
The 2030 Sustainable Development Plan expresses the Company’s commitment and initiatives regarding material topics and sustainability challenges. The strategy is based on five priorities: contributing to climate change mitigation, promoting a circular economy, valuing and preserving human capital, developing sustainability throughout the entire value chain, and maintaining ethical and transparent governance.
The 2030 Sustainable Development Plan aligns with the United Nations Sustainable Development Goals and the principles of the OUR BRIGHT IMPACT program.
Within the 5 pillars, 10 goals have been identified, broken down into 18 targets to be achieved by 2030. Progress towards the targets is carefully monitored through a digital and integrated performance tracking system.



The Board of Directors (BoD) is at the top of the sustainability governance structure, supported by the Control, Risks, and Sustainability Committee (CRSC). The CRSC coordinates the sustainability development strategy, acting as a bridge between the BoD and the various business functions.
The Quality, Sustainability & Lean Development function manages the economic, environmental, and social impacts of the organization, working closely with other business functions. It implements concrete projects to turn sustainability goals into actions.
It regularly monitors the results of the sustainable development program and communicates them to management. In case of deviations from the goals, corrective actions are taken to align performance with the sustainability strategy.

The Group is committed to achieving global leadership by creating lasting value for stakeholders and contributing to a more sustainable future. The policies express the principles and regulatory framework

CODE OF CONDUCT
The Code of Conduct forms the foundation of the control model and highlights the principles that guide and standardize every business activity: integrity, transparency, respect, legality, and confidentiality. The Code of Conduct also defines the conduct criteria to be observed by all employees and the prohibited behaviours, with particular reference to areas of potential risk for committing offenses.

SUPPLIER CODE OF CONDUCT
To extend the Company’s ethical principles along the supply chain and implement the sustainable procurement policy, which is one of the Group’s strategic objectives, Comer Industries has developed and documented in a manual the minimum set of requirements that each supplier of components or services must meet for a solid and long-lasting partnership. All suppliers are required to sign the Code of Conduct, adhering to its principles as an integral part of their contractual obligations.
Compliance
Comer Industries operates in compliance with Regulation 1907/2006/EC (REACH) concerning the registration, evaluation, authorization and restriction of chemical substances, therefore it is continuously monitoring its products in order to assess the applicability and compliance with all the requirements of the Regulation.
For this purpose, Comer Industries has requested from all its suppliers detailed information regarding the presence of Substances of Very High Concern (SVHC) in the Candidate List with concentrations higher than 0.1% by weight on the weight of the article (w/w).
Based on this information, Comer Industries found the presence of LEAD (Pb) CAS 7439-92-1 in some articles with a concentration higher than 0.1% (w/w), in particular in some metal components such as plugs, greasers, fittings, bushings assembled in complex objects belonging to the following product families:
– Gearboxes
– Planetary drives
– Axles
– Driveshafts
Consequently, Comer Industries, as required by Directive 2018/851/EC – articles 9 (1)(i) and 9(2) – which amends Directive 2008/98 / EC, registered into SCIP Database the articles and the complex objects containing concentrations of SVHC in the Candidate List above the threshold of 0.1% (w/w).
Environmental labelling
Following the entry into force of Legislative Decree 3 September 2020, No. 116, which transposes EU Directive 2018/851 and EU Directive 2018/852 relating to packaging and packaging waste, Comer Industries and Walterscheid, as users of packaging solely for the transport of their products, prefer, in compliance with legal obligations, digital channels to communicate information relating to the environmental labeling of packaging.
In this regard, the table containing the information on the nature of the packaging materials used, on the basis of Commission decision 97/129/EC is shown.