Standards of Business Ethics and Conduct

Table of Contents MESSAGE 1 BUSINESS ETHICS PRINCIPLES 3 BUSINESS ETHICS MODEL 4 WORKING WITH GOVERNMENT CUSTOMERS AND PUBLIC OFFICIALS 11 WORKING WITH OTHERS 13 PROTECTING OUR RESOURCES 15 TAKING ACTION 17 INSIDE BACK COVER

Dear Fellow Employee: This is the General Dynamics Standards of Business Ethics and Conduct handbook, which we call the Blue Book. The Blue Book lays the foundation for how we conduct ourselves as a corporation and as individuals representing the company. Every action we undertake reflects on us, our values and our character. At our core, we are in business to earn a fair return for our shareholders. In doing so, we must use our company’s assets wisely and we must deliver on our promises to our customers, our partners and our people. These are the ethics that guide our conduct and decisions....

Business Ethics Principles We are in business to earn a fair return on behalf of our shareholders. • Use Assets Wisely – How we manage assets reects our personal values, our companyʼs values, and determines our ability to earn a fair return. • Offer a Fair Deal – We offer the best products at a reasonable price. – We make hard decisions and tackle tough choices. – How we go about making these decisions reects our values. – We are people of our word — we deliver on our promises. – We are responsible to our stakeholders and earn their trust everyday. • Earn a Fair Return – Our reputation is based...

General Dynamics Business Ethics Model Talents and Assets • Truth telling • Promise keeping • Respect • Trust • Integrity • Stewardship Compliance • Blue Book • Policies • Training • Enforcement • Oversight Business Ethics Principles • Use assets wisely • Offer a fair deal • Deliver on promises • Earn a fair return Each Other

This Booklet A Practical Reference Each day you will face and make decisions that are critical to our success. This booklet is a practical reference that you can use to get the information you need to make good decisions. You will also learn when to contact your business unitʼs ethics ofcer. Over the years, this booklet has become known as the Blue Book after the color of its cover. Use the Blue Book in conjunction with the policies, procedures, and work rules of your business unit to guide your actions as you do your job. The Blue Book is not an employment agreement. The Blue Book applies to...

Global Reality of Our Work We conduct business in numerous countries around the globe. Our employees are citizens of different countries and belong to diverse cultural groups. We are subject to the laws and regulations of all the countries, states and municipalities where we have operations and do business. Our worldwide presence subjects us to the regulatory and legal control of many jurisdictions at the same time. We must recognize the global reality of our work. In some instances, there may be a real or apparent conict between the laws of two or more countries. In that event, you must obtain...

Regardless of who the customer is, certain rules govern how we conduct our business every day. Antitrust, Sales Practices, and Competitive Information Antitrust and competition laws prohibit agreements that eliminate or discourage competition. Violations of these laws carry both stiff monetary nes and jail terms. We comply fully with the antitrust and competition laws of every jurisdiction where we do business. We are committed to fair and competitive sales practices. We will not engage in practices that would unfairly limit trade or exclude competitors from the marketplace. We will not communicate...

The following situations can easily give rise to conicts of interest: Gifts and Hospitality: Commercial Customers Personal Business Relationships You should disclose to your business unitʼs ethics ofcer any substantial interest that you or an immediate family member might have in our suppliers, customers, or competitors. Ownership of stock in a publicly traded company that is a competitor could create real or potential conicts of interest for you and our company. Be careful that your personal business relationships do not inuence the decisions you make on behalf of General Dynamics. Organizational...

Insider Information and Securities Trading You may learn of material information related to General Dynamics or other companies before the general public knows about such information. This type of information is called “insider” information. You may not buy or sell stock based on such insider information, or pass insider information on to someone else who then buys or sells stock, until this information has been publicly released. These rules also apply to more complex transactions including options, puts and calls, and techniques such as selling short. The best way to know if information is...

about any inspection, investigation, or request for information from any outside organization. During an inspection, never destroy or alter any documents, lie to or mislead an inspector, or obstruct the collection of information. The Legal Department will assist you in reviewing any information requested by an inspector before it is released. We keep accurate records of all nancial and business transactions. Our record-keeping procedures are essential to ensure that all costs are properly charged. It is your responsibility to record all costs accurately and to follow all accounting procedures....

Working With Government Customers and Public Ofcials We are a leader in the defense industry. We provide services and products to many governments around the globe. The laws and regulations relating to doing business with government customers and public ofcials are complex. Follow these laws carefully to protect our companyʼs reputation. When working with government customers and public ofcials you must be vigilant in complying fully with all laws and regulations. We do not engage in bribery or kickbacks. A bribe or kickback is the giving or accepting of money, fees, commissions, credits, gifts,...