Leonardo SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Limited	Leonardo SpA offers only a narrow window into its climate-policy lobbying. Its disclosures identify a single concrete policy – the EU “Taxonomy Regulation 2020/852” – but do not reference any other laws or regulations it has tried to influence. The company describes one specific method and target, noting that it “took part in a consultation with the Platform on Sustainable Finance” where an internal working group prepared its submission. Beyond this consultation, references to industry associations and research programmes are presented without explaining how they were used to influence policymakers. The only articulated objective is to have the Aerospace & Defence sector better reflected in the Taxonomy, as the company “supported the initiative, giving some recommendations to better consider the Aerospace & Defence sector within the Taxonomy applications.” No other desired policy changes, positions, or rationales are provided. As a result, Leonardo’s transparency remains limited, centered on a single EU consultation and lacking wider detail on policies, mechanisms, or outcomes.	1

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Leonardo describes a structured approach to ensuring its policy engagement reflects its climate objectives, noting that “Leonardo ensures the alignment of its external engagement activities with its climate commitments and transition plan through a well-defined process” that is “managed…across divisions and geographies in a consistent and coordinated manner,” and stating that “its engagement activities consider the goals of the Paris Agreement.” These statements demonstrate a clear policy and procedural commitment to align direct lobbying and broader external advocacy with climate commitments. However, the company does not disclose any specific individual or formal body responsible for overseeing this process, nor does it detail how it monitors, reviews or enforces alignment—such as the frequency of reviews or criteria for evaluating trade or industry association positions—leaving key governance elements unexplained.	2