Based on trust
Management of whistleblowing reports

Leonardo encourages anyone who becomes aware of facts or behaviors contrary to the company’s codes and internal rules, laws or regulations, to make a report in the utmost confidentiality.

Reports may be about employees at all levels, members of corporate bodies, Leonardo Group’s companies, and third parties (e.g.: suppliers, consultants, collaborators, etc.).

As an example, whistleblowing reports may include, but are not limited to, the following topics:

  • acts of bribery put in place directly, indirectly or solicited by third parties (e.g.: suppliers, consultants, collaborators, customers and intermediaries);
  • conflicts of interest or other violations of the Code of Ethics;
  • unlawful acts among those set forth by Leonardo’s Model 231, committed by the company’s employees in the interest of, or for the benefit of, Leonardo Group;
  • unlawful and/or fraudulent activities causing harm to customers or to the company assets;
  • unlawful acts relating to the safety of employees.

In order to file an effective whistleblowing report, allowing the competent organizational units to investigate satisfactorily on the reported concerns, it is necessary to provide accurate and reliable facts, producing documentary evidence, if available.   

Assuring confidentiality of the whistleblower’s identity, Leonardo offers the following channels to file a report: 

Leonardo ensures protection from retaliation and other discriminatory actions against the whistleblower for reasons related, directly or indirectly, to the contents of her/his filed report.

In order to protect everyone’s dignity, honor and reputation, Leonardo is committed to offer maximum protection from defamatory whistleblowing reports.

Leonardo implemented an online platform dedicated to the management of whistleblowing reports, introducing a two-way communication system with the whistleblowers, while protecting their privacy, identity or anonymity. The online platform enables greater support for the phases of receipt, monitoring and repository of filed reports. The system registers the report-processing phases and allows the competent organizational units to request – during the preliminary investigation and verification phase – the whistleblower, even if anonymous, for any clarifications or further information useful for understanding and analyzing the case. Through the platform, it is also possible to provide the whistleblowers with updates on the outcomes of investigations.

On a yearly basis, Leonardo spontaneously informs the Italian National Anti-Corruption Authority (“ANAC”) in relation to whistleblowing reports concerning cases of alleged corruption. ANAC illustrates such data in its whistleblowing annual reports.

 

Internal investigation system


The Surveillance Body of Leonardo, or other Group’s Company, reviews filed whistleblowing reports, and if they appear prima facie credible, it transmits them to Leonardo’s Whistleblowing Committee for a preliminary analysis. Afterwards, when supplementary investigation is needs, the Whistleblowing Committee may ask for support to the Organizational Unit Group Internal Audit (“U.O. GIA”) or the O.U. Security. The Committee reports semiannually on the whistleblowing investigation activities performed to the following corporate bodies: the Board of Directors, the Control and Risks Committee, the Board of Statutory Auditors and the Surveillance Body. In addition, with regard to those reports involving a risk of corruption, the Whistleblowing Committee informs semiannually the Coordination and Consultation Body for the Prevention of Corruption, in relation to the investigation activities performed.

Within the O.U. GIA, the O.U. Management Audit & Whistleblowing has operational responsibility for investigating reports assigned by Leonardo’s Whistleblowing Committee. The unit is active since 2015 and composed of a team of Internal Auditors with different professional backgrounds (i.e. legal, tax, economics, HR and security). Within the unit, a new O.U. Analysis and Research has been established with the main task of performing fraud investigations and researching new auditing tools and methodologies.

With regard to the quality assurance of the Internal Audit activities carried out by the O.U. GIA, and in compliance with the Institute of Internal Auditors (IIA) Standards, as of 2016, Leonardo has commenced a process to obtain an independent Quality Assurance Review. At the end of its evaluation, the external consultant released a quality certificate (valid for 5 years) expressing an overall opinion of “General Compliance” of the Internal Audit activities. 

In addition, within the O.U. GIA, the O.U. Corporate Bodies Relations and Quality Assurance is responsible for monitoring the Internal Audit activities through planning and executing an internal quality assurance plan. Consequently, with the main duty of pursuing and maintaining continuous improvement of the Internal Audit activities, the Quality Assurance and Improvement Program (established by IIA Standard 1300) is presented annually to the Controls and Risks Committee.

 

Whistleblowing Management Guidelines


For additional information, please refer to the Whistleblowing Management Guidelines, which define and describe Leonardo’s whistleblowing management system, establishing specific activities and action plans.