Anti-Bribery Management System

In July 2018 Leonardo S.p.a. was among the first companies, in the top ten worldwide in the AD&S sector, to obtain ISO 37001:2016 “Anti-Bribery management systems” Certification, the first international standard on management systems for the prevention of corruption.

The Anti-Bribery Management System Certification is valid for three years and is subject to an annual surveillance programme conducted by an external Certification Body.

The Anti-Bribery Management System represents an organic set of tools and principles aimed at preventing and combating corruption within the Company and is based on common values and internal codes that promote a culture of ethics and legality.

Charter of Values
Code of Ethics
Anti-corruption Code
Organisation, Management and Control Model adopted pursuant to Legislative Decree 231/01
Whistleblowing Management Guidelines
Management Manual of the Anti-corruption System
 
Procedures, Directives and Instructions
 

These tools act in synergy to create a transparent and responsible corporate culture.

Leonardo's Anti-Bribery Management System has been defined according to the areas at risk of corruption to which the company is exposed, in order to prevent and fight against non-compliant conducts, in respect of the “zero tolerance” principle.

Leonardo verifies the ongoing adequacy and effectiveness of the Anti-Bribery Management System, monitoring the areas exposed to corruption risk (so-called Anti-Corruption Risk Assessment).

 

Zero tolerance against corruption

Compliance with the relevant laws, transparency, integrity, bona fide, trust and cooperation with stakeholders and zero tolerance towards corruption are the ethical principles followed by Leonardo - and which have inspired its model of conduct - in order to compete effectively and fairly in the market, improve customer satisfaction, maximise value for the benefit of its shareholders, develop the skills and promote the professional growth of its human resources.

Everyone who works in the name and on behalf of Leonardo or for its benefit is therefore committed, without distinction or exception, to observe and enforce these principles within his own function and responsibilities. The Company also requires that all the parties involved in any business dealing with Leonardo have to act in accordance with rules and methods inspired by the same values.

 

Leonardo Group Anti-Corruption Code

The Anti-Corruption Code of Leonardo Group represents a structured and consistent system of rules, inspired to principles of integrity and transparency, aimed at contrasting risks of illicit practices when conducting business activities. The Code has been approved by the Board of Directors of Leonardo on 21 April 2015, revised on 26 September 2019 and on 7 April 2022, and lastly on 12 December 2024, in order to strengthen the controls incorporated to fight and prevent corruptive practices.

Recipients of the Anti-Corruption Code are members of the Boards of Directors and Statutory Auditors (or the administrative and control bodies), employees, collaborators and anyone who has contractual relations with Leonardo or the Group Companies. No one excluded.

The Anti-Corruption Code completes the enhancement of internal controls, pursued by the Board of Directors of Leonardo, in compliance with relevant legislation and in line with the international industry best practices, with a special focus on preventing and fighting corruption.

The Coordination and Consultation Body for the Prevention of Corruption, consisting of the Chairman of Leonardo's Board of Directors and the Chairmen of the Control and Risk Committee, the Board of Statutory Auditors and the Surveillance Body of Leonardo pursuant to Legislative Decree 231/01, coordinates the offices responsible for verifying compliance with the applicable rules of conduct at Group level, and oversees the application of the Anti-Corruption Code, as well as its update.

In Leonardo Spa there is a specific Unit responsible for overseeing the Anti-Bribery Management System, monitoring its functioning, adequacy with respect to the risks and effective implementation as well as for promoting update in case of changes of the applicable law and/or the relevant internal or external factors. The Anti-Corruption Unit reports hierarchically to the Chief Compliance Officer and functionally to the Chairman, in accordance with the powers of attorney issued by the Board of Directors.

 

Training

Training is a core element for the mitigation of the Company exposure to corruption risks.

For this reason, Leonardo S.p.a. invests in:

  • Mandatory training programmes: sessions for all employees, focusing on anti-corruption, applicable legislation, and internal procedures.
  • Thematic workshops: specific meetings to focus on risk situations and best practices.
  • Awareness-raising campaigns: activities to raise awareness and train third parties to promote a corporate culture based on integrity and transparency.

Training activities are differentiated by functions and risks to which personnel is exposed and repeated periodically, according to the risks associated with the role performed and the function covered. The effectiveness of anti-corruption communications and training activities is monitored, with the support of the relevant Organizational Units, through periodic verification of the trained personnel.

 

International Conferences and Working Groups

Leonardo S.p.a. also promotes and spreads a culture of integrity at an international level. The Company actively participates in conventions, working groups and global initiatives that address the issues of compliance, anti-corruption, and ethical responsibility, contributing to the sharing of best practices in the sector.

Leonardo S.p.a. is also an active member of the International Forum on Business Ethical Conduct (IFBEC), an organisation that involves leaders in the AD&S sector to promote the highest standards of ethics and integrity in responsible business conduct.

In recent years, the Compliance Unit has been attending:

  • IFBEC International Conferences: speaking on topics such as preventing corruption and promoting effective compliance systems.
  • Roundtables: sharing best practices and innovative solutions with experts and representatives of other global companies.
  • Compliance Workshops: thematic workshops and meetings with experts to discuss international regulations, emerging risks, and process monitoring.

Leonardo also collaborates with TRACE International, an international association committed to spreading ethical values and principles and anti-corruption.

Actively participating in international conferences and working groups allows the company to: share its experience and discuss with other companies in the sector, contribute to the evolution of worldwide compliance standards and strengthen the company's ethical culture.

 

Monitoring

Continuous monitoring is a fundamental pillar. Through a structured approach, Leonardo is committed to ensuring compliance with regulations and continuous improvement of business processes.

Leonardo monitors and evaluates on an ongoing basis and with the support of the relevant Organizational Units, for their respective areas of competence, the functioning, adequacy and effective implementation of the Anti-Bribery Management System.

In order to ensure compliance with the regulations of all the countries in which Leonardo is based, a wide network of law firms located all over the world has been developed, which assist the Company, through specific legal opinions, in the knowledge and monitoring of relevant rules and regulations.

The main areas of monitoring include:

Monitoring activities are a key element in the continuous improvement of the Anti-Bribery Management System.

Press releases

19.07.2024 - 17:13
Leonardo’s anti-corruption leadership confirmed with management system certification renewal
Leonardo has been confirmed as a leading company in the fight against corruption. The company’s commitment against bribery and enhancing the related risk prevention system, in the area of global security technologies, are the main factors behind the renewal of the Anti-Corruption System Certification, which was issued by RINA, pursuant to the standard ISO 37001:2016 “Anti-bribery Management Systems”- the first international standard in the sector.

28.07.2021 - 11:00
Leonardo at the top in anti-corruption. “Anti-bribery Management Systems” certification confirmed
Leonardo has been re-certified as compliant with the ISO 37001:2016 standard, recognising the Company’s commitment to anti-corruption, its targeted risk assessment, stringent internal controls and awareness-raising campaigns

24.07.2018 - 17:30
LEONARDO IS THE 1ST COMPANY AMONG THE TOP TEN GLOBAL PLAYERS IN THE AD&S SECTOR TO OBTAIN ISO 37001:2016 "ANTI BRIBERY MANAGEMENT SYSTEMS" CERTIFICATION
Leonardo Spa is the first company among the top ten global players in the Aerospace, Defense and Security sector to obtain ISO 37001:2016 "Anti bribery management systems" certification, the first international standard for anti-corruption management systems.