Leonardo

Reference: page 66

The Board of Directors examines and approves the Group's strategic and industrial plans, monitors implementation, and sets the risk level compatible with the Company's strategic objectives, taking into account long-term value generation. Assisted by the Sustainability and Innovation Committee (five non-executive directors, mostly independent) and the Control and Risks Committee (also five non-executive directors, mostly independent), the Board promotes the integration of sustainability into strategy and business, supervises the double materiality analysis, and sets sustainability guidelines. The Sustainability and Innovation Committee assesses whether Sustainability Plan objectives have been pursued and monitors ESG ratings positioning; the Control and Risks Committee assesses risk management adequacy and, jointly with the Sustainability and Innovation Committee, examines periodic non-financial reporting. The Board of Statutory Auditors oversees compliance with the CSS reporting standards.

Reference: page 67

In 2025, during the meetings of the Sustainability and Innovation Committee, the Board addressed issues related to the sustainability strategy and the Sustainability Plan 2025-2029, the progress of sustainability projects and goals, and the Group's decarbonisation strategy. The Committee also reviewed the overall approach, completeness and transparency of the Consolidated Sustainability Statement (CSS), and monitored the double materiality process, receiving detailed information and disclosures on outcomes and on the impacts, risks and opportunities relevant to Leonardo. Separately, the Board received an update on the development of the Strategic Plan, including business-development issues related to information security and cyber security. Preparation of the CSS itself is managed under the responsibility of the Chief Financial Officer, who acts as the officer in charge of financial reporting under Legislative Decree 125/2024.

Reference: page 67

Long-term remuneration of the CEO and General Manager and of Top Management, approved by the Board, is 10% linked to reduction of Scope 1 and 2 (market-based) CO2 emission intensity on revenues and to the increased hiring of women with STEM degrees, with two payout ranges (50% minimum target, 100% full target). Short-term remuneration is a further 10% dependent on Leonardo's inclusion in the Dow Jones Best-in-Class Indices and the accident frequency index (on/off payout). The Short-Term Incentive Plan (MBO) covers about 1,200 Group executives; the Long-Term Incentive Plan covers about 250. Middle managers in Italy have been assigned a bonus target since 2021. In 2025: inclusion in the Dow Jones index was confirmed, injury rate was 1.93, Scope 1+2 (location-based) CO2 intensity/revenues was 19.13 (2024: 22.6), and Scope 1+2 (market-based) intensity was 12.2. The 2025 Shareholders' Meeting cast 97.7% favourable votes on Remuneration Policy; the CEO-to-median-employee remuneration ratio is 40x.

Reference: page 68

Leonardo's sustainability due diligence process is rooted in the Group's double materiality analysis. Requirements for due diligence and risk management are integrated into business processes through company policies, directives and procedures, with specific due diligence carried out on promoters and consultants, associations, collaboration agreements, suppliers (including conflict minerals) and potential customers and end-users. In view of the future implementation of the Corporate Sustainability Due Diligence Directive, a process is under way to strengthen corporate procedures on environmental and human-rights due diligence. A mapping table between the elements of the duty of care and the CSS disclosures on Leonardo's due diligence process is provided in the Annex to the Report on Operations. Human rights principles are set out in the Code of Ethics, the Charter of Values, the Group Policy on Human Rights, the Supplier Code of Conduct and the Diversity, Equity and Inclusion Policy; people management, supplier relations, and sale/distribution of products were identified via an ISO 26000-based analysis as the areas most exposed to human-rights risk.

Reference: page 69

Leonardo identifies and updates, on a periodic basis, the risks related to the process of preparing the CSS, measuring them in terms of impact and probability. The Company has adopted an Internal Control System on sustainability information, with ad hoc documents developed for the Group's main Divisions and legal entities describing the operational methods of sustainability data collection and formalising the inherent checks needed to ensure process robustness. The Internal Audit function, on request of the officer in charge of financial reporting, subjects these checks to annual testing, with outcomes and any related action plan shared with the Board Control and Risks Committee. This internal-control model over sustainability data is cited by Leonardo as among the factors that enabled it, as one of the first companies in Italy, to obtain reasonable assurance on its strategic sustainability KPIs.

Reference: page 71

Leonardo is a global industrial group in Aerospace, Defence & Security operating in 150 countries, organised into five business areas: Defence Electronics and Security, Helicopters, Aeronautics, Cyber Security Solutions and Space. In 2025 the Group reported revenues of €19.5 billion, new orders of €23.8 billion, EBITA of €1.75 billion, a backlog of €46.6 billion, R&D spend of about €3 billion and 62,762 employees (Group Profile, page 9). Revenue by sector splits across Defence Electronics and Security, Helicopters, Aeronautics, Cyber & Security Solutions and Space; 81% of revenue is defence-related and 71% governmental (page 10). The business-model overview (page 11) sets out the Group's capitals (people and skills, financial resources, technologies and IP, industrial assets, relations and collaborations, energy and natural resources) and links them to R&D, operations and customer-support activities. SBM-1 itself cross-refers readers to the Group Profile and Business Review chapters for the full description of business model, value chain, markets and financial performance.

Reference: page 71

Continuous engagement with internal and external, domestic and international stakeholders is a core element of Leonardo's strategy to create shared value, through organisational units established to understand stakeholder interests and expectations. A detailed stakeholder table (page 72) sets out ways of engagement, purposes and example results for employees, trade unions, suppliers, business partners, industrial associations, customers, financial stakeholders, international organisations/NGOs, traditional and digital media, and universities/schools/research institutes. Stakeholder opinions emerging from the process of defining material topics are brought to the Sustainability and Innovation Committee during the annual sharing of double-materiality outcomes. In 2025, membership fees for trade associations, industry bodies and think tanks totalled approximately €5.4 million, with the largest contributions to Confindustria (€2.5 million), AIAD (€1.19 million) and GAMA (€198K). Key 2025 engagement activities included the UN Global Compact, Valore D, ASD, CSR Europe and chairing the IAEG Board of Directors (page 73).

Reference: page 76

Leonardo's double materiality analysis identified 15 material topics grouped under the pillars Governance, Planet, People and Prosperity: business integrity/compliance/anti-corruption, climate change, cyber security & resilience and data protection, diversity/equity/inclusion, environmental impact of material use and circularity, global security, health and safety, natural resource management and biodiversity, protection of human rights, R&D/innovation/advanced technologies, skills development/talent attraction/employee wellbeing, solutions' quality/safety/performance, sustainable supply chain, value creator for society, and ESG-related competitiveness and market risks. The table on pages 77-80 sets out, for each topic, one or more actual or potential impacts (positive or negative) and financial risks or opportunities, each tagged with value chain location, time horizon and the ESRS standard(s) affected (E1-E5, S1-S4, G1 or entity-specific). Skills development, global security and climate change are flagged as the most relevant issues, with cyber security, resilience and data protection also a priority. Full IRO-level detail is in the site's IRO analysis for this company-year.

Reference: page 74

Leonardo's double materiality combines impact materiality (an inside-out view of the Group's main impacts on the environment, society and governance, along the value chain) with financial materiality (an outside-in view of ESG risks and opportunities affecting the Group's objectives). Both follow a three-step process of identification, assessment and prioritisation. Impact materiality drew on regulatory and policy requirements, prior-year impacts, peer benchmarking, the Business Plan and AI-based data analysis; the 29 impacts identified in 2024 were confirmed unchanged for 2025, and impact materiality itself was deemed unchanged. Financial materiality was updated through the Company's Enterprise Risk Management process, starting from 31 identified ESG risk/opportunity drivers, with Process Owners and Risk Owners of divisions and head-office functions assessing risks and treatment actions. Impact materiality confirmed 14 material topics; financial materiality identified 13; combined, this produced Leonardo's final list of 14 material topics, shared with the Sustainability and Innovation Committee and approved by the CEO. Climate-specific risk identification and scenario analysis is also presented under E1-2 (2025 ESRS numbering).

Reference: page 75

A reconciliation table between the information provided in the Consolidated Sustainability Statement and the disclosure requirements of the ESRS reported on by Leonardo, including individual datapoints required by other EU legislation under Appendix B of ESRS 2, is provided in the "Annex to the Report on Operations - Note of the CSS - Index of ESRS contents" (ESRS Content Index, pages 337-352). The CSS is prepared under Legislative Decree 125/2024, transposing the CSRD in Italy, and forms an integral part of the Report on Operations pursuant to Article 4 of the Decree. Leonardo notes that its decision to adopt an integrated Report anticipated the CSRD's own requirement for companies to publish sustainability disclosures in the Report on Operations starting with reports issued in 2025.

Reference: page 85

Leonardo's climate strategy is aligned with the Industrial Plan and Sustainability Plan and is approved by the Board of Directors, supported since 2025 by the Climate and Environmental Steering Committee (evolved from the SBTi Steering Committee and Supplier Engagement IPT), chaired by the CEO with top management and divisional/geographic front lines. Three SBTi-validated targets anchor the plan: a 53% reduction in Scope 1+2 market-based emissions by 2030 vs 2020 (82% progress to target in 2025), 58% of Scope 3 Cat.1&2 suppliers with science-based targets by 2028 (78% progress), and a 52% reduction in Scope 3 Cat.3-8&11 emissions per equivalent flight hour by 2030 vs 2020 (28% progress) (page 93). Scope 1+2 (market-based) levers rest on four pillars - energy efficiency, energy-transformation-plant efficiency, energy-mix rebalancing and other projects - detailed under E1-3. Locked-in emissions are not yet quantified: Leonardo states it is "currently evaluating and aligning its in-house methodologies and data collection practices" to meet the ESRS requirement. Leonardo is not excluded from the EU Paris-Aligned Benchmarks.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and the E1 climate-DMA section, where this content is disclosed in the FY2025 report (pages 86-87). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Leonardo assesses physical risk through scenario analysis using two SSP-RCP pathways: RCP 8.5 ("business-as-usual", +3.3 to +4.5°C) and RCP 2.6 (accelerated transition, +1.5 to +2.0°C). Sixty-one priority sites, covering over 80% of Group employees, were screened against eight hazards (heat waves, floods, drought, fires and other extreme events); heat waves and flooding emerged as the most significant, the latter as the main source of potential economic loss, driving enhanced insurance cover, a structured Climate Risk Analysis programme and building-design guidelines (page 86).

Transition risk and opportunity were assessed, mostly qualitatively, against three IEA scenarios: NZE 2050 (most ambitious), APS (announced pledges) and STEPS (stated policies only) across Policy & Legal, Technology, Market and Reputation categories (pages 86-87). No global-average-temperature-projection figure per scenario is disclosed. The analysis is not dated to a specific year within the narrative beyond the 2025 reporting period, and no explicit statement of scenario-analysis update frequency is given.

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 and the E1 "Managing impacts, risks and opportunities" section, where this content is disclosed in the FY2025 report (page 86). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Leonardo does not describe a discrete, ESRS-defined resilience analysis distinct from its physical- and transition-risk scenario work. The scenario analysis is presented as informing resilience directly: "This comparison made it possible to assess how increasingly intense physical phenomena and more or less rapid transition policies could affect operational continuity, people's safety and the resilience of company assets" (page 86).

Capacity to adjust is described qualitatively: in response to physical-risk findings (heat waves and flooding as the dominant threats), Leonardo has defined "a comprehensive set of responses and mitigation measures, including enhanced insurance plans; the extension of a structured Climate Risk Analysis programme aimed at ensuring continuous monitoring of physical risks; and the adoption of guidelines for the design and adaptation of buildings and facilities" (page 86). For transition risk, key levers include SBTi-aligned decarbonisation targets and supplier engagement (page 87). No areas of significant uncertainty are separately flagged, and no resilience-refresh frequency is stated.

Reference: page 81

Leonardo does not name a single standalone climate change policy in the sustainability management policies table; climate change and decarbonisation is addressed within the overarching HSE Policy and the Energy Policy, both approved at CEO/Board-of-Directors level. The HSE Policy commits the Group to reducing energy consumption, pursuing continuous environmental-performance improvement, and minimising and controlling climate-changing gas emissions, including through eco-design and life-cycle assessment from the design phase. The Energy Policy commits Leonardo to a centralised energy-governance model spreading a corporate energy-aware culture, compliance with laws and regulations, a standardised analysis and management model, consumption- and emission-reduction targets, centralised investment management, performance monitoring and staff training. Implementation responsibility sits with Managing Directors, Business Unit heads and subsidiary CEOs identified by the Board (page 85). Policy links to remuneration and ISO 50001 certification of six production sites are set out under E1-1 and GOV-3.

Reference: page 88

Scope 1+2 reduction rests on four pillars: energy efficiency (the Full Potential Lighting Programme, roughly €31 million total investment, about €1.8 million in 2025); energy-transformation-plant efficiency (the new Vergiate thermal plant, completed in 2025 and operational in 2026, expected to cut gas consumption by about 900,000 m³/year); energy self-production (19 PV agreements totalling about 43 MWp contracted, 14.8 MWp installed by end-2025, enabling roughly 11,400 MWh of self-consumption in 2025); and energy-mix rebalancing (86% of purchased electricity covered by Guarantees of Origin, plus SAF-compatible testing and acceptance flights). Scope 3 actions cover supplier engagement toward the SBTi supplier target, product decarbonisation (virtualisation via VxR/MITHOS simulators, SAF-compatible helicopters, hybrid-electric propulsion research under Clean Aviation), and other levers including sustainable-mobility plans at 38 Italian sites and logistics consolidation (a 6-point rise in shipment-consolidation rate versus 2024) (pages 88-90).

Reference: page 92

Three SBTi-validated near-term targets structure Leonardo's climate targets: a 53% reduction in absolute Scope 1+2 market-based GHG emissions by 2030 from a 2020 baseline (82% progress to target in 2025); 58% of suppliers by Scope 3 Cat.1&2 emissions holding science-based targets by 2028 (78% progress); and a 52% reduction in Scope 3 Cat.3-8&11 emissions per equivalent flight hour by 2030 from 2020 (28% progress). The two Scope 3 targets are designed to cover at least 67% of Leonardo's total Scope 3 emissions. Beyond the SBTi roadmap, Leonardo UK is separately committed to Net Zero by 2050 across its value chain under its Carbon Reduction Plan. Two additional targets were set during 2025 following achievement of the electricity-withdrawal-reduction objective: a further target to increase renewable electricity share (page 93).

Reference: page 93

Total energy consumption was 5,427 TJ in 2025 (+0.93% vs 2024), of which 39% from renewable sources; energy intensity fell to 0.28 MJ/€ (-6% vs 2024). By source: natural gas 47%, purchased electricity 44%, other sources (including self-generated electricity) 9%; 86% of purchased electricity came from renewable sources. Electricity purchased was 2,398 TJ (666 GWh, +1.85%); natural gas 2,520 TJ (70.5 million m³, +2%); other sources 509 TJ (+9%). The E1-5 datapoint table (page 94) reports total energy consumption of 1,507,498 MWh in 2025 (2024: 1,493,670 MWh), with fossil sources at 61.3% (2024: 60.1%) and renewables at 38.7% (2024: 39.6%); energy intensity was 77 MWh/M€ (2024: 84). Fuel consumption from coal was zero; from crude oil and petroleum products, 79,952 MWh; from natural gas, 699,931 MWh. This DR is within the scope of EY's reasonable-assurance engagement on selected KPIs.

Reference: page 95

Gross Scope 1 emissions were 185,262 tCO2e in 2025 (2024: 185,446), of which 63% from regulated ETS installations (2024: 56%). Gross location-based Scope 2 was 187,839 tCO2e (2024: 216,386); market-based Scope 2 was 53,090 tCO2e (2024: 54,378). Gross Scope 3 was 5,627,192 tCO2e (2024: 5,167,604), dominated by Cat.1 purchased goods and services (2,843,800 tCO2e) and Cat.11 use of sold products (2,449,608 tCO2e). Total GHG emissions were 6,000,293 tCO2e location-based and 5,865,544 tCO2e market-based, i.e. 308 and 301 tCO2e/M€ respectively (2024: 314 and 304). Scope 1+2 market-based CO2e emissions were 238,352 t in 2025 (-0.6% vs 2024), of which Scope 1 accounted for 185,262 t (including 9,798 t linked to SF6, down 39%) and Scope 2 market-based 53,090 t; intensity was 12.2 g/€ (-9.5% vs 2024). Leonardo does not consolidate emissions from joint ventures over which it lacks operational control. This DR is within the scope of EY's reasonable-assurance engagement.

Reference: page 94

Leonardo states plainly that it "has no GHG emission offset or mitigation projects financed with carbon credits." No nature-based solutions and no removals are used in the Group's decarbonisation strategy; reductions rely instead on the direct-abatement levers described under E1-3 (energy efficiency, renewable sourcing, product and supply-chain decarbonisation). This is a continuation of the position reported in the prior year: Leonardo has not adopted carbon offsetting or removal-crediting mechanisms as part of its path toward the SBTi-validated Scope 1 and 2 targets, relying instead on direct operational and product-level abatement across the value chain.

Reference: page 94

Leonardo makes use of a shadow price scheme, with the value determined by reference to the European Emissions Trading Scheme (ETS) allowance price. The Group operates eight Italian sites subject to EU ETS and applies this internal carbon price to assess the cost-effectiveness of investments to reduce emissions both at ETS-regulated installations and at sites in countries where ETS-like tools may apply in future. New EU regulation extending ETS to intra-EU flights could push customers toward lower-consumption, lower-emission products. The carbon price is used in business decisions on energy-efficiency projects, investments underpinning the Scope 1 and Scope 3 upstream (Cat.1&2) decarbonisation pathway, and the identification of business opportunities, including directing R&D activity.

Reference: page 81

Leonardo does not name a standalone pollution-specific policy; pollution is addressed within the same HSE Policy that covers climate, water, biodiversity and resource use. The policy commits the Group to reducing environmental impacts through corporate, process and innovation strategic choices aimed at both careful, sustainable use of natural raw materials and protection of soil, subsoil and ecosystem biodiversity, including reduced use of hazardous substances and preparations. Implementation is anchored in the ISO 14001-certified HSE Management System applied at all Group sites, ensuring compliance with limits set by environmental regulation and continuous-improvement monitoring of impact reduction.

Reference: page 97

Leonardo performs environmental assessments and monitors strategic-plan progress under ISO 14001, including risk assessment tied to processes, assets and geography, backed by specific insurance for unexpected events. For soil and air emissions, the Group works on new processes, technologies and more efficient abatement systems to reduce diffuse/fugitive pollution and NOx, SO2 and VOC emissions, with wastewater at its Italian and foreign sites treated before discharge. Product-use pollutant reduction includes electrification/hybridisation projects such as Clean Aviation and the new-generation civil Tiltrotor, which cuts normalised NOx emissions by about 50% versus the AW139, plus acoustic-noise-reduction projects on rotor blades, turbine nacelles and urban electric-transport control systems (Genova IV Assi, Milan Remote City Management). For hazardous substances, Leonardo runs a REACH-driven rationalisation of purchased substances with per-Division mitigation plans and eco-design substitution where feasible, engaging more than 1,000 suppliers on REACH compliance in 2025 and surveying about 2,300 suppliers on PFAS exposure.

Reference: page 99

Leonardo's pollution target addresses hazardous substances (SVHC) purchased under REACH Annex XIV, measured as kilograms of SVHC per production hour relative to 2022. In 2025 the indicator stood at 2.97 (-34% vs 2022), against interim and long-term targets of -15% by 2025 and -50% by 2032. The target is monitored through this single indicator, with stakeholder involvement channelled through the double materiality process.

Reference: page 99

Leonardo's European sites report exceedances of air, water and soil pollutant emission limits under Annex II of the E-PRTR Regulation to ISPRA in Italy; non-EU sites are monitored against local limits or, if stricter, the equivalent EU thresholds. As at the reporting date, there were no reported exceedances of emission levels for 2025, and micro-plastics are neither used nor produced. Separately, in 2025 nine environmental incidents occurred, mainly leaks, including two F-gas leaks at the Villaputzu site (about 40 kg of R-407C and 25 kg of R-32); three health-and-safety-regulation violations reported by supervisory bodies resulted in monetary penalties of €7,918. VOC emissions from Leonardo's activities amounted to 198.2 tons in 2025.

Reference: page 100

Leonardo maintains dedicated tools for collecting and reporting substances of concern (SoC) and substances of very high concern (SVHC), enabling proactive assessment and mitigation of health and environmental impacts, and requires suppliers to comply with the same regulations. In 2025, total SoC fell to 796 tonnes (2024: 2,541 tonnes) and total SVHC fell to 41 tonnes (2024: 70 tonnes).

Reference: page 100

During 2025, regulatory bodies reported six environmental violations (at the Tessera, Cascina Costa, Anagni, Brindisi, Fitchburg and Philadelphia sites), giving rise to cumulative monetary penalties of approximately €6,000 for the year. Total remediation costs incurred in 2025 were €10.1 million. These figures sit alongside the separate financial-effects disclosure under E2-4, which records three health-and-safety-regulation violations at the Villaputzu site resulting in penalties of €7,918 following two F-gas leaks. Leonardo does not disclose a forward-looking quantification of anticipated financial effects from pollution-related risks or opportunities beyond these realised 2025 costs.

Reference: page 81

Water is addressed within the same HSE Policy covering pollution, biodiversity and resource use, committing Leonardo to careful and sustainable use of water resources alongside soil and biodiversity protection. Leonardo is committed to reducing and optimising water withdrawals, with particular attention to water-stressed areas, ensuring adequate discharge treatment, complying with applicable law and considering stakeholder expectations; the Group pursues investments in circular industrial-water use and redundant sources such as rainwater as risk-mitigation actions. Implementation runs through the ISO 14001-certified HSE Management System applied at all sites (page 101 elaborates the resulting water-management strategy).

Reference: page 101

Leonardo's water strategy rests on two pillars: making site water networks more efficient through targeted revamping and measurement (the Smart Water programme installed roughly 90 new smart meters between 2019 and 2025, with 2025 actions at Anagni, cooling-tower control, and Benevento, waste/X-ray projects), and implementing closed-loop industrial-water circularity, including wastewater-treatment upgrades. Phase 3 of Smart Water launched in 2025 across six Italian sites, covering feasibility studies and preliminary design for recovery and reuse systems; a rainwater-recovery system was installed at Foggia, and an evapoconcentrator began operating at Caselle for galvanic-process water at end-2025. Site-specific feasibility studies covered reverse-osmosis wastewater treatment at Nola, a closed-loop geothermal cooling replacement at Pomigliano, and treated-water reuse in the NDI process at Grottaglie. The Smart Water project cut water supplies by approximately 245 million litres in 2025, with over €4.5 million in planned investment for 2026-2029 (€1.3 million spent in 2025).

Reference: page 102

Leonardo targets a 25% reduction in absolute water withdrawal volumes (and consequent consumption) by 2030 against a 2019 baseline, deliberately independent of business performance given expected further production growth. The Group prioritises interventions in water-stressed areas and aims to improve discharge water quality. Progress to date: a 23% reduction in water withdrawals in 2025 compared with 2019.

Reference: page 103

In 2025 Leonardo withdrew 4,540,567 m³ of water and discharged 2,741,249 m³, for consumption of 1,799,318 m³, of which 62.4% occurred in water-stressed areas; water intensity was 92.25 m³/M€ (2024: 98). Water withdrawals fell 2.3% to 4,540 megalitres; withdrawals from water-stressed areas fell 1.8% to 2,749 megalitres; reused and recycled water was 160.5 megalitres, about 4% of total withdrawals. By source, 52% came from water-supply systems and 43% from wells; 61% of withdrawals occurred outside water-stressed areas. This DR is within the scope of EY's reasonable-assurance engagement (via the entity-specific "water withdrawals" KPI).

Reference: page 105

Leonardo's industrial activity interacts with local biomes across the value chain, grouped into five interaction clusters per TNFD recommendations: climate change, land/water-use change, use and restoration of material resources, pollution, and invasive alien species. The Group frames water management, climate action and materials procurement/use as integral parts of its biodiversity approach and, within the broader transition-plan strategy, deploys monitoring tools for local (including site-adjacent) and global ecosystems, partly via its own technologies. Leonardo treats ecosystem conservation as a resilience-relevant business element, targeting both impact reduction and biodiversity regeneration at its industrial sites and across parts of the product lifecycle, extending analysis upstream to raw-material procurement in line with the Science Based Targets Network (SBTN) framework and the EU Deforestation Regulation.

Reference: page 81

Biodiversity sits within the same HSE Policy covering pollution, water and resource use, and is reinforced by a dedicated Group Biodiversity Policy published in June 2024 and approved by the CEO. The Biodiversity Policy commits Leonardo to reversing the trend of natural-resource use across the value chain, reducing and mitigating impacts on nature, protecting and regenerating ecosystems and biodiversity - starting from protected and high-biodiversity (KBA) areas near production sites - and reducing deforestation impacts through habitat protection, regeneration and reforestation. Specific commitments include encouraging renewable energy and emissions reduction, reducing pollution and preserving flora/fauna habitats near sites and testing/training activities, promoting sustainable and traceable use of natural raw materials and water, reducing hazardous-substance use, and leveraging technology to assess and mitigate biodiversity impacts (page 82).

Reference: page 106

In 2025 Leonardo advanced use of the WWF Biodiversity Risk Filter tool, adapted to its sites' geographic, operational and business specifics, feeding a Biodiversity Risk Assessment (BRA) Model enriched with a site-specific biodiversity risk index (LDO Index) aligned with ISO 14001 and the SBTN methodology. This produced a structured prioritisation of 51 production sites (44% of the Group's industrial footprint) by biodiversity impact/dependency risk, guiding on-site investigations. Actions adapted to local geography include reforestation with native species, projects to minimise acoustic/light/electromagnetic impacts, and prevention of harmful-substance dispersion. In the UK, biodiversity assessments completed for Yeovil and Southampton with the Somerset Wildlife Trust Consultancy identified biodiversity-net-gain opportunities, leading to hedge and wildflower planting at Edinburgh, a Yeovil Sustainability Garden and solar-park biodiversity-gain design, and 10,000 trees planted with the non-profit Carma.

Reference: page 107

Leonardo has not set specific standalone biodiversity targets, instead relying on targets already defined for the underlying biodiversity drivers: climate change, water, pollution and waste (i.e. the water-withdrawal, hazardous-substance and waste-reduction targets reported under E1/E2/E3/E5). In addition, site-specific biodiversity-project targets are measured with the Mean Species Abundance KPI, defined by SBTN-recognised standard models and determined by the same five biodiversity drivers, including land use.

Reference: page 107

Within a 5 km radius of high-biodiversity-value areas, Leonardo has 71 sites covering 18.5 km²; within a 20-40 km radius, a further 23 sites covering 1.6 km². Based on GIS proximity analysis using the National Geoportal of the Ministry of the Environment and Energy Security, approximately 67% of the total area occupied by Leonardo sites lies near or within protected areas or areas of high biodiversity value. Impact/dependency-related ecosystem-change metrics otherwise draw on the Group's water-withdrawal and waste-generation data reported at Group perimeter level.

Reference: page 81

Resource use and circular economy is addressed within the same HSE Policy covering pollution, water and biodiversity, alongside a dedicated policy for materials procured in conflict areas, which applies enhanced due diligence - via the Human Rights Impact Assessment tool - to incoming materials linked to conflict minerals (gold, tantalum, tungsten, tin and cobalt). The Group's circular-economy commitments emphasise reducing environmental impacts through production-process efficiency, waste-reduction plans and circular-economy programmes, including circular supply chains, alongside reduced use of hazardous substances (page 82).

Reference: page 109

Leonardo's circularity strategy rests on four pillars: material inflow (supply-chain resilience via secondary materials, digital traceability and ESG-integrated procurement), product portfolio (eco-design/LCA, Digital Twin/additive manufacturing, durability and product-as-a-service), material outflow and operating efficiency (circular value chains for critical materials, by-product upcycling), and product end-of-life (spare parts, product recall). Flagship 2025 projects include the Supply Chain Control Tower for Critical Raw Materials monitoring, a full LCA model for the AW139 transmission (ISO 14040/14044), expanded Rotorcraft Digital Twin use, the "Product-as-a-Service" High Power Computer and Second-Hand Parts Marketplace, the CRM4Defence project to upcycle aluminium/titanium/magnesium processing residues (about 2,400 tonnes/year targeted), the closed-loop FEP plastics project with Guarniflon, and the OnLife programme with HP giving end-of-life corporate PCs a second life (275 units donated/reintroduced, 17.3 tonnes CO2e avoided, 2,072 kg WEEE recycled in 2025).

Reference: page 111

Leonardo has set an absolute target to reduce total waste produced (hazardous and non-hazardous) by 15% by 2030 against a 2019 baseline, deliberately independent of expected future production growth, given the Group's production volumes are expected to keep growing. Progress to date: a 22% reduction in waste generated in 2025 compared with 2019, achieved through waste-reduction and circular-economy programmes described under E5-2, including upcycling of critical-raw-material processing scraps and expanded reuse/recycling of end-of-life products. Leonardo notes separately that its waste-reduction targets, unlike some other environmental targets, were set on a voluntary basis rather than under a specific regulatory requirement.

Reference: page 112

In 2025 Leonardo purchased a total of 92.7 ktonnes of materials, comprising raw materials and semi-finished products; total weight of products and technical/biological materials used was 92,743 tonnes (2024: 23,590 tonnes). None of this related to reused or recycled secondary components. The share of biological materials used from a sustainable supply chain was 0%, unchanged from 2024. Total weight of secondary reused or recycled components, intermediary products and materials used (including packaging) was 1,831,670 kg, or 1.97% of the total (2024: 2.66%).

Reference: page 112

Waste produced in 2025 was 30,090 tonnes (-7.57% vs 2024), of which 7,787 tonnes hazardous; 74% was non-hazardous. Of total waste, 61% was recovered (10% recycled): 18,208 tonnes were diverted from disposal (3,117 tonnes recycled, 15,051 tonnes to other recovery operations), while 11,883 tonnes went to disposal (85 tonnes incinerated, 902 tonnes landfilled, 10,896 tonnes to other disposal operations); 0.0501 tonnes of radioactive waste were collected. Waste intensity fell to 1.54 g/€ (-16% vs 2024). Leonardo notes its waste-reduction targets were set on a voluntary basis (see E5-3).

Reference: page 112

Leonardo's E5-5 waste data (see also above) show total waste generated of 30,090 tonnes in 2025 versus 32,555 tonnes in 2024. Of this, 18,208 tonnes were diverted from disposal (2,415 tonnes hazardous, 15,793 tonnes non-hazardous), including 40 tonnes reused, 3,117 tonnes recycled and 15,051 tonnes sent to other recovery operations. The remaining 11,883 tonnes were directed to disposal (5,372 tonnes hazardous, 6,511 tonnes non-hazardous): 85 tonnes incinerated, 902 tonnes landfilled and 10,896 tonnes to other disposal operations. Non-hazardous waste made up 74% of the 2025 total; recovered/recycled waste was 61%.

Reference: page 82

Leonardo's core workforce policy is the Group Policy on Human Rights, which sets rules in line with the UN Universal Declaration of Human Rights, ILO Conventions, OECD guidelines and the EU Charter of Fundamental Rights, covering own workforce, workers in the value chain, communities and consumers/end-users. It is complemented by the Diversity, Equity and Inclusion Policy, laying down rules on respecting diversity, promoting an inclusive working environment, and preventing discrimination. Following an ISO 26000-based analysis, people management was identified as an area exposed to human-rights risk; the resulting policy provisions prohibit all forms of discrimination and child/forced/illegal labour exploitation, guarantee political and trade-union rights, protect personal data, and protect worker health and safety (page 118).

Reference: page 118

The perspective of workers and their representatives on sustainability-related risks and impacts is captured through the materiality analysis. Leonardo runs annual people-listening and engagement initiatives; in 2025 a new Employee Listening and Engagement Ecosystem was designed for 2026 launch, alongside thematic surveys. 2025 projects included three new Employee Resource Groups (Gender Equality, Disability, Intergenerationality, comprising 40 people), a "Diversity Speaking" inclusive-language programme, a home-work travel survey covering all Italian sites, a Digital Solutions & Infrastructure survey (over 4,200 responses), and a call for employee brand testimonials (over 100 participants).

Reference: page 119

As part of managing risks and negative impacts on its people, Leonardo makes available the Whistleblowing Platform, an IT tool using an encryption system, governed by the Whistleblowing Management Guidelines and regulated in line with Legislative Decree 24/2023; reports (signed or anonymous) are handled by the Management Audit & Whistleblowing OU within Group Internal Audit. Leonardo states it conducts activities with the aim of not causing or contributing to material adverse impacts on its people.

Reference: page 119

Actions cover labour protection and welfare (fair/adequate wages including gender pay gap monitoring, second-level bargaining benefits, working-time and overtime tracking, ongoing works-council involvement), physical wellbeing (the "Leonardo Active Hours" programme launched July 2025, over 8,000 participants; "Dr. Feel" virtual clinic pilot, about 5,000 people), family wellbeing (expanded "Leonardo Family Care", including nursery provision, babysitting search, summer camps and dedicated "Corallo" nursing rooms for returning mothers), and DE&I (Springboard Programme for women's development, three 2025 editions, over 400 participants; ERG activity; disability programmes including UK Disability Confident Level 2 accreditation). Leonardo used no social safety nets in 2025.

Reference: page 69

Six own-workforce targets track Leonardo's inclusive-workplace commitment, defined against industry benchmarks: women on total new hires (2025: 23.00%, target 30% by 2025); women on total new hires in STEM (2025: 21.4%, target 24% by 2030); women at managerial levels (2025: 18.9%, target 20% by 2025 and 22% by 2030); women on total employees (2025: 20.5%, target 22% by 2030); women in succession plans (2025: 29.2%, target 27% by 2025); and annual renewal/maintenance of ISO 37001:2016 Anti-Bribery certification (maintained in 2025).

Reference: page 124

Leonardo employed 62,762 people at end-2025 (2024: 60,468): 49,898 men (2024: 48,183), 12,863 women (2024: 12,284) and 1 other/not disclosed. Of these, 48,576 held permanent contracts and 1,322 temporary; 61,065 were full-time and 1,697 part-time. By country: Italy 38,320, United States 7,809, United Kingdom 9,362, Poland 3,301, other countries 3,970. Employee turnover was 4,397 leavers, or 7% of total employees (2024: 3,922, 6%). Leonardo employs 62,762 people, 94% in Italy, the UK, the US and Poland; 64% of the workforce holds a STEM profile.

Reference: page 126

Non-employee workers in Leonardo's own workforce, calculated as supervised workers as of 31 December, numbered 2,061 in 2025, down from 2,361 in 2024. This category sits alongside, and is reported separately from, injuries of workers who are not employees: 7 injuries were recorded among non-employee workers in 2025 (total injury rate 1.89 per million hours worked), down from 16 injuries (rate 4.01) in 2024, indicating both a smaller supervised-worker population and a lower injury rate year on year.

Reference: page 127

Industrial-relations coverage in 2025: 48,176 employees covered by collective bargaining (77% of the reported base, up from 45,557/75% in 2024); 18,470 employees are trade-union members (29%, 2024: 13,311/22%); 973 meetings were held with trade unions (2024: 755); 41,659 employees are covered by workers' representatives (66%, 2024: 37,707/62%); total strike hours in the reporting period were 318,202 (2024: 78,704). Detailed EEA/non-EEA coverage-rate and workplace-representation bands are also reported by country (Italy, UK, Poland, US).

Reference: page 127

By age group in 2025: 10,088 employees under 30, 31,857 aged 30-50, 20,817 over 50 (2024: 9,058/30,928/20,482). Top management composition: 149 men (73%) and 54 women (27%) in 2025, versus 159 men (80%) and 39 women (20%) in 2024; the executive team including the CEO comprises 19 men (82.6%) and 4 women (17.4%). "Top management" is calculated as first- and second-level managerial positions directly or indirectly reporting to the CEO.

Reference: page 120

Leonardo states that all its employees receive fair pay in line with reference parameters, consistent with the labour-protection commitment to guarantee fair and adequate wages, including monitoring of gender pay gaps, and with the more favourable economic and regulatory conditions granted under second-level company bargaining agreements on top of collective agreements and statutory minimums.

Reference: page 120

Leonardo states it "did not resort to any social safety nets in 2025 in its offices and production units." Employee protection instead runs through supplementary healthcare and pension schemes strengthened under the Company Supplementary Agreement, new protection forms for death or permanent disability, the Leonardo Loyalty Bonus and the birth bonus, all continued in 2025 alongside additional working-hours flexibility to support work-life balance.

Reference: page 128

Employees with disability numbered 1,862 in 2025 (3% of the workforce, matching 2024's 1,803/3%). By gender: 1,322 men (71%), 540 women (29%) in 2025, versus 1,255 men (70%) and 548 women (30%) in 2024. This metric sits within Leonardo's broader disability commitments described under S1-4, including Leonardo UK's Disability Confident Level 2 accreditation and the 2025 "CasAUTentica" project with the PizzAut ETS Foundation in Italy, which created two "Independent Living Gyms" for people with autism at Cassina de' Pecchi (Milan) and Monza.

Reference: page 122

Average training hours per employee rose to 26.2 in 2025 (2024: 23.0): 26.9 hours for men, 23.4 for women (2024: 23.2/22.5). By category: managers 17.5 hours, middle managers 21.1, white collars 24.0, blue collars 35.8 (2024: 13.9/22.1/22.8/25.0). Total employees assessed on performance were 43,311 (69% of the base, 2024: 41,091/68%). Group-wide, about 1.6 million training hours were delivered via 1,360 courses run with the educational system, and 63.7% of employees hold a STEM qualification. Skill-mapping in 2025 covered over 55,000 people, and internal job-posting filled a meaningful share of open roles (Italy 15%, US 12%, UK 12%, Poland 5%).

Reference: page 123

The 2025 employee injury rate was 1.93 per million hours worked (2024: 1.70), from 203 injuries (2024: 174); the rate for non-employee workers was 1.89 (7 injuries, 2024: 4.01/16), and value-chain-worker injuries numbered 85 (2024: 75). There were no employee, non-employee or value-chain-worker fatalities in 2025 or 2024. Occupational diseases rose to 17 (rate 0.03) from 8 (0.02) in 2024; lost-days rate fell to 9.99 from 10.58; absenteeism rate fell to 4.72% from 6.98%. 79% of employees work at ISO 45001-certified sites (68 certified sites); 1,957 health-and-safety audits were conducted (1,821 internal, 136 external). This DR is within the scope of EY's reasonable-assurance engagement.

Reference: page 130

100% of Leonardo's 62,762 employees were entitled to parental leave in 2025 (2024: 60,468, also 100%). 1,760 employees took parental leave during the year (2024: 1,895): 1,282 men (3% of male employees) and 478 women (2%). Country-specific provisions vary: Italy offers 10 days' fully-paid secondary parental leave (plus one additional day granted by Leonardo); the UK and Poland offer two weeks fully paid; the US provides up to 12 weeks unpaid leave under the FMLA, with Leonardo DRS offering two weeks fully paid.

Reference: page 131

Gender pay gap stood at 98% in 2025, unchanged from 2024; the remuneration ratio of the highest-paid individual to median annual total remuneration for all employees was 40 (2024: 37). Leonardo states all employees receive fair pay in line with reference parameters; incidents of discrimination or human-rights violations are addressed under the Governance chapter.

Reference: page 158

Leonardo's Whistleblowing Platform received 109 reports in 2025 (a 51% increase over 2024's 72), of which 41 were qualified reports; 56% concerned human-resource management, 18% procurement, 6% corporate security, 6% HSE, 3% legal/compliance, and 11% other processes. Of the 109 reports, 44 involved human-rights issues; of 81 reports specific to Leonardo S.p.A., 22 related to DEI topics. Investigations concluded in 2025 found supporting elements in 8 cases, including 4 confirmed incidents of discrimination or harassment and one conflict-of-interest violation; there were no confirmed cases of bribery, customer-privacy violation, or money laundering/insider trading among these.

Reference: page 82

Leonardo requires suppliers to comply with the Code of Ethics, the Organisational, Management and Control Model, and the Supplier Code of Conduct - published in 2024 and based on the IFBEC framework and approved by the CEO - which sets out the conduct rules and principles Leonardo expects for responsible, sustainable supplier management. The Code covers non-discrimination and equal opportunity, protection of workers' rights, prohibition of forced labour/human trafficking/child labour, payment of legally mandated minimum wages and benefits, and workplace health and safety compliance (page 132).

Reference: page 132

The perspective of suppliers is captured through the double materiality analysis. Leonardo conducts reputational checks on prospective third-party counterparties and includes clauses protecting workers during any change of contractor; additional safeguards on health and safety, social security, union rights and employment guarantees are negotiated with trade-union representatives for contractor-firm employees under the corporate supplementary agreement.

Reference: page 132

Leonardo makes available to all stakeholders, including suppliers, mechanisms for the management of signed or anonymous reports, as prescribed by the Whistleblowing Management Guidelines and the Supplier Code of Conduct, through the internal reporting channel - the Whistleblowing Platform, an IT tool using an encryption system. Reports are handled by the Management Audit & Whistleblowing OU within Group Internal Audit, in line with the same process applied to reports concerning Leonardo's own workforce and other stakeholder groups, and are protected from retaliatory, discriminatory or punitive action under the Group's whistleblowing management process.

Reference: page 133

Supplier management runs through portal registration, pre-qualification (Code of Ethics, Anti-Corruption Code, no child/forced/illegal labour, no criminal sanctions, Modern Slavery and Trade Compliance checks), qualification (technical/environmental/health-and-safety/cyber-security/IP requirements), and ongoing monitoring (document review, inspections, on-site audits) with escalation to blacklisting. 2025 KPIs: over 5,800 supplier pre-qualifications, 129 denials, 51 revocations at renewal, 5,252 reputational due-diligence checks, 2,786 completed qualifications, over 900 suppliers selected on environmental criteria, over 5,300 environmental/health-and-safety audits on service-provider suppliers, over 1,800 suppliers subject to deep sustainability assessment in the last two years, and 16 blacklisted suppliers. Leonardo has participated in the UK's A&D JOSCAR accreditation register since 2015.

Reference: page 136

Three targets track Leonardo's supply-chain sustainability commitment: the percentage of suppliers by emissions with decarbonisation science-based objectives (2025: 16%, target 58% by 2028); the number of key suppliers delivered sustainability training (2025: 306, target ≥500 by 2027); and the value share of major closed tenders including ESG criteria (2025: 34%, target >70% by 2028). Methodology: the supplier-targets indicator is the ratio of Scope 3 Cat.1&2 emissions from suppliers with SBTi-defined/validated targets to total supplier emissions in those categories; the training indicator counts key suppliers receiving at least €500K in orders who completed at least one sustainability training course since 2024; the tender indicator covers Ariba-portal tenders worth ≥€1 million including sustainability criteria.

Reference: page 82

Communities are covered by the same Group Policy on Human Rights that applies to own workforce, value chain, consumers and end-users, aligned with the UN Universal Declaration of Human Rights, ILO Conventions, OECD guidelines and the EU Charter of Fundamental Rights. Leonardo's business-conduct principles under the Code of Ethics and Charter of Values extend the commitment to respect human rights to communities affected by its operations and value chain.

Reference: page 142

Leonardo is committed to conducting its business in full respect of human rights, integrated into the Code of Ethics and Charter of Values and the Group Policy on Human Rights, and has adopted processes to avoid violations affecting affected communities. Community engagement runs through the Group's Foundations (Leonardo ETS, Ansaldo-Leonardo Group, and Med-Or) and dialogue/outreach initiatives promoting STEM education, sustainability culture and inclusion in the territories where Leonardo operates.

Reference: page 142

Leonardo makes available specific mechanisms for the management of signed or anonymous reports concerning affected communities, as prescribed by the Whistleblowing Management Guidelines and accessible through the internal reporting channel, the Whistleblowing Platform. This channel is the same one used to remediate impacts on own workforce, value chain workers and consumers, and is offered alongside the Group's broader human-rights due-diligence processes described under the "Statement on due diligence" and "Respect for human rights" sections of the General Information chapter.

Reference: page 142

Through the Leonardo ETS, Ansaldo-Leonardo Group and Med-Or Italian Foundations, Leonardo pursues social, economic and environmental development in the territories where it operates, generating shared value with entities, associations and non-profits, and disseminating knowledge, STEM disciplines and an inclusion-oriented, gender-equality-focused culture. In 2025 Leonardo invested about €4 million in sponsorship initiatives supporting communities, culture and scientific research (76% for scientific-culture promotion and local-community support), with 89% of sponsorship spend directed to Italy. Country-by-Country tax reporting for 2024 is also disclosed, breaking down revenues, pre-tax profit, taxes paid/accrued, workforce and property by jurisdiction (USA, UK, Poland, Italy, other countries).

Reference: page 346 (Annex - ESRS Content Index)

Leonardo states plainly: "Leonardo has not set targets on these issues for the time being," in relation to targets for managing material negative impacts, advancing positive impacts, and managing material risks and opportunities toward affected communities. In place of a quantified target, effectiveness is tracked through the actions reported under S3-4, including the activity of Leonardo's three Group Foundations (Leonardo ETS, Ansaldo-Leonardo Group and Med-Or), whistleblowing-based remediation of any human-rights issues under S3-3, and the community-sponsorship spend and geographic/scope breakdown disclosed on page 143.

Reference: page 137

Sale and distribution of company products was identified as one of the areas most exposed to human-rights risk. Leonardo's Trade Compliance Program governs this exposure, committing the Group to: developing security/protection technology solutions; non-involvement in non-conventional weapons (cluster bombs, landmines, biological/chemical/blinding-laser/incendiary weapons, depleted uranium) or nuclear-weapons production/maintenance; compliance with embargo, sanctions and trade-restriction obligations; blacklist and Sensitive-Country due diligence on potential customers and end-users; and full use of the Human Rights Impact Assessment (HRIA) tool. In 2025, 570 transactions in Sensitive Countries were monitored.

Reference: page 138

Customer engagement is measured via the Net Promoter System (NPS): in 2025, over 100 customers across civil, military and government markets in about 50 countries were involved, and 2,500 pieces of feedback were collected and analysed to guide corrective action. Leonardo also provides digital customer-service platforms (CRM, e-commerce, the Leonardo Customer Portal) and continues to build out its Leonardo Logistic Network for foreign-market technical and industrial support.

Reference: page 138

The process for handling consumer and end-user complaints is described in the whistleblowing section; complaints are channelled through the same Whistleblowing Management Guidelines and Whistleblowing Platform used for other stakeholder groups, with signed or anonymous reporting available. This shared mechanism sits alongside Leonardo's dedicated customer-facing service infrastructure - including the Leonardo Customer Portal and Customer Relationship Management platforms - which handle operational service requests, while the Whistleblowing Platform remains the channel for reports of potential violations or adverse impacts.

Reference: page 138

Leonardo pursues the highest safety and quality standards under ISO 9001, AS/EN 9100, AS/EN 9110 and NATO AQAP standards, backed by internal and third-party audits, centralised Safety Management Systems, crisis-management/recall procedures and a continuously updated "Lesson Learnt" register. In 2025, 89% of employees operated at ISO 9001-certified sites and 85% of suppliers (by purchase value) held process-quality certification; a QA Matrix implemented at 17 sites analysed priority non-quality events, closing about 60% of them. Customer support delivered approximately 57,000 training hours through flight simulators to over 16,000 pilots and operators, and Leonardo ranked first among helicopter companies in ProPilot's after-sales-support quality ranking for the seventh consecutive year.

Reference: page 346 (Annex - ESRS Content Index)

Leonardo states plainly: "Leonardo has not set targets on these issues for the time being," in relation to targets for managing material negative impacts, advancing positive impacts, and managing material risks and opportunities toward consumers and end-users. In place of a quantified target, Leonardo tracks quality and safety performance through the ISO 9001/AS-EN 9100 certification coverage, QA Matrix non-quality-event closure rate, and customer-satisfaction NPS methodology reported under S4-2 and S4-4, and remediates individual issues through the whistleblowing-based complaints process under S4-3.

Reference: page 151

Leonardo's responsible-conduct model rests on the Charter of Values, the Code of Ethics, the Anti-Corruption Code (informed by the 2003 UN Convention against Corruption), the Organisational, Management and Control Model adopted under Legislative Decree 231/2001 by Leonardo S.p.A. and its Italian subsidiaries, and Compliance Programs adopted by foreign subsidiaries under local regulation. Leonardo has also adopted ASD's Common Industry Standards and IFBEC's Global Principles of Business Ethics for the Aerospace and Defence Industry, and collaborates with TRACE International. The model combines tone-from-the-top, awareness-raising and training, defined processes and organisation, codes and rules of conduct, national/international best practice, transparency, risk assessment and due diligence, and internal/external audit and whistleblowing controls (page 153).

Reference: page 132

Supplier relationships run through a structured lifecycle of portal registration, pre-qualification (Code of Ethics, Anti-Corruption Code, no forced/child labour, sanctions and Modern Slavery screening, environmental/cyber/IP requirements), qualification, and ongoing monitoring through inspections and audits, with escalation to temporary or permanent removal from the supplier register for serious or repeated non-compliance. Leonardo has participated in the UK A&D JOSCAR accreditation register since 2015. Leonardo's approximately 11,000-strong global supply chain represents 81% of purchases in goods and services (€12.5 billion, 64% of revenue), 64% concentrated in domestic markets with about 7,000 local SMEs; supplier-development programmes are supported by roughly €3.7 million allocated to the supply-chain sustainability acceleration programme (€244 million spent in 2025 - see also G1-2 methodology notes on the Annex page 349).

Reference: page 156

Leonardo has held ISO 37001:2016 Anti-Bribery Management Systems certification since among the first companies in the AD&S sector's global top ten, subject to an annual third-party surveillance audit; the 2025 audit was completed successfully, with all reviewed processes found compliant and, for the first time, only two improvement recommendations issued. The Anti-Corruption System is supervised by a function reporting to the Chief Compliance Officer and functionally to the Board Chairman, which monitors adequacy and effectiveness on an ongoing basis through an Anti-Corruption Risk Assessment (ACRA) run via the Group's Enterprise Risk Management methodology. In 2025, about 16,000 people were trained in anti-corruption and about 45,600 in Legislative Decree 231/2001 matters; 139 enhanced due-diligence audits were carried out on promoters, commercial advisors, distributors, resellers and lobbyists, plus 432 due-diligence audits on other third parties.

Targets related to business conduct

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement. G1-3 became a standalone DR only in the 2025/2026 ESRS; the report was prepared under the 2023 ESRS.

Leonardo does not state a quantified, outcome-oriented business-conduct target for corruption prevention. Consistent with MDR-T's other limb, effectiveness of anti-corruption policies and actions is tracked through structured monitoring rather than a numeric target: the Group's ISO 37001:2016 Anti-Bribery Management System certification is subject to annual third-party surveillance audit (the 2025 audit found all reviewed processes compliant, issuing only two improvement recommendations - the fewest to date), and the Anti-Corruption System's adequacy is verified on an ongoing basis via the Anti-Corruption Risk Assessment (ACRA), run through the Group's Enterprise Risk Management methodology (page 156). Training coverage is also tracked as a proxy for effectiveness: about 16,000 people were trained in anti-corruption topics and about 45,600 under Legislative Decree 231/2001 in 2025, alongside 139 enhanced due-diligence audits on promoters, commercial advisors, distributors, resellers and lobbyists (page 157).

Reference: page 157

There were no legal actions related to unfair competition, antitrust or monopolistic practices in 2025. In 2025 there were no convictions issued as part of criminal proceedings against Group companies, and no dismissals resulting from judicially established corruption cases. This clean record follows the annual ISO 37001 surveillance audit reported under G1-3, which found all reviewed anti-corruption processes compliant. Separately, under the SASB Content Index, Leonardo reports no monetary losses from legal proceedings tied to corruption or bribery in 2025, and 13% of 2025 revenues came from countries classified in bands E and F of Transparency International's Government Defence Anti-Corruption Index.

Reference: page 159

Under the Code of Ethics, Leonardo does not contribute company funds to political or trade-union parties, movements, committees, organisations or their representatives/candidates anywhere in the Group, including the US; in the US, employee-funded Political Action Committee contributions are permitted but supervised and monitored for legal compliance to prevent use as a corruption vehicle. In 2025, lobbying-related expenses by the Group's non-Italian subsidiaries, all in the US, amounted to just over USD 1.1 million (2024: about USD 2 million), covering optical-recognition/infrastructure technologies, government procurement/tenders, and R&D programmes for submarines, protection systems, and naval/ground/satellite communications, lasers and sensors.

Reference: page 160

Leonardo makes monthly payments of overdue and payable invoices to meet contractual commitments; payment terms are not standardised and vary by supplier, typically ranging between 60 and 90 days. There are no legal proceedings currently pending due to late payment. This payment practice applies across Leonardo's approximately 11,000-strong supplier base, described under G1-2 and S2-4, and sits alongside the Group's broader financial-resilience commitments, including the supply-chain financing tools it makes available to suppliers to support their growth and liquidity.