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Compliance

Compliance

Leonardo Electronics US Compliance ensures the guidance, coordination, and control of the initiatives related to the areas of Trade and Business Compliance, also through the drafting and updating of internal regulatory system documents.

Trade Compliance oversees the implementation of the Trade Compliance Program, interacting with the competent authorities with respect to the import and export of defense products and dual-use goods, ensuring the performance of all national and international administrative duties.

Business Compliance ensures the performance of due diligence activities and reputational verifications with reference to the appointment of Commercial Advisors/Sales Promoters. Furthermore, it manages the relevant contractual documentation.

Through the Corporate and Divisional structures, Compliance ensures adequate control of the legal risks aimed at preventing behaviors not compliant with the rules. In coordination with the other relevant company functions, it supports the training activities leading to a constantly increasing compliance culture, contributing to the definition of an Effective Compliance Program inspired by a Zero Tolerance approach against conduct in violation of the Company values.

Compliance ensures adequate information flows in favor of the Top Management, Governing Bodies, and first-tier executives, updating periodically the Control and Risks Committee and the Board of Statutory Auditors.

 

Business Compliance

The Business Compliance Operating Unit is to ensure the application of the Guidelines and Directive in the performance of the activities related to the appointment of Sales Promoters and Commercial Advisors. The Guidelines apply to Leonardo Electronics US and must duly implement the relevant general principles and rules through the issue of specific procedures.

The company must duly implement the relevant general principles and rules through the issue of specific procedures that may diverge with respect to the Directive in a more restrictive way and/or in order to be in compliance with the relevant local laws.

The above-mentioned Guidelines, Directive, and implementing procedures have been defined on the basis of the best practices so as to ensure full compliance with applicable regulations. The Business Compliance structures carry out an accurate ethical and reputational due diligence and an enhanced risk analysis related to any appointment process.

 

 

Trade Compliance

Leonardo Electronics US has established a Trade Compliance Program – in order to ensure full compliance with the applicable Trade Compliance laws and regulations issued by the competent authorities. The Trade Compliance Program ensures the timely identification and fulfillment of the requirements related to the applicable national, European Union, and international legislation, in particular, regarding the import and export of defense, dual-use, and commercial products and services subject to export control laws and regulations as well as to embargoes, sanctions, or other trade restrictions.

In 2018, Leonardo joined the UN Global Compact, and in 2021, Leonardo was confirmed as a United Nations Global Compact Lead Company. In 2021, Leonardo has developed and implemented, in line with its policy on the respect of human rights, the “Human Right Impact Assessment” (HRIA). This tool, which is a core element of the Leonardo Trade Compliance Program, aims to identify the main risk factors related to the respect of human rights and the potential impact of the activities carried out by the Company.