Compliance

Leonardo Compliance ensures the guidance, coordination and control of the initiatives related to the areas of Trade and Business Compliance, also through the drafting and updating of internal regulatory system documents. 

Trade Compliance oversees the implementation of the Trade Compliance Program interacting with the competent authorities with respect to the import and export of defence products and dual-use goods ensuring the performance of all national and international administrative duties.

Business Compliance ensures the performance of due diligence activities and reputational verifications with reference to the appointment of Commercial Advisors/Sales Promoters. Furthermore, it manages the relevant contractual documentation.

Through the Corporate and Divisional structures, Compliance ensures an adequate control of the legal risks, aimed at preventing behaviours not compliant to the rules.  In coordination with the other relevant  company functions, it supports the training activities leading to a constant increasing compliance culture, contributing to the definition of an Effective Compliance Program inspired to a Zero Tolerance approach against conducts in violation of the Company values.
Compliance ensures adequate information flows in favour of the Top Management,  Governing Bodies and first tier executives, updating periodically the Control and Risks Committee and the Board of Statutory Auditors.

The Compliance Council constitutes one of the pillars of Leonardo Compliance Programme. Its main objective is to promote a corporate culture founded on the observance of the rules and on the Company’s values. Compliance with the law, transparency and correct management conduct, good faith, trust and cooperation with the stakeholders are crucial to compete efficiently and fairly in the market.

This event is held annually and involves the Top Management of the company, the first-level management and the key-persons and represents an essential occasion of exchange of views among the company’s different realities and to raise awareness of employees about the risks in conducting business. 

The involvement of subject matter experts and representatives of the Institutions characterizes the Council as a training experience, focused on the relevant national and international rules and the best practices. 

Compliance Council 2019
 

On October 30^th 2019 the fourth edition of the Compliance Council, focusing on “Integrity in Business”, was held in Rome. 
“Integrity in Business”, one of the eight Values of the Leonardo skillset - namely the Leonardo Leadership Framework -, was the common link of all the sessions held: five divisional sessions (from 7^th to 18^th October), an international workshop dedicated to the Group Subsidiaries (29^th October) and the final institutional event. The internal and external speakers discussed how it is a fundamental part of the way in which we develop sustainable values in the long run. 

1,100 employees from Leonardo and its Group companies, as well as Joint Ventures representatives, from 15 countries, were involved in the initiative representing the following organizational functions: Marketing & Sales, Offset, Procurement and Supply Chain, Operations, Customer Support, Lines of Business, Administration, Finance and Control, Internal Audit, Competitive Analysis and Strategies, Legal, Corporate Affairs, Compliance, Criminal Law and Anti-corruption and Risk Management.  

External experts from Academia, Courts and Institutions provided high level contributions during the Compliance Council’s sessions, representing case studies and best practices.

Anti-corruption legislative aspects and concrete risk situations were discussed during all the sessions.

The main objective was to raise employees' awareness on the observance of rules to manage business in a sustainable manner, preventing reputational risks. The innovative approach adopted in the 2019 Compliance Council aimed to promote the importance of effective actions and transparency, as well as the need to share both business and managerial objectives at Group level.

Through a bottom-up process the Heads of Divisions defined a Management Action, one for each Division, to better explain the concept of Business Integrity by means of operational and managerial processes.

Furthermore, a new contest involving employees at Group level was launched to promote ethical behaviours and discourage corruption: nine Integrity Actions, proposed by five Divisions and four Leonardo Subsidiaries/Joint Ventures, competed during the Compliance Council and were voted by on-line survey, open to all Group employees. A high level Leonardo Committee (composed of Chairman of the BoD, CEO, Group General Counsel, Chief People, Organization & Transformation Officer, Chairman of the Supervisory Body, Chairman of the Control and Risks Committee, Chairman of the Board of Statutory Auditors and Communications Officer) chose the winning Integrity Action among the three finalists proposed by Telespazio, Electronics and Helicopters Divisions. 
On 9^th December 2019, in occasion of the International Anti-Corruption Day, the winning Integrity Action was announced: “Bridging generations in integrity”, presented by the Joint Venture Telespazio. The winning team was rewarded by the Chairman and  CEO of Leonardo during a dedicated ceremony in December 2019.
The winning Integrity Action will be implemented during 2020 throughout the Group.