood and promote work-life balance.

The gender equality policy starts from gradually but rigorously reducing pay gaps and career advancement disparities that may have occurred throughout the company’s long history. Additionally, recruitment policies and plans are implemented to promote and enhance diversity in a broad sense, bringing value and new momentum to all sectors and areas of the company.

Intellitronika, always attentive to market evolution and business needs, implements a policy aimed at promoting gender equality not only internally but also by favoring relationships and business partnerships with companies and entrepreneurs equally committed to inclusion and gender equality.

In particular, to achieve these objectives, the company:

  • Commits concretely to family welfare, providing tangible support to employees’ families both economically and through flexible working hours and remote work.
  • Rejects all forms of gender-based violence and discrimination and, as stated in the Code of Ethics, does not tolerate and sanctions such behaviors and encourages reporting.
  • Supports sports activities and events aimed at promoting gender equality and inclusion.
  • Encourages participation in training sessions, webinars, and discussions for all employees regardless of role or contractual classification.
  • Promotes active policies for gender equality and inclusion through posts and publications on its website and social media.
  • Measures and reports progress in achieving gender equality.

Information Security

Intellitronika’s mission is to offer its Customers solutions and services that meet the highest international standards and applicable regulations regarding information security, in full compliance with the requirements specified by them.

In order to achieve this mission, Management considers it of fundamental importance to orient the organization toward a comprehensive approach to security management, in order to protect the information management system from events such as threats or incidents, whether external and/or internal, objective and/or subjective, which may compromise the provision of services.

The information management system has been developed in compliance with the International Standard UNI CEI EN ISO/IEC 27001:2024, with extension to ISO 27017 and ISO 27018.

This certification represents, for the Company, recognition of its commitment to the continuous improvement of the quality of these services.

In particular, Intellitronika is constantly committed to:

  • Ensure security management aimed at preserving the confidentiality, integrity, and availability of information.
  • Promote secure development and the continuous evolution of technological security solutions.
  • Comply with regulations and directives regarding data protection and information security, as well as applicable legal requirements related to its services.
  • Ensure the security, resilience, and protection of IT systems and services used and offered to customers, such as cloud and hosting services.
  • Train and inform personnel on information security and increase awareness regarding behaviors and guidelines to be followed in order to prevent threats from materializing.
  • Promote a risk-based approach in the selection of security measures to be adopted.
  • Promote continuous internal dialogue aimed at understanding internal and external factors that may affect the objectives of the Information Security Management System (ISMS).

Service Level and Business Continuity

Intellitronika recognizes the importance of ensuring the reliability and continuity of the services provided to its customers by adopting a systemic and integrated approach compliant with ISO/IEC 20000-1 Service Management System and ISO 22301 Business Continuity Management System standards. This policy establishes the commitments and strategic macro-objectives to ensure the resilience of business processes.

In particular, Intellitronika is constantly committed to:

  • Service Levels (SLA): Define, monitor, and comply with clear and measurable SLAs with customers.
  • Service Quality: Ensure availability, performance, and compliance of the services delivered.
  • Transparent Communication: Maintain ongoing dialogue with customers regarding service commitments, planned changes, and any service interruptions.
  • Risk Analysis and Management: Identify risk scenarios, threats, and vulnerabilities that may compromise business continuity.
  • Continuity and Recovery Plans: Maintain up-to-date Business Continuity and Disaster Recovery plans, testing them periodically.
  • Critical Resources: Ensure the availability of human, technological, and logistical resources required to maintain essential activities.
  • Operational Resilience: Ensure that critical processes are resilient and capable of rapidly recovering from disruptions or emergencies.
  • Awareness and Training: Regularly train personnel to ensure full understanding of procedures and behaviors to be adopted in the event of a crisis.

These objectives, in addition to being continuously monitored according to predefined frequencies, are analyzed and reviewed during Management Review meetings with the Heads of Functions and/or units of the Company.

To achieve corporate objectives, the Administrator commits to:

  • Ensure that the Corporate Policy is supported at all levels of the Company’s organization and is appropriate to the purpose, size, and context of the organization and to the specific nature of its risks and opportunities.
  • Provide the resources necessary to achieve the objectives.
  • Encourage the continuous improvement of the individual capabilities of each collaborator and employee, fostering an improved organizational climate.
  • Periodically review the Corporate Policy to ensure its ongoing suitability.
  • Ensure the dissemination of the Corporate Policy, as well as objectives and implementation programs, through the distribution of this document and the Company’s management system documentation, requiring full compliance by personnel within their respective roles and responsibilities.
Contents