Within this section, it is possible to read the communication notices pertaining to transactions performed by “Key Persons” and disclosed to the market by Leonardo in compliance with current regulations about Internal Dealing, governing the specific transparency regime – as well as the relevant information flows towards the market –required for transactions involving shares issued by Leonardo or other related financial instruments and carried out, even through third parties, by the Company’s "Key Persons" and by persons that are “closely related” to them.

In this regard the Company's Board of Directors has adopted, in accordance with current provisions, the specific Code of Internal Dealing, over time updated to reflect the changes in the regulatory framework and, in particular, the contents of the European Regulation about Market Abuse (EU Regulation no. 596/2014), as well as in order to align its contents with the organizational structure.

"Key Persons" currently include the members of Leonardo’s Board of Directors and Board of Statutory Auditors, as well as persons holding in the Company the office of General Manager, Co-General Manager and Officer in Charge of Financial Reporting.

Specific periods are provided in which Key Persons shall refrain from such transactions (black out periods): in particular, Key Persons are prohibited from dealing during the 30 calendar days preceding the date of the announcement of the interim results related to each fiscal year accounting period (March 31, June 30, September 30, December 31) as well as the approval of the Company's strategic-industrial plan and until the occurred disclosure of the related press release.

Updated November 10, 2025

Code of Internal Dealing Archive