In pursuing its business objectives, Leonardo Group is committed to contrast unlawful conduct both through promotion of ethical values and principles and through the actual implementation of rules of conduct and control processes, in line with the requirements set forth by the applicable laws and with the best international practices.

In compliance with applicable whistleblowing legislation, the Whistleblowing Management Guidelines provide a common framework throughout Leonardo Group on the procedures and conditions for filing internal reports, as well as on the channel, procedures and conditions for filing external reports.

In this regard, the Internal Reporting Channel has been identified in the Whistleblowing Platform and the Office in charge of carrying out the investigation activities, in the Management Audit & Whistleblowing O.U. operating within the Group Internal Audit O.U. of Leonardo S.p.a.

Leonardo, therefore, encourages anyone who becomes aware of violations (behaviors, acts or omissions) of laws or internal company protocols that are, even potentially, detrimental to the public interest or to the integrity of the Group, to file a whistleblowing report through the Whistleblowing Platform [it is suggested to open the link through the Google Chrome or Microsoft Edge browser].

The Whistleblowing Platform is a dedicated IT tool that uses an encryption system to ensure the confidentiality of the identity of the whistleblower, the person concerned, the person mentioned in the report, as well as the content of the report and of the relevant documentation, allowing the competent office to communicate with the whistleblower by providing an acknowledgement of receipt of the report and feedback on the action taken or intended to be taken.

Whistleblowing reports can be submitted via the Whistleblowing Platform, either in written or oral form. For the latter, the whistleblower may alternatively attach an audio file or request a face-to-face meeting with the competent office.

Anyone receiving a whistleblowing report outside the Internal Reporting Channel (Whistleblowing Platform), shall forward it as soon as possible, and in any case within 7 days of receipt, to the Management Audit & Whistleblowing O.U., in the original version, including any attachments, and in the strictest confidentiality.

In order to allow a better investigation of a whistleblowing report, the whistleblower should provide, in good faith, all useful information, including, where available, supporting documentary evidence.

Whistleblowing reports may include, but are not limited to, the following topics:

• administrative, accounting, civil and/or criminal offences;
• unlawful conduct relevant under Italian Legislative Decree 231/01;
• breaches of Leonardo Group Code of Ethics, Anti-Corruption Code, Organization, Management and Control Model pursuant to Italian Legislative Decree 231/01, provisions of the Compliance Programs of foreign Group companies, and internal procedures;
• offences falling within the scope of EU or national acts relating to the following areas: public procurement; financial services, products and markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; environmental protection; radiation and nuclear safety; safety of food and animal feeds and animal health and welfare; public health; consumer protection; privacy and personal data protection and security of networks and information systems;
• acts or omissions affecting the financial interests of the European Union;
• acts or omissions relating to the internal market.

Leonardo ensures protection against any act of retaliation against the whistleblower for reasons related, directly or indirectly, to his/her whistleblowing report made in good faith. In any case, in order to protect the dignity, honor and reputation of everyone, Leonardo also undertakes to offer maximum protection against defamatory reports.

For more information on the procedures and conditions for filing a whistleblowing report, please consult the Whistleblowing Management Guidelines.