Leonardo Group Trade Compliance Programme

trade controls, import/export, international sanctions, monitoring of transactions with sensitive Countries and respect of human rights

Trade - Company

Leonardo has established an Internal Compliance Programme (ICP) for the Group – the Trade Compliance Programme – to ensure full compliance with the applicable Trade Compliance laws and regulations issued by the competent authorities.

The Trade Compliance Programme ensures the timely identification and fulfilment of the requirements related to the applicable national, European Union and international legislation regarding the import and export of defence, dual use and commercial products and services subject to export control laws and regulations as well as to embargoes, sanctions or other trade restrictions.

In 2018 Leonardo joined the UN Global Compact and in 2021, Leonardo was confirmed as a United Nations Global Compact Lead Company. In line with its commitments, in 2021 Leonardo has developed and implemented, in line with its policy on the respect of human rights, the Human Right Impact Assessment (HRIA). This tool, which is a core element of Leonardo Trade Compliance Programme aims at identifying the main risk factors related to the respect of human rights and the potential impact of the activities carried out by the Company.

2022 report to the Italian Chamber of Deputies Report on export, import and transit of defence products (Italian version only).

The main laws and regulations related to these matters include the following:

Directive 43/2009/EU

Topic

Transfers within the Community of defense products
Law n. 185/1990, as amended by Legislative Decree no. 105/2012

Topic

Itralian Export control rules
Missile Technology Control Regime (MTCR)

Topic

Rules for the export of missile technologies
Nuclear Suppliers Group (NSG) Guidelines

Topic

Rules for the export of nuclear technologies
Office or Foreign Assets Control (OFAC)

Topic

Sanctions programs and embargoes
Common Position of the Council 2008/944/ CFSP

Topic

Common rules for the control of exports of military technology and equipment
EU Regulation 821/2021 of the European Parlamient and of the Council of 20 May 2021

Topic

Setting up a European Union regime for the control of exports, brokering technical assistance, transit and transfer of dual-use items (recast)
ST/5470/2020/INIT of the Council of the European Union February 17, 2020

Topic

Common list of military equipment
The UK Anti-Bribery Act 2010

Topic

Active and passive bribery, bribery of foreign officials, bribery of society
The Wassenaar Arrangement (WA)

Topic

Transfers of conventional weapons and dual-use items (Convention)
UK Export Control Act 2002

Topic

UK Export Control Regime;
US Foreign Corrupt Practices Act (FCPA)

Topic

The payment of bribes to foreign officials to assist in obtaining
US Export Administration Regulations (EAR)

Topic

Items and technologies subject to the jurisdiction of the US Department of Commerce, Bureau of Industry and Security (BIS)
US International Traffic in Arms Regulations (ITAR)

Topic

Items and technologies subject to the jurisdiction of the US Department of State, Directorate of Defence Trade Controls (DDTC)
US Department of Justice Criminal Division

Topic

Evaluation of Corporate Compliance Programs (Updated June 2020)
US Department of Treasury

Topic

A Framework for OFAC Compliance Commitments (05/02/2019)

The Trade Compliance Programme includes the following core elements:

  • Governance
  • Trade Control (export, import, transit, brokering, re-export, transfer or use of defence products, dual use or certain types of commercial products if subject to restrictions)
  • Import/Export
  • Reporting

Core sections of the trade compliance programme

Search overlay background

Mobile navigation menu