Leonardo encourages anyone who becomes aware of facts or behaviours that may damage the Group, or contrary to the company’s values, codes and internal rules, law or regulations, and in particular anti-corruption laws, to make a report in the utmost confidentiality.
Reports may be about: Leonardo Group’s Directors, Officers, Employees at all levels, Members of corporate bodies, Group Companies, third parties (e.g.: suppliers, consultants, collaborators, etc.), which may cause, directly or indirectly, economic damage or harm to the Company’s image, in line with the Whistleblowing Management Guidelines.
Reports may include, but are not limited to, the following concerns:
- attempted, alleged and actual 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;
- alleged offences among those set forth by Leonardo Model 231/2001, committed by the company’s employees in the interest of or for the benefit of the Group;
- unlawful and/or fraudulent activities causing harm to customers or to the company assets;
- violations related to the safety of workers.
In order to make an effective 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, Leonardo offers the following channels to make a report:
- Website: through the dedicated platform, even anonymously
- Email: email@example.com
- Mail: Organismo di Vigilanza, Piazza Monte Grappa 4, 00195, Rome, Italy
- Fax: +39 06 45538059
Leonardo ensures protection from retaliation and other discriminatory actions for anyone who makes a report in good faith about any facts or behaviours in violation of laws and regulations, or Leonardo’s rules and Code of Ethics, or refuses to act unethically.
As part of the whistleblowing management process, Leonardo resolved to implement a dedicated online platform aimed at a more effective reporting management architecture, introducing a two-way communication tool with the whistleblowers while protecting their privacy and identity. This platform enables greater support for the phases of receipt, monitoring and repository of filed reports and allows the competent organizational units – during the preliminary investigation and verification phase – to ask the whistleblower, even if anonymous, for any clarifications or further information useful for understanding and analyzing the case. The Company provides whistleblowers with updates on the outcomes of investigations.
On a yearly basis, even if not provided by law, Group Internal Audit operational unit GIA informs the Italian National Anti-Corruption Authority (“ANAC”) in relation to whistleblowing reports concerning cases of alleged corruption. Such information is mentioned in ANAC’s whistleblowing annual reports.
Investigation system and process
The Surveillance Body (“Organismo di Vigilanza”) reviews the reports received at least on a monthly basis. The Reports Committee meets at least on a quarterly basis, and carries out a preliminary analysis of the individual reports in order to verify the need for a supplementary investigation. The Reports Committee reports semiannually on the 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 Reports Committee reports semiannually to the corporate bodies listed above on the activities performed, informing also the Coordination and Consultation Body for the Prevention of Corruption.
Leonardo assures the quality of its internal investigations by having systems in place for complaints about its investigations process through Leonardo Surveillance Body. According to Leonardo’s Whistleblowing Management Guidelines, the Surveillance Body will examine any type of concern, including complaints about the investigation process itself, since it will involve a breach of internal procedures.
Within Leonardo’s Group Internal Audit (“GIA”), the Management Audit & Whistleblowing organizational unit (o.u.) has operational responsibility for investigating whistleblowing reports. The unit is active since 2015, and is composed of a team of six experienced internal senior auditors, with different professional backgrounds (i.e. legal, tax, economics, HR and security). Within the unit, a new Analysis and Research o.u. has been established with the main tasks of performing fraud investigations and researching new auditing tools and methodologies.
As of 2016, with regard to the quality assurance of the Internal Audit activities – including the whistleblowing investigations carried out by the Management Audit & Whistleblowing o.u. –, upon request of the Control and Risk Committee and the Board of Statutory Auditors, and in compliance with IIA Standard requirements, Leonardo commenced the process to obtain the external certification on activities carried out by GIA, through an independent Quality Assurance Review. At the end of the evaluation, the external consultant expressed an overall opinion of “General Compliance” to the IIA Standards (maximum positive assessment established by the Institute of Internal Auditors) of the activities carried out by GIA. The evaluation has been presented to the Board of Directors and to the Control and Risk Committee. The External Quality Assessment Certificate issued by external consultant is valid for 5 years.
Within GIA, the Corporate Bodies Relations and Quality Assurance o.u. is entrusted with the responsibility of monitoring the Internal Audit activities – including whistleblowing investigations carried out by the Management Audit & Whistleblowing o.u. – through planning and executing an internal quality assurance plan.
Whistleblowing Management Guidelines
For additional information, please consult the Whistleblowing Management Guidelines, which define and describe the process for managing reports, even anonymous ones, establishing specific audit activities and action plans, and assuring anonymity of the whistleblower during all phases.