Leonardo is committed to carry out its activities in full respect of human rights, as stated in the Group’s Code of Ethics and Charter of Values, based on the principles of the United Nations’ Universal Declaration of Human Rights, the International Labour Organisation Conventions, the OECD guidelines, the Charter of Fundamental Rights of the European Union and additional relevant regulations. [...]

As per the above, Leonardo can only carry out activities in the frame set up by the applicable laws and regulations, thus the Company has established an Internal Compliance Program (ICP) for the Group – the Trade Compliance Program – in order to ensure full compliance with the applicable Trade Compliance laws and regulation. Within this program, the Human Rights Impact Assessment (HRIA) is a core element, with the purpose of assessing potential impacts for the respect of human rights of the activities carried out by the Company. Leonardo’s HRIA is carried out at both country level as well as at single transaction level covering the full range of activities in which Leonardo may be directly or indirectly involved.

[...] As a consequence for the conflict in Yemen and the related role of the Kingdom of Saudi Arabia, as you have mentioned in your inquiry, we can confirm that any activity carried out by Leonardo in either Yemen or Saudi is subject to an enhanced due diligence as part of the Monitoring of Politically Sensitive Transactions process to ensure the timely identification and fulfilment of the requirements prescribed by the applicable national, European Union and international legislation. [...]

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