Trade Compliance & Compliance Program Officer

Role Purpose

The Trade Compliance & Compliance Program Officer is responsible for implementing and maintaining Axiomatics AB’s trade compliance and group compliance framework in alignment with:

• EU Dual-Use Regulation (EU) 2021/821
• Swedish export control framework
• U.S. EAR (where applicable)
• Leonardo SpA’s central compliance policies and governance requirements

Axiomatics, as a subsidiary of Leonardo SpA, must comply with central group policies covering trade compliance, ethics, environmental compliance, and broader governance obligations. Leonardo is a publicly listed, partly state-owned company, and export control violations may constitute criminal offenses under applicable law.

This role ensures that Axiomatics has a structured, documented, and defensible compliance framework and acts as the designated operational interface toward Leonardo’s central compliance organization.

Organizational Context

Axiomatics will be supported by Leonardo’s central compliance organization, which includes approximately 150 compliance professionals.

Leonardo provides:

• Central compliance policies (mandatory for subsidiaries)
• Training support
• Access to sanctions screening tools
• Due diligence support
• Policy frameworks and reporting structures

Axiomatics remains legally responsible for:

• Its own export classification determinations
• Proper application of EU and Swedish export regulations
• Implementation of Leonardo’s compliance policies locally
• Reporting deviations and ensuring remediation

Scope of the Role

This role combines:

1. Trade Compliance (Export Controls)

2. Leonardo Group Compliance Program Implementation

3. Operational Compliance Integration into Business Processes

Key Responsibilities

1. Export Classification Governance

• Implement and maintain Axiomatics’ internal export classification framework.
• Develop structured classification checklists aligned with:
  • Swedish Military List (e.g., ML22 – software)
  • EU Dual-Use Regulation Annex I
  • Category 5 Part 2 (5D002)
  • Other potentially relevant Annex I entries

• Ensure Engineering performs technical classification determinations.
• Document and archive:
  • Annex I subentry determinations (e.g., 5D002.c.1)
  • Cryptography Note (Note 3) assessments
  • Non-controlled justifications
• Maintain defensible written records.

2. Implementation of Leonardo Group Compliance Policies

• Implement and operationalize Leonardo’s mandatory central compliance policies, including:
  • Trade compliance
  • Ethics and anti-corruption
  • Environmental compliance (where applicable)
• Ensure policies are:
  • Formally adopted
  • Communicated internally
  • Integrated into Axiomatics processes
• Establish deviation reporting and escalation procedures.
• Coordinate compliance reporting to Leonardo.

3. Sanctions & Know Your Customer (KYC) Controls

• Implement screening procedures:
  • Sanctions lists
  • Restricted parties
  • End-use and end-user verification
• Integrate compliance checks into:
  • Sales processes
  • Contract approval workflows
  • Partner onboarding
• Use Leonardo-provided tools where applicable.
• Maintain audit trail and documentation.

4. U.S. EAR & Third-Country Content Oversight

• Coordinate assessment of U.S.-origin components (e.g., Apache cryptographic libraries).
• Assess potential EAR applicability.
• Coordinate dual-regime compliance where relevant.
• Work with Leonardo when cross-border legal interpretation is required.
  

5. Training & Awareness

• Act as internal focal point for compliance training.
• Coordinate with Leonardo central compliance for:
  • Initial training
  • Ongoing updates
• Ensure employees understand:
• • Export control obligations
  • Sanctions compliance
  • Escalation channels
  • Personal and corporate liability exposure

6. Designated Leonardo Interface

• Act as the named compliance contact person toward:
  • Stefano Spano
  • Fausto Di Fant
  • Leonardo central compliance organization
• Provide timely responses regarding:
  • Organizational compliance structure
  • Implementation status
  • Identified risks
• Participate in group-level compliance coordination.

Leonardo requires clarity on who this designated contact person will be.

Accountability

The Compliance Program Officer is accountable for:

• Ensuring Axiomatics has an implemented and documented compliance program aligned with Leonardo policies.
• Ensuring export classification governance is structured and defensible.
• Ensuring sanctions and KYC processes are operational.
• Ensuring deviations are reported and remediated.
• Acting as the official compliance liaison to Leonardo.

Engineering remains responsible for technical product functionality and technical export classification determinations.