Based on trust
Whistleblowing management

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 employees, members of corporate bodies, Group companies, and third parties (e.g.: suppliers, consultants, collaborators, customers and intermediaries).
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, 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 employees.

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 and anonymity of the whistleblower, Leonardo offers the following channels to make a report: 

According to the Italian legislation on whistleblowing (Law n. 179, November 30, 2017), 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.

The Surveillance Body (Organismo di Vigilanza) reviews the reports received on a monthly basis. The Reports Committee meets 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.

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 will enable greater support for the phases of receipt, monitoring and repository of filed reports. The system will inform the whistleblower about the report-processing phases (acknowledgement of receipt/investigation in progress/investigation completed) and will allow 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.

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.