Leonardo has established an overall program for the Group – the Trade Compliance Program – in order to ensure full compliance with the applicable laws and regulations laid down by the competent authorities in the field of Trade Compliance. The Program ensures also timely identification and fulfilment of requirements prescribed by applicable national, EU and international legislation, in particular, regarding the export and import of defence and dual use products and services, of commercial products and services subject to regulations as well as obligations related to embargoes, sanctions or other trade restrictions.
Main national and international regulations on Trade Compliance:
2018 Report on export, import and transit of defence products (Italian version only)
The Program is defined in Guidelines No. 16 dated September 20, 2016 “Trade Compliance” for the One Company and in Directive No. 5 dated December 19, 2016 “Trade Compliance” (replacing the Directive no. 21/2012 (“Trade Compliance Program”) for all the Subsidiaries.
The Guidelines and the Directive as above rules to the following activities:
a) Governance and implementation of the Trade Compliance Program;
b) Trade Control (export, import, transit, brokering, re-export, transfer or use of defence products, dual-use or certain types of commercial products subject to restrictions);
c) Import/Export.
- Senior Compliance Officer (SCO): : responsible for supervising the implementation of this Directive and the Guidelines on Trade Compliance, with the possibility to report potential risks or violations to the Chairman and Managing Director, as well as to the other bodies and internal committees
- Trade Compliance (TCO): responsible for management and coordination of Trade compliance activities of Leonardo at the One Company and Group level. As part of TCO, TCD (Trade Compliance of Division) is in charge of managing the trade compliance activities of each Division and ITC (UK/International Trade Compliance) is in charge of coordination and monitoring of Trade Compliance activities of foreign Subsidiaries.
- Trade Compliance Subsidiary (TCS): responsible for ensuring the implementation of Directive 5/2016, in particular TCS of Direct and Strategic Subsidiaries have the responsibility to act as connection with TCO/ITC and with TCS of indirect controlled subsidiaries.