Whistleblowing Platform


What is whistleblowing?

Whistleblowing is about raising concerns relating to violations (behaviours, acts or omissions) of laws or company protocols, which damage the public interest or the integrity of Leonardo Group, through the filing of an internal report (written or oral).

When is it appropriate to file a report?

In order to promote the culture of transparency and correctness in the company context and in daily operations, Leonardo Group encourages anyone who becomes aware of violations (behaviours, acts or omissions) of laws or company protocols, even potentially harmful to the interests public or the integrity of the Group, to file a report in good faith via the Internal Reporting Channel (Whistleblowing Platform).

How is whistleblowing regulated within Leonardo Group?

In compliance with current legislation on the protection of whistleblowers, the Leonardo Group Whistleblowing Management Guidelines set forth the whistleblowing management process for the Group. In particular, the Guidelines establish both protection of the confidentiality of the identity of the whistleblower, of the person involved or otherwise mentioned in the report and protection from any act of retaliation, direct or indirect, against the whistleblower for reasons related, directly or indirectly, to the report.

Who can report?

Pursuant to the current regulatory framework, the whistleblower is the individual who reports violations known within his/her work context, and in particular:

Can I submit a report anonymously?

Yes, you can report anonymously through the Whistleblowing Platform. Anonymous reports fall within the scope of “Ordinary Reports”, as better described in Leonardo Group Whistleblowing Management Guidelines.

Can a report be oral?

Reports can be submitted both in written and oral form. For oral reports, the whistleblower shall, alternatively, attach an audio file or request a direct meeting with the Office of Internal Investigations through the Whistleblowing Platform.

What types of violations can I report?

The following violations may be reported:

What kind of evidence do I need to file a report? In order to facilitate an effective investigation, whistleblowing reports must include information or evidence to support a reasonable belief that misconduct, or violation of law (or of internal protocols), occurred. For example:

Who investigates whistleblowing reports?

Whistleblowing reports are investigated by the Management Audit & Whistleblowing O.U., incorporated within the Group Internal Audit O.U. (GIA) of Leonardo S.p.a., acting as the dedicated Office of Internal Investigations pursuant to Sections 4 and 5 of the Italian Legislative Decree 24/23. Some phases of the investigation process are shared with collegial bodies of Leonardo Group (i.e., Supervisory Body / Monitoring Body and Whistleblowing Committee). In particular, the Supervisory Body of the involved Group Company governed by Italian law (or the Monitoring Body of the involved Group Company governed by foreign law), on the basis of a preliminary investigation carried out by the Office of Internal Investigations, decides whether to dismiss the report or to request further investigations; the Whistleblowing Committee, among other things, on the basis of the investigation report, evaluates the adequacy of the results of the investigations carried out, identifying any corrective and/or improvement actions to be implemented.

How is the confidentiality of the identity of the whistleblower guaranteed?

n order to protect and guarantee the confidentiality of the whistleblower’s identity as well as any other information from which such identity can be inferred, directly or indirectly, Leonardo ensures discretion and confidentiality along the entire investigation process. The same forms of protection are also guaranteed in favour of the person involved. Furthermore, the Whistleblowing Platform is an IT tool that, also thanks to an encryption system, guarantees the confidentiality of the whistleblower’s identity, the person involved, and the person mentioned in the report, as well as the content of the report and the related documentation.

As a whistleblower, will I be protected from retaliation?

Leonardo Group guarantees protection from any retaliation, discrimination, or penalisation, direct or indirect, against the whistleblower for reasons connected, directly or indirectly, to the report.

What can happen if I defame someone?

Defamatory reports are not allowed and are censored. In this regard, when the criminal liability of the whistleblower for the crimes of libel or slander or his civil liability, for the same reason, in cases of wilful misconduct or gross negligence is ascertained by a sentence, even if not definitive, of the first degree, the protections from retaliation do not apply and a disciplinary measure is imposed on the whistleblower.