Leonardo has established an Internal Compliance Program (ICP) for the Group – the Trade Compliance Program – in order to ensure full compliance with the applicable Trade Compliance laws and regulations issued by the competent authorities.
The Trade Compliance Program ensures the timely identification and fulfilment of the requirements related to the applicable national, European Union and international legislation, in particular, 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 Program 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.
2021 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:
The Trade Compliance Program includes the following core elements:
b) 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);
- Senior Compliance Officer (SCO): responsible for supervising the implementation of Internal Compliance Program (ICP), with the possibility to report potential risks or violations to the Chairman and Managing Director, as well as to the other corporate bodies and internal committees.
• Trade Compliance Officer (TCO): responsible for the management and coordination of Trade Compliance activities of Leonardo S.p.A. as well as for the coordination of the related activities of the companies of the Group. Under the responsibility of the TCO, the Organisational Unit TCD (Trade Compliance of Division) is in charge for managing the trade compliance activities of each Division and the Organisational Unit STC (Subsidiaries Trade Compliance) is in charge of the coordination and monitoring of the activities related to the implementation of the Trade Compliance Program within the Subsidiaries.
• Trade Compliance Subsidiary (TCS): responsible for managing trade compliance activities within the subsidiary ensuring the implementation of the Trade Compliance Program. In particular, the TCS of Direct and of the Strategic Subsidiaries have the responsibility for fulfilling the obligations related to the Trade Compliance Program towards STC and for coordinating the transposition of the same internal rules by the TCS of the indirectly controlled subsidiaries.