Final Assessment General Dynamics Corporation

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FINAL ASSESSMENT GENERAL DYNAMICS CORPORATION

The following pages contain the detailed scoring for your company based on public information.

The following table represents a summary of your scores:

Topic Number of % score based questions on public information

Leadership, Governance and Organisation 10 70%

Risk Management 7 7.1%

Company Policy and Codes 12 66.7%

Training 5 40%

Personnel and Helplines 7 71.4%

Total 41 54.9%

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A1: Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Score:

Comments: Based on public information, there is evidence that the company has published a statement from the Chairman and CEO Phebe Novakovic, in the Standards of Business Ethics and Conduct, which promotes the company’s whole ethics and anti-corruption agenda. The company therefore scores 1. To score higher the company would need to provide evidence of at least two other such statements from the last two years, or one statement from the last two years that specifically supports the company’s strong stance against corruption.

References: Public: Company website: Ethos, Codes of Conduct and Ethics ‘General Dynamics' ethos - our distinguishing moral nature - is rooted in five values: -Honesty -Trust -Humanity -Alignment -Value Creation Honesty: We tell the truth to ourselves and to others. Honesty breeds transparency. Trust: We trust each other to do the right thing. Humanity: We are compassionate and empathetic. We respect the dignity, rights and autonomy of others. Alignment: We are united in our commitment to our values. Value Creation: We create value by doing the right thing for our shareholders, our customers, our employees and our communities. As a community of people dedicated to our ethos, we stand against those who betray others, trod upon others' rights or disrespect the rule of law. Each of us has an obligation to GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

behave according to our values. In that way, we can ensure that we continue to be good stewards of the investments in us by our shareholders, customers, employees and communities, now and in the future. Phebe N. Novakovic Chairman & Chief Executive Officer General Dynamics’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

Standards of Business Ethics and Conduct (June 2013), p.1: ‘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. Please read the Blue Book carefully and spend some time thinking about our commitment to do the right thing every day. General Dynamics has an excellent reputation for how we do business. It is our responsibility as employees of General Dynamics to preserve that reputation through our integrity, honesty and respect for others. Sincerely, Phebe N. Novakovic Chairman and Chief Executive Officer’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

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A2: Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Score:

Comments: Based on public information, there is evidence that Chairman and CEO Phebe Novakovic, sits on the DII Steering Committee. TI understands that the DII Steering Committee meets several times a year.

References: Public: DII website: DII Steering Committee Phebe N. Novakovic, Chairman & Chief Executive Officer’ http://www.dii.org/dii-steering-committee

DII website: DII Working Group ‘La Guardia Myers, Staff Vice President, Ethics’ http://www.dii.org/dii-working-group

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A3: Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Score:

Comments: Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong personal, internal-facing commitment to the ethics and anti- corruption agenda of the company.

References: Public: NA

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A4: Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Score:

Comments: Based on public information, there is evidence that the company has a statement of values representing high standards of ethical business conduct, including honesty, trust and integrity. The values are described on the company’s website.

References: Public: Company website: About Our Ethics ‘Our Ethos General Dynamics' ethos - our distinguishing moral nature - is rooted in five values.’ ‘Business Ethics Principles Use Assets Wisely How we manage assets reflects our personal values, our company 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 reflects our values. Deliver on Promises We are people of our word - we deliver on our promises. We are responsible to our stakeholders and earn their trust every day. Earn a Fair Return Our reputation is based on our ability to use our values to generate profits. As we deliver on our promises, we must contract for a fair return.’

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http://www.generaldynamics.com/about/about-our-ethics/

Company website: Diversity and Inclusion ‘This inclusive culture has as its basis the following principles: Integrity Treating people with openness, dignity and respect is paramount to sustaining and growing a culture of integrity in which everyone feels valued. General Dynamics is committed to nurturing this culture every day through our dealings with one another. Valuing Differences Appreciating differences involves respecting the underlying characteristics that make each of us unique. These differences include personal points of view, beliefs and ways of thinking, as well as tangible differences such as age, gender, ethnicity, national origin, physical ability, military experience, sexual orientation and gender identity, among others. General Dynamics recognizes that the best ideas and solutions are developed by gathering input from people who have these different perspectives as well as these tangible differences. Equal Opportunity and Affirmative Action The principles of equal employment opportunity and affirmative action are part of General Dynamics' commitment to integrity. We value the contributions that all individuals make to our company.’ http://www.generaldynamics.com/about/DiversityandInclusion.cfm

Company website: Ethos, Codes of Conduct and Ethics ‘General Dynamics' ethos - our distinguishing moral nature - is rooted in five values: -Honesty -Trust -Humanity -Alignment -Value Creation Honesty: We tell the truth to ourselves and to others. Honesty breeds transparency. Trust: We trust each other to do the right thing. Humanity: We are compassionate and empathetic. We respect the dignity, rights and autonomy of others. Alignment: We are united in our commitment to our values. Value Creation: We create value by doing the right thing for our shareholders, our customers, our employees and our communities. As a community of people dedicated to our ethos, we stand against those who betray others, trod upon others' rights or disrespect the rule of law. Each of us has an obligation to behave according to our values. In that way, we can ensure that we continue to be good stewards of the investments in us by our shareholders, customers, employees and communities, now and in the future. GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

Phebe N. Novakovic Chairman & Chief Executive Officer General Dynamics’ ‘Our Values at Work These values drive how we operate our business. We relentlessly pursue operating excellence by innovating, improving our processes and reducing waste. We believe in being wise stewards of capital and resources, as informed by our values. These values govern how we interact with each other and our customers, partners and suppliers. Honesty, trust, humanity, alignment and value creation require that we be forthright about our mistakes and that we strive to correct them. We seek partners and suppliers who adhere to these values in their businesses and we hold them to that standard. These values guide the way that we treat our workforce. We believe we have a responsibility for the health and safety of our employees. We treat all of our employees with dignity and respect and provide them with fair compensation and equal employment opportunity. We stand behind basic universal human rights, including that employment must be voluntary. We oppose human trafficking in all forms. These values determine how we connect with our communities. We believe that we have a responsibility to be good corporate citizens and we believe in sustainable business practices, which include supporting the environment and the communities in which we work. We remind ourselves often of who we are and what we do. Our ethos undergirds our culture, our business model and our daily interactions.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

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(p.3): ‘Business Ethics Principles We are in business to earn a fair return on behalf of our shareholders. • Use Assets Wisely – How we manage assets reflects 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 reflects our values. • Deliver on Promises – 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 on our ability to use our values to generate profits. – As we deliver on our promises, we must contract for a fair return. Our business conduct reflects our business ethics principles’

(p.4):

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(p.5): ‘Business Ethics and Compliance When we talk about business ethics, we refer to the commitments that make our company great. We deal fairly with our companyʼs customers, suppliers, and competitors, as well as with each other. Each of us should strive to be: • Law abiding • Honest and trustworthy • Responsible and reliable • Fair and cooperative When we talk about compliance, we refer to the laws, rules, regulations, and policies that control and direct both our actions and those of our company. The Blue Book includes information about both the ethics and compliance aspects of business conduct.’

Proxy Statement 2014, p.9: ‘General Dynamics is committed to employing strong corporate governance practices to promote a culture of ethics and integrity that defines how we do business. At the core, we are in business to earn a fair return for our shareholders. To that end, our Board of Directors believes that a commitment to good corporate governance helps us compete more effectively, sustain our success over the long term and enhance shareholder value.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=proxy

Corporate Sustainability Report (June 2012), pp.1-2: ‘Throughout our history, we at General Dynamics have endeavored to deliver the highest quality products and services, as well as foster a culture of ethical behavior, integrity, innovation and continuous improvement. This culture is evident in the ways we interact with employees, customers, partners and shareholders. We also bring this culture and our corporate values in our approach to sustaining the environments in which we work and live. These values of ethical behavior, integrity, innovation and continuous improvement have been evident since our beginnings in the 1950s, when General Dynamics was created through the combination of Electric Boat, Canadair, Consolidated Vultee and Stromberg- Carlson. They were evident in our earliest accomplishments and they continue to be evident today throughout our four business groups: Aerospace, Combat Systems, Information Systems and Technology and Marine Systems. Our values have empowered us to produce innovative products and services, such as the best-in-class business jets built by Gulfstream, which have a global reputation for superior aircraft design, quality, safety and reliability. They manifest themselves in our production of the Stryker family of combat vehicles which, along with the Abrams main battle tank, have become a mainstay of the U.S. Army’s ground vehicle ﬂeet and are now in demand among Allied nations as well. These same values are present in the Information Systems and Technology group, in our provision of the U.S. Army’s next-generation broadband on-the-move tactical network, a

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prime example of continuous improvement and innovation in action. What’s more, these values drive the manufacturing of our state-of-the-art combatant and auxiliary ships and submarines, such as the Virginia-class submarines, which are essential to the U.S. Navy’s missions worldwide. Our accomplishments are not limited to the equipment we manufacture and the services we provide. They can also be measured in terms of the environments we support and sustain, both within and beyond our corporate borders. Beginning with our employees and extending through our communities and the physical environment we all inhabit, General Dynamics is committed to leadership and excellence. We bring our culture of ethical behavior, integrity, innovation and continuous improvement to these environments. In short, we endeavor to “do the right thing,” and we are equally proud of our accomplishments in, and our attention to, these environments.’

(p.3): ‘The Blue Book clearly states our expectation that all employees will conduct General Dynamics’ business in accordance with the law, our policies, our values and our business- ethics principles. It contains rules and guidance on how employees are to conduct business — whether dealing with customers, suppliers or each other. It reminds employees to sustain General Dynamics’ ethical business reputation by adhering to our principles of integrity, honesty and respect.’ http://www.gd.com/downloads/pdf/about/GD_Corporate_Sustainability_Report.pdf

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A5: Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Score:

Comments: Based on public information, there is evidence that the company is a member of IFBEC and a signatory of the DII.

References: Public: IFBEC website: Our Members General Dynamics and General Dynamics European Land Systems are members of IFBEC. http://ifbec.info/our-members/

DII website: Signatories General Dynamics is a signatory. http://www.dii.org/signatories

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A6: Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Score:

Comments: Based on public information, there is evidence that the company’s Audit Committee has overall corporate responsibility for the company’s ethics programme. The Committee monitors the management’s implementation of the policies and practices of the Standards of Business Ethics and Conduct Programme.

References: Public: Company website: About Our Ethics ‘The General Dynamics ethics program provides many resources to help employees “do the right thing.” Day-to-day oversight is provided at the corporate office by an ethics program manager. Overall leadership is provided by a chief ethics officer who reports directly to the Chairman and CEO on all ethics program matters. The ethics officer briefs the Audit Committee of the Board of Directors twice a year at regularly scheduled meetings. In addition, the program is managed at each business unit by a business unit ethics officer, with support from local ethics officers. The 13 business unit ethics officers and 120 local ethics officers implement the ethics program by: -Distributing the Blue Book and conducting orientation for all new employees; -Developing policies, procedures and work rules that, in conjunction with the Blue Book, govern employee conduct at the business units; -Ensuring that all employees receive periodic refresher training regarding the ethics program and any specific topic areas that are critical to the performance of their jobs; -Responding to questions about interpretation and application of rules and policies; -Providing advice and guidance to help employees resolve ethical dilemmas and make decisions; -Receiving reports of employee concerns regarding ethical matters; and

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-Conducting and overseeing prompt, thorough and objective investigations of all reported allegations of suspected ethical misconduct and taking corrective action, if necessary.’ http://www.generaldynamics.com/about/about-our-ethics/

(p.4): ‘Corporation Policies. The Committee will monitor management’s implementation of the policies, practices and programs of the Corporation in the following areas: (a) the Corporation’s Standards of Business Ethics and Conduct Program; (b) equal employment; (c) employee safety and health standards; (d) product and plant safety; (e) environmental matters; and (f) community relations and affairs.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govHighlights

Nominating and Corporate Governance Committee Charter (May 2014), p.1: ‘Purpose. The Nominating and Corporate Governance Committee (the “Committee”) of the Board of Directors (the “Board”) will assist the Board in identifying qualified individuals to serve as Board members, recommending committee assignments and responsibilities to the Board, evaluating Board and management effectiveness, developing and recommending to the Board corporate governance guidelines, and generally advising the Board on corporate governance and related matters.’

(p.2): ‘The Committee will develop and recommend to the Board corporate governance guidelines that comply with all applicable legal and regulatory requirements. Updates to the guidelines will be recommended by the Committee periodically as the Committee deems appropriate.’ ‘The Committee will monitor developments, trends and best practices in corporate governance, and take such actions in accordance therewith as it deems appropriate.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govHighlights

Proxy Statement 2014, p.12:

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Audit Committee responsibilities include ‘Monitors management’s implementation of the policies, practices and programs of the company in several areas, including business ethics and conduct, employee safety and health standards, and environmental matters’

(p.13): Nominating and Corporate Governance Committee responsibilities include: ‘• Advises the Board on corporate governance matters and monitors developments, trends and best practices in corporate governance • Recommends to the Board corporate governance guidelines that comply with legal and regulatory requirements’

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A7: Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti- corruption agenda, and who has a direct reporting line to the Board?

Score:

Comments: Based on public information, there is evidence that the company has appointed a Chief Ethics Officer with responsibility for implementing the company’s ethics programme. The Chief Ethics Officer has overall leadership of 13 business unit ethics officers and 120 local ethics officers who implement the ethics programme; he or she reports directly to the Chairman and CEO, and the Audit Committee. The company therefore scores 1. To score higher the company would need to provide evidence that the Chief Ethics Officer is identifiable by name.

References: Public: Company website: About Our Ethics ‘The General Dynamics ethics program provides many resources to help employees “do the right thing.” Day-to-day oversight is provided at the corporate office by an ethics program manager. Overall leadership is provided by a chief ethics officer who reports directly to the Chairman and CEO on all ethics program matters. The ethics officer briefs the Audit Committee of the Board of Directors twice a year at regularly scheduled meetings. In addition, the program is managed at each business unit by a business unit ethics officer, with support from local ethics officers. The 13 business unit ethics officers and 120 local ethics officers implement the ethics program by: -Distributing the Blue Book and conducting orientation for all new employees; -Developing policies, procedures and work rules that, in conjunction with the Blue Book, govern employee conduct at the business units; -Ensuring that all employees receive periodic refresher training regarding the ethics program and any specific topic areas that are critical to the performance of their jobs; -Responding to questions about interpretation and application of rules and policies; -Providing advice and guidance to help employees resolve ethical dilemmas and make GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

decisions; -Receiving reports of employee concerns regarding ethical matters; and -Conducting and overseeing prompt, thorough and objective investigations of all reported allegations of suspected ethical misconduct and taking corrective action, if necessary.’ http://www.generaldynamics.com/about/about-our-ethics/

Corporate Sustainability Report (June 2012), p.3: ‘Our commitment to our ethics program is reinforced in a number of ways, including a Chief Ethics Oﬃcer who reports directly to the Chairman and Chief Executive Oﬃcer on all ethics program matters, and regularly briefs the Audit Committee of the board of directors.’

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A8: Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Score:

Comments: Based on public information, there is evidence of regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda. The Chief Ethics Officer briefs the Audit Committee twice a year at scheduled meetings on all ethics programme matters.

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allegations of suspected ethical misconduct and taking corrective action, if necessary.’ http://www.generaldynamics.com/about/about-our-ethics/

Company website: Corporate Governance – Highlights ‘The General Dynamics Board of Directors believes that a commitment to good corporate governance enhances shareholder value. To that end, the Board has adopted governance policies and processes to ensure effective governance of the Company. These governance policies are embodied in the General Dynamics Corporate Governance Guidelines, which, along with the charters of the Board's committees and the Company's Certificate of Incorporation and Bylaws, provide the framework for the oversight of the Company's business and operations. The Board of Directors conducts periodic governance reviews of all Board and committee governance documents and updates these documents as necessary and appropriate.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govHighlights

Corporate Governance Guidelines (May 2014), p.1: ‘In addition to its general oversight of management, the Board or its committees perform the following principal functions: • reviewing, approving and monitoring the Company’s business strategies, annual operating plan and significant corporate actions; • selecting, evaluating and compensating the CEO; • providing counsel and oversight on the selection and evaluation of senior management;

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• determining the compensation of the Company’s officers; • reviewing and approving CEO and senior management succession planning; • ensuring appropriate processes are in place for maintaining the integrity of the Company-- -including the integrity of the financial statements, compliance with law and ethics, and the integrity of relationships with customers, suppliers and other stakeholders; and • advising and counseling management.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govHighlights

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A8(a): Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Score:

Comments: Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and no evidence of improvement plans being implemented when issues are identified.

References: Public: TI notes: Company website: About Our Ethics ‘The General Dynamics ethics program provides many resources to help employees “do the right thing.” Day-to-day oversight is provided at the corporate office by an ethics program manager. Overall leadership is provided by a chief ethics officer who reports directly to the Chairman and CEO on all ethics program matters. The ethics officer briefs the Audit Committee of the Board of Directors twice a year at regularly scheduled meetings. In addition, the program is managed at each business unit by a business unit ethics officer, with support from local ethics officers. The 13 business unit ethics officers and 120 local ethics officers implement the ethics program by: -Distributing the Blue Book and conducting orientation for all new employees; -Developing policies, procedures and work rules that, in conjunction with the Blue Book, govern employee conduct at the business units; -Ensuring that all employees receive periodic refresher training regarding the ethics program and any specific topic areas that are critical to the performance of their jobs; -Responding to questions about interpretation and application of rules and policies; -Providing advice and guidance to help employees resolve ethical dilemmas and make

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Audit Committee Charter (May 2014), p.1: ‘Purpose. The Audit Committee (the “Committee”) will assist the Board of Directors (the “Board”) in its oversight of the integrity of the financial statements of the Corporation; the qualifications, performance and independence of the Corporation’s independent auditors; the performance of the Corporation’s internal audit function; and compliance by the Corporation with legal and regulatory requirements. The Committee will also prepare a report as required by the Securities and Exchange Commission (the “Commission”) to be included in the Corporation’s annual proxy statement.’ (p.4): ‘Corporation Policies. The Committee will monitor management’s implementation of the policies, practices and programs of the Corporation in the following areas: (a) the Corporation’s Standards of Business Ethics and Conduct Program; (b) equal employment; (c) employee safety and health standards; (d) product and plant safety; (e) environmental matters; and (f) community relations and affairs.’

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• selecting, evaluating and compensating the CEO; • providing counsel and oversight on the selection and evaluation of senior management; • determining the compensation of the Company’s officers; • reviewing and approving CEO and senior management succession planning; • ensuring appropriate processes are in place for maintaining the integrity of the Company-- -including the integrity of the financial statements, compliance with law and ethics, and the integrity of relationships with customers, suppliers and other stakeholders; and • advising and counseling management.’

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A9: Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Score:

Comments: Based on public information, there is evidence that the company has a formal process for review and update of company policies in the event of an actual or alleged instance of corruption. Ethics officers will conduct thorough and objective investigations of all reported allegations of suspected ethical misconduct. The company states it will take corrective action in response to ethical violations, including the implementation of system-wide changes. Evidence suggests that the Audit Committee is responsible for reviewing the Standards of Business Ethics and Conduct in response to violations.

References: Public: Company website: About Our Ethics ‘The General Dynamics ethics program provides many resources to help employees “do the right thing.” Day-to-day oversight is provided at the corporate office by an ethics program manager. Overall leadership is provided by a chief ethics officer who reports directly to the Chairman and CEO on all ethics program matters. The ethics officer briefs the Audit Committee of the Board of Directors twice a year at regularly scheduled meetings. In addition, the program is managed at each business unit by a business unit ethics officer, with support from local ethics officers. The 13 business unit ethics officers and 120 local ethics officers implement the ethics program by: -Distributing the Blue Book and conducting orientation for all new employees; -Developing policies, procedures and work rules that, in conjunction with the Blue Book, govern employee conduct at the business units; -Ensuring that all employees receive periodic refresher training regarding the ethics program and any specific topic areas that are critical to the performance of their jobs; -Responding to questions about interpretation and application of rules and policies; -Providing advice and guidance to help employees resolve ethical dilemmas and make GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

Standards of Business Ethics and Conduct (June 2013), p.18: ‘If we find that our standards have been violated, we will take action, including imposing disciplinary action, implementing system-wide changes, or notifying the right governmental office or agency as appropriate. Not only will we deal with a specific situation, but we will also make changes so that similar problems do not recur.’

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A9(a): Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Score:

Comments: Based on public information, there is limited evidence that the company has a risk assessment procedure implemented enterprise-wide, which includes an anti-corruption element. The Audit Committee has oversight of the company’s policies and practices concerning risk assessment and senior management is responsible for conducting risk management activities. However, it is not clear whether these processes contain an anti- corruption element, nor is there evidence of mitigation plans, their ownership or their implementation timelines.

References: Public: TI notes: Audit Committee Charter (May 2014), p.3: ‘Risk Assessment and Management. To the extent appropriate to comply with the requirements of the New York Stock Exchange or otherwise, the Committee will periodically review and take appropriate action with respect to the Corporation’s policies and practices with respect to risk assessment and risk management. The Committee will also review with the General Counsel the status of pending litigation and other legal matters on a periodic basis.’

Annual Report 2013, p.13: ‘International sales and operations are subject to different risks that may be associated with doing business in foreign countries. In some countries there is increased chance for economic, legal or political changes, and procurement procedures may be less robust or mature, which may complicate the contracting process. Our international business may be sensitive to changes in a foreign government’s budgets, leadership and national priorities. International transactions can involve increased financial and legal risks arising from foreign exchange-rate variability and differing legal systems. Our international business is subject to

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U.S. and foreign laws and regulations, including laws and regulations relating to import- export controls, technology transfers, the Foreign Corrupt Practices Act and certain other anti-corruption laws, and the International Traffic in Arms Regulations (ITAR). An unfavorable event or trend in any one or more of these factors or a failure to comply with U.S. or foreign laws could result in administrative, civil or criminal liabilities, including suspension or debarment from government contracts or suspension of our export privileges and could materially adversely affect revenues and earnings associated with our international business. In addition, some international government customers require contractors to enter into letters of credit, performance or surety bonds, bank guarantees and other similar financial arrangements. We may also be required to agree to specific in- country purchases, manufacturing agreements or financial support arrangements, known as offsets, that require us to satisfy certain requirements or face penalties. Offset requirements may extend over several years and require us to establish joint ventures with local companies. If we do not satisfy these financial or offset requirements, our future revenues and earnings may be materially adversely affected.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-reportsAnnual

Proxy Statement 2014, p.13: ‘Risk Oversight We believe our Board leadership structure supports a risk-management process in which senior management is responsible for our company’s day-to-day risk-management processes and the Board provides oversight of those processes. The Board oversees management of risks across the company at both the full Board and committee levels. The focus of the Board’s risk management oversight is on the most significant risks facing the company, including strategic, operational, financial and legal risks.’

(p.14): ‘Audit Committee. The Audit Committee has responsibility for oversight of the company’s policies and practices concerning overall risk assessment and risk management. The committee reviews and takes appropriate action with respect to the company’s annual and quarterly financial statements, the internal audit program, the ethics program and disclosures made with respect to the company’s internal controls. To facilitate these risk oversight responsibilities, the committee receives regular briefings from members of senior management on the internal audit plan; Sarbanes-Oxley 404 compliance; significant litigation and other legal matters; ethics program matters; and health, safety and environmental matters. The committee also holds regular executive sessions with the staff vice president, internal audit, and regular executive sessions with the partners of the KPMG LLP audit team.’

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A10: Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Score:

Comments: Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. TI notes that the Board’s risk management procedure includes operational risks, but there is no evidence that this includes an anti-corruption element.

References: Public: TI notes: Annual Repot 2013, p.13: ‘We have made and expect to continue to make investments, including acquisitions and joint ventures, that involve risks and uncertainties. When evaluating potential mergers and acquisitions, we make judgments regarding the value of business opportunities, technologies and other assets and the risks and costs of potential liabilities based on information available to us at the time of the transaction. Whether we realize the anticipated benefits from these transactions depends on multiple factors, including our integration of the businesses involved, the performance of the underlying products, capabilities or technologies, market conditions following the acquisition and acquired liabilities, including some that may not have been identified prior to the acquisition. These factors could materially adversely affect our financial results.’

Proxy Statement 2014, p.13: ‘Risk Oversight We believe our Board leadership structure supports a risk-management process in which senior management is responsible for our company’s day-to-day risk-management processes and the Board provides oversight of those processes. The Board oversees management of risks across the company at both the full Board and committee levels. The GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

focus of the Board’s risk management oversight is on the most significant risks facing the company, including strategic, operational, financial and legal risks.’

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A11: Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Score:

Comments: Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing agents.

References: Public: TI notes: Standards of Business Ethics and Conduct (June 2013), p.10: ‘Suppliers, Consultants, Part-time and Temporary Workers We select our suppliers based on objective criteria such as price, quality, and prior performance. As a condition of employment, all consultants and part-time or temporary workers are required to follow the Blue Book as well as corporate and business unit policies and practices. When dealing with suppliers or consultants, you have the following responsibilities: • Require competitive bids where appropriate • Fairly evaluate all proposals for work • If dealing with suppliers or consultants in the United States, or if appropriate in other jurisdictions, investigate opportunities to encourage small or minority-owned businesses to work with us • Get legal advice regarding doing business with former employees or board members • Do not accept gifts of more than modest value • Ensure that meals provided by a supplier or consultant serve a valid business purpose and are appropriate to the relationship’

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A12: Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Score:

Comments: Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption. Despite the Standards of Business Ethics and Conduct Code stating that consultants must follow its guidance on ethical business practice, there is no evidence of contractual rights and formal processes, nor does it specify that consultants include agents.

References: Public: TI notes: Company website: About Our Ethics ‘The Blue Book also states that we expect our suppliers, vendors, contractors and joint venture partners to develop ethics and compliance programs that are consistent with our values in all material respects.’ http://www.generaldynamics.com/about/about-our-ethics/

Standards of Business Ethics and Conduct (June 2013), p.10: ‘Suppliers, Consultants, Part-time and Temporary Workers We select our suppliers based on objective criteria such as price, quality, and prior performance. As a condition of employment, all consultants and part-time or temporary workers are required to follow the Blue Book as well as corporate and business unit policies and practices. When dealing with suppliers or consultants, you have the following responsibilities: • Require competitive bids where appropriate

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• Fairly evaluate all proposals for work • If dealing with suppliers or consultants in the United States, or if appropriate in other jurisdictions, investigate opportunities to encourage small or minority-owned businesses to work with us • Get legal advice regarding doing business with former employees or board members • Do not accept gifts of more than modest value • Ensure that meals provided by a supplier or consultant serve a valid business purpose and are appropriate to the relationship’

Corporate Sustainability Report (June 2012), p.3: ‘Furthermore, the Blue Book states that we expect our suppliers, vendors, contractors and joint venture partners to develop ethics and compliance programs that are consistent with our values in all material respects.’

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A13: Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Score:

Comments: Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, its stance on bribery and corruption. The Standards of Business Ethics and Conduct states that suppliers must develop ethics and compliance programmes that are consistent with the company’s values in all material respects. However, there is no evidence that the consequences of non-compliance are made clear or that there are contractual rights to apply sanctions in the event of a breach of a supplier’s contract. The company therefore scores 1.

References: Public: Company website: About Our Ethics ‘The Blue Book also states that we expect our suppliers, vendors, contractors and joint venture partners to develop ethics and compliance programs that are consistent with our values in all material respects.’ http://www.generaldynamics.com/about/about-our-ethics/

Standards of Business Ethics and Conduct (June 2013), p.5: ‘We expect our suppliers, vendors, contractors, and joint venture partners to develop ethics and compliance programs that are consistent with our values in all material respects.’

Standards of Business Ethics and Conduct (June 2013), p.10: ‘Suppliers, Consultants, Part-time and Temporary Workers We select our suppliers based on objective criteria such as price, quality, and prior performance. As a condition of employment, all consultants and part-time or temporary workers are GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

required to follow the Blue Book as well as corporate and business unit policies and practices. When dealing with suppliers or consultants, you have the following responsibilities: • Require competitive bids where appropriate • Fairly evaluate all proposals for work • If dealing with suppliers or consultants in the United States, or if appropriate in other jurisdictions, investigate opportunities to encourage small or minority-owned businesses to work with us • Get legal advice regarding doing business with former employees or board members • Do not accept gifts of more than modest value • Ensure that meals provided by a supplier or consultant serve a valid business purpose and are appropriate to the relationship’

Company website: Suppliers – FAQs ‘Additionally, we expect suppliers to demonstrate the following (business units may have additional special technical or quality requirements unique to their environment): -Financial viability -High ethical standards’ ‘How can we get on General Dynamics' approved supplier list? Please refer to each of the General Dynamics business unit websites since approval criteria vary by business unit. Qualification requirements are also typically identified with specific solicitations from the business unit.’ http://www.gd.com/suppliers/supplier-faq/index.cfm

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A13(a): Does the company explicitly address the corruption risks associated with offset contracting?

Score:

Comments: Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

References: Public: TI notes: GOCA website: Regular Member Directory General Dynamics Corporation is a member. http://www.globaloffset.org/regularmembers.php

Annual Report 2013, p.13: ‘In addition, some international government customers require contractors to enter into letters of credit, performance or surety bonds, bank guarantees and other similar financial arrangements. We may also be required to agree to specific in-country purchases, manufacturing agreements or financial support arrangements, known as offsets, that require us to satisfy certain requirements or face penalties. Offset requirements may extend over several years and require us to establish joint ventures with local companies. If we do not satisfy these financial or offset requirements, our future revenues and earnings may be materially adversely affected.’

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A13(b): Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Score:

Comments: Based on public information, there is no readily available evidence that the company conducts due diligence when selecting its offset partners and brokers.

References: Public: TI notes: GOCA website: Regular Member Directory General Dynamics Corporation is a member. http://www.globaloffset.org/regularmembers.php

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A15: Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Score:

Comments: Based on public information, there is readily available evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. The Code of Conduct prohibits the giving or receiving of bribes and identifies forms of corruption such as kickbacks and corrupt gift and hospitality exchange.

References: Public: Standards of Business Ethics and Conduct (June 2013), p.11: ‘We do not engage in bribery or kickbacks. A bribe or kickback is the giving or accepting of money, fees, commissions, credits, gifts, favors, or anything of value that is either directly or indirectly provided in return for favorable treatment. You must never offer, give, ask for, or receive any form of bribe or kickback. Favorable treatment often can appear innocent, such as paying an invoice earlier than we normally would. However, favorable treatment is illegal when offered in exchange for a gift.’

(p.7): ‘A conflict of interest occurs when your private interests interfere — or appear to interfere — with the interests of General Dynamics. You should base business decisions on our companyʼs needs, rather than your own interests, the interests of family or friends, or your desire for personal gain. You should not do business with organizations in which you, or your family, have a substantial financial interest. Each of us should deal with suppliers, customers, and others in ways that avoid even the appearance of a conflict between our personal interests and those of General Dynamics. Talk to your business unitʼs ethics officer and disclose any situation that presents or might present a conflict of interest.’

(p.8): ‘Gifts and Hospitality: Commercial Customers Gifts We compete solely on the merits of our products and services. When people exchange gifts GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

in a business context, it can look as if favors were granted in order to influence business judgment. We may provide gifts, meals, refreshments, and entertainment of reasonable value in the course of doing business with commercial customers or non-government personnel, provided that this practice does not conflict with our standards or the standards of the recipientʼs organization. You should not give or offer any gift if, under the circumstances, such a gift might appear to be improper. Receipt of Gifts Generally, you should not accept gifts, meals or entertainment from those with whom we do business unless this activity serves a legitimate business purpose and is appropriate for the relationship. You may accept small gifts that are of modest value only. When conducting business in some countries, it may be customary to accept gifts of substantial value. These gifts are company property and must be reported to your business unitʼs ethics officer for disposition. For example, they can be purchased from the company at fair market value, or donated to an appropriate charity on behalf of General Dynamics.’

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A16: Is the anti-corruption policy explicitly one of zero tolerance?

Score:

Comments: Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. TI notes that the company states that its employees should not engage in bribery or kickbacks, but this is not considered to be an explicit zero tolerance policy of bribery or corruption.

References: Public: TI notes: Standards of Business Ethics and Conduct (June 2013), p.11: ‘We do not engage in bribery or kickbacks. A bribe or kickback is the giving or accepting of money, fees, commissions, credits, gifts, favors, or anything of value that is either directly or indirectly provided in return for favorable treatment. You must never offer, give, ask for, or receive any form of bribe or kickback. Favorable treatment often can appear innocent, such as paying an invoice earlier than we normally would. However, favorable treatment is illegal when offered in exchange for a gift.’

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A17: Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Score:

Comments: Based on public information, there is evidence that the company’s Code of Conduct is easily accessible to Board members, employees and third parties. It is provided to all new employees and is available on the company website in numerous languages.

References: Public: Company website: Ethos, Codes of Conduct and Ethics Standards of Business Ethics and Conduct is available in numerous languages http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

Standards of Business Ethics and Conduct (June 2013), p.18: ‘General Dynamics updates and distributes the Blue Book to all employees.’

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A17(a): Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Score:

Comments: Based on public information, there is evidence that the company’s Standards of Business Ethics and Conduct is easily understandable and clear to Board members, employees and third parties. It is written in accessible, comprehensible language.

Code of Conduct for Members of the Board of Directors (August 2013), p.1: ‘To avoid actual or perceived conflicts of interest, we will fully disclose all material facts with respect to any private interest we may have in a transaction or other matter being considered by the Board. We will also recuse ourselves from participation in any decision of the Board in which there is a conflict between our private interests and the interests of the Company.’

Code of Ethics for Financial Professionals (August 2013), p.1: ‘As a Covered Executive, you will: a) Avoid conflicts of interest; b) Engage in honest and ethical conduct, including the ethical handling of any actual or apparent conflicts of interest between personal and professional relationships’

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A18: Does the anti-corruption policy explicitly apply to all employees and members of the Board?

Score:

Comments: Based on public information, there is evidence that the ethics and anti-corruption policy applies to all employees and Board members. The Standards of Business Ethics and Conduct applies to all officers and employees, while the Code of Conduct for Members of the Board of Directors applies to Board members. An additional Code of Ethics for Financial Professionals applies to the CEO, CFO, controller and any person performing similar financial functions. TI notes that the Code of Conduct for Members of the Board of Directors does not explicitly state that it is supplementary to the broader Standards of Business Ethics and Conduct, nor does it specifically address corruption or bribery.

References: Public: Company website: About Our Ethics ‘The handbook states clearly our expectation that all employees will conduct business in accordance with the law, our policies, our values and our business-ethics principles. It contains rules and guidance on how employees are to conduct business, whether dealing with customers, suppliers or each other. It reminds employees to sustain General Dynamics’ ethical business reputation by adhering to our principles of integrity, honesty and respect.’ ‘We have adopted additional ethics codes specifically applicable to our financial professionals and the Board of Directors to supplement the Blue Book. The Code of Ethics for Financial Professionals applies to the chief executive officer, chief financial officer, controller, and any person performing similar financial functions for General Dynamics. All personnel subject to the Finance Code are required to periodically recertify their compliance. In addition, there is a Code of Conduct for members of the Board of Directors that embodies the board’s commitment to manage our business in accordance with the highest standards of ethical conduct. Copies of the Blue Book, Code of Ethics and Code of Conduct are available in the Corporate Governance section of this website.’ http://www.generaldynamics.com/about/about-our-ethics/ GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

Corporate Governance Guidelines (May 2014), p.8: ‘Codes of Ethics. The Board expects General Dynamics directors, officers and employees to act ethically at all times. To that end, directors are subject to the Code of Conduct for Directors and all officers and employees are subject to the policies comprising General Dynamics’ code of conduct set forth in the Company's Standards of Business Ethics and Conduct handbook. The CEO, chief financial officer, controller and all persons performing similar functions are subject to an additional code of ethics. All of these ethics policies are posted on the General Dynamics’ website.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govHighlights

Standards of Business Ethics and Conduct (June 2013), p.5: ‘The Blue Book applies to all officers, executives, and full-time, part-time, and temporary employees of General Dynamics’

Code of Conduct for Members of the Board of Directors (August 2013), p.2: ‘General Dynamics operates in a highly regulated environment. Many federal, state and foreign agencies direct how General Dynamics conducts its business. When acting on behalf of and for General Dynamics, we will comply with applicable laws, rules and regulations. We will provide prompt and full disclosure to the Company of any information necessary for the Company to comply with its obligations under applicable laws, rules and regulations, as well as the rules and regulations of private and public regulatory agencies and organizations to which the Company is subject.’ NOTE: This Code does not specifically address bribery or corruption http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

Code of Ethics for Financial Professionals (August 2013), p.1: ‘This Code of Ethics for Financial Professionals (this “Code”) applies to the Chief Executive Officer, Chief Financial Officer, Controller and any person performing similar functions for General Dynamics Corporation or any of its subsidiaries (each a “Covered Executive”). Like all of our employees, Covered Executives are expected to conduct themselves in accordance with the very highest standards of ethical conduct and to comply with all applicable legal and regulatory requirements. This Code is intended to supplement our other policies and procedures, including our Standards of Business Ethics and Conduct handbook.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

Proxy Statement 2014, p.9: ‘We also have adopted ethics codes specifically applicable to our Board of Directors and our financial professionals. The Code of Conduct for Members of the Board of Directors embodies our Board’s commitment to manage our business in accordance with the highest standards of ethical conduct. The Code of Ethics for Financial Professionals, which

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supplements the Blue Book, applies to our chief executive officer, chief financial officer, controller and any person performing similar financial functions.’

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A20: Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Score:

Comments: Based on public information, there is evidence that the company has a policy on conflicts of interest. It is written with clear wording and a definition and examples are provided. The Code of Conduct for Members of the Board of Directors includes a conflicts of interest policy for Board members.

References: Public: Corporate Governance Guidelines (May 2014), pp.8-9: ‘Conflicts of Interest. If an actual or potential conflict of interest arises for a director, the director will promptly inform the CEO, the chair of the Nominating and Corporate Governance Committee, or the Corporate Secretary. All directors will recuse themselves from any discussion or decision affecting their personal, business or professional interests. The Board will resolve any conflict of interest question involving the CEO, and the CEO will resolve any conflict of interest issue involving any other officer of the Company.’

Standards of Business Ethics and Conduct (June 2013), p.7: ‘A conflict of interest occurs when your private interests interfere — or appear to interfere — with the interests of General Dynamics. You should base business decisions on our companyʼs needs, rather than your own interests, the interests of family or friends, or your desire for personal gain. You should not do business with organizations in which you, or your family, have a substantial financial interest. Each of us should deal with suppliers, customers, and others in ways that avoid even the appearance of a conflict between our personal interests and those of General Dynamics. Talk to your business unitʼs ethics officer and disclose any situation that presents or might present a conflict of interest.’

(p.8): ‘The following situations can easily give rise to conflicts of interest:

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Personal Business Relationships You should disclose to your business unitʼs ethics officer 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 conflicts of interest for you and our company. Be careful that your personal business relationships do not influence the decisions you make on behalf of General Dynamics. Organizational Relationships If you or an immediate family member serve as a director, officer, or consultant for any company that does business with us, you must disclose these obligations to your business unitʼs ethics officer even if this service is unpaid. Outside Employment Before you accept outside employment, consider if this second job could create a conflict of interest with your work here or negatively impact your ability to do your job. Taking a second job can be tricky because you may not always see clearly where your loyalties should lie. Do not accept outside employment with our competitors, suppliers, or customers.’

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A21: Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Score:

Comments: Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of gifts. However, the rules of the policy are unclear. Employees must avoid giving or receiving gifts above a modest value when dealing with commercial customers, and are instructed to consult their business unit’s ethics officer before offering or retaining any gift of greater than nominal value. The company therefore scores 1. To score higher the company would need to provide evidence of upper limits for gift exchange and/or a specific threshold necessary for senior authorisation.

References: Public: Standards of Business Ethics and Conduct (June 2013), p.8: ‘Gifts and Hospitality: Commercial Customers Gifts We compete solely on the merits of our products and services. When people exchange gifts in a business context, it can look as if favors were granted in order to influence business judgment. We may provide gifts, meals, refreshments, and entertainment of reasonable value in the course of doing business with commercial customers or non-government personnel, provided that this practice does not conflict with our standards or the standards of the recipientʼs organization. You should not give or offer any gift if, under the circumstances, such a gift might appear to be improper. Receipt of Gifts Generally, you should not accept gifts, meals or entertainment from those with whom we do business unless this activity serves a legitimate business purpose and is appropriate for the relationship. You may accept small gifts that are of modest value only. When conducting business in some countries, it may be customary to accept gifts of substantial value. These gifts are company property and must be reported to your business unitʼs ethics officer for disposition. For example, they can be purchased from the company GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

at fair market value, or donated to an appropriate charity on behalf of General Dynamics. Regarding the giving or receiving of gifts, you have the following responsibilities: • Do not offer or provide gifts when prohibited by the recipientʼs rules, standards, or policies • Avoid giving or receiving gifts above modest value when dealing with commercial customers • Ensure that meals and entertainment have valid business purposes • Before offering or retaining any gift of greater than nominal value, consult your business unitʼs ethics officer’

(p.12): ‘Gifts and Hospitality: Government Customers We compete solely on the merits of our products and services. We do not try to influence a customerʼs decision to purchase from General Dynamics by offering gifts, meals, or entertainment. Most governments have regulations prohibiting their employeesʼ acceptance of items of value from contractors or suppliers. We carefully follow these regulations and policies when dealing with government officials and their representatives. These regulations can be complex, so make sure you understand them. Seek guidance from your business unitʼs ethics officer, who will consult the Legal Department as appropriate. The giving of gifts, meals, or anything of value to government and public officials is almost always prohibited. Never give money or anything else of value to a government or public official for the purpose of improperly influencing an official decision or obtaining or retaining business. Consult your business unitʼs ethics officer before offering anything of value to a government or public official. Before making any payments to facilitate routine government action, you must get advance approval from the Legal Department. In addition, any gift given to a government or public official must be recorded properly in our books and records.’

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A22: Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Score:

Comments: Based on public information, there is evidence that the company has a policy that regulates the giving and receipt of hospitality. However, the rules of the policy are unclear. Employees must ensure meals and entertainment have valid business purposes and that they are of reasonable value. The company therefore scores 1. To score higher the company would need to provide evidence of upper limits for hospitality exchange and/or a specific threshold necessary for senior authorisation.

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A23: Does the company have a policy that explicitly prohibits facilitation payments?

Score:

Comments: Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

References: Public: TI notes: Standards of Business Ethics and Conduct (June 2013), p.12: ‘Before making any payments to facilitate routine government action, you must get advance approval from the Legal Department.’

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A24: Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Score:

Comments: Based on public information, there is evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. All corporate political contributions must be approved by the Senior Vice President, Planning and Development. The company's Board of Directors receives annual briefings on prior-year corporate-wide political spending. The company discloses the amount it discloses yearly, but not the recipients.

References: Public: Standards of Business Ethics and Conduct (June 2013), p.9: ‘Lobbying and Political Contributions Do not contribute any company funds or other assets directly or indirectly to any political party or to the campaign for or against any candidate for political office, if prohibited by law. Seek legal advice before contributing anything to a charity that is affiliated with a politician. We encourage you to participate individually in political affairs with your own time and resources.’

Company website: Corporate Governance - Political Contributions ‘General Dynamics participates in the U.S. political process when it is in the best interests of its shareholders, businesses and employees to do so. Participation in this process ensures that the company's interests as a leading member of the defense and aerospace industries, as well as a large employer, are well represented. Process and Oversight The company has a comprehensive oversight process to ensure that political contributions are made in a legal, ethical and transparent manner that best represents the interests of our

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shareholders. Corporate political contributions are made pursuant to the company's Delegation of Authority, as established by the Board of Directors, which requires that all corporate political contributions be approved by the Senior Vice President, Planning and Development who oversees the company's government relations. The company's Board of Directors receives annual briefings on prior-year corporate-wide political spending. As part of an effort to ensure compliance with all applicable laws relating to political activities and effective corporate governance, we have a written policy governing lobbying practices. This policy covers compliance with laws and regulations regarding the lobbying of government officials, the duty to track and report lobbying costs and expenses as nondeductible for tax purposes and unallowable for purposes of U.S. Government contracts. It requires that all lobbying contacts with covered government officials be coordinated with and approved by the Senior Vice President, Planning and Development.’

‘501(c)(4)/527/State & Local Contributions. The company has made contributions on a limited basis to 501(c)(4) and 527 organizations as well as to state and local candidates, where permissible and in accordance with all laws and regulations. In April 2014, the company determined to no longer make contributions to 501(c)(4) and Section 527 organizations. In 2013, our total 501(c)(4)/527/State & Local Contributions expenditures were $225,600. 501(c)(4) Contributions $165,000 (4 organizations) 527 Contributions $25,000 State & Local Contributions $35,600 2013 Corporate Contributions $225,600

Tax-exempt organizations that Write and Endorse Model Legislation. General Dynamics has not been a member of or made payments to any organization that writes and endorses model legislation, such as the American Legislative Exchange Council. If this policy changes, we will disclose this development. Employee Political Contributions Summary General Dynamics offers certain eligible employees (as determined by federal election laws) an opportunity to make political contributions through a company-sponsored Political Action Committee (PAC), called the General Dynamics Corporation Political Action Committee (GDC PAC). The General Dynamics employee PAC is organized and operated on a strictly voluntary, nonpartisan basis and is registered with the Federal Election Commission. The PAC's political contributions are reported monthly to the Federal Election Commission. Detailed information about the PAC's donations can be accessed on the U.S. Federal Election Commission website. PAC Process and Oversight A committee of senior management employees administers the company's employee PAC. In conjunction with this committee's oversight, the PAC contributions are subject to a robust

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internal review process. PAC expenditures are reviewed to ensure they represent the best interests of the company, its employees and its shareholders. Additionally, internal financial controls exist to ensure company compliance with federally mandated contribution limits.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-politicalcontributions

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A25: Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Score:

Comments: Based on public information, there is evidence that the company has a policy on engagement in lobbying activities. The policy states that all lobbying contacts with covered government officials must be coordinated with and approved by the Senior Vice President, Planning and Development. Each quarter the company files a publicly available federal Lobbying Disclosure Act report that provides specific information on all General Dynamics lobbying activities. The company website details the total company lobbying expenditures for the past three years.

References: Public: Company website: Corporate Governance - Political Contributions ‘General Dynamics participates in the U.S. political process when it is in the best interests of its shareholders, businesses and employees to do so. Participation in this process ensures that the company's interests as a leading member of the defense and aerospace industries, as well as a large employer, are well represented. Process and Oversight The company has a comprehensive oversight process to ensure that political contributions are made in a legal, ethical and transparent manner that best represents the interests of our shareholders. Corporate political contributions are made pursuant to the company's Delegation of Authority, as established by the Board of Directors, which requires that all corporate political contributions be approved by the Senior Vice President, Planning and Development who oversees the company's government relations. The company's Board of Directors receives annual briefings on prior-year corporate-wide political spending. As part of an effort to ensure compliance with all applicable laws relating to political activities and effective corporate governance, we have a written policy governing lobbying GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

practices. This policy covers compliance with laws and regulations regarding the lobbying of government officials, the duty to track and report lobbying costs and expenses as nondeductible for tax purposes and unallowable for purposes of U.S. Government contracts. It requires that all lobbying contacts with covered government officials be coordinated with and approved by the Senior Vice President, Planning and Development.’ ‘Lobbying Contributions. Each quarter we file a publicly available federal Lobbying Disclosure Act report that provides specific information on all General Dynamics lobbying activities. This report captures all of the company's lobbying expenditures, including all federal and state direct, indirect and grassroots lobbying. Our quarterly lobbying report, which can be found at the U.S. House of Representatives Office of the Clerk website, describes the specific pieces of legislation that were the subject of our lobbying efforts and identifies the individuals who lobbied on behalf of our company. Outside consultants who lobby on our behalf also file reports detailing their efforts on the company's behalf, and any sums we expend on those consultants are included in our own report. In 2013, our total lobbying expenditures were $11.1 million; in 2012, $10.9 million; and in 2011, $11.4 million. State lobbying expenditures and grassroots lobbying represent a very small portion of our annual spend.’ http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-politicalcontributions

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A25(a): Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Score:

Comments: Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

References: Public: TI notes: Standards of Business Ethics and Conduct (June 2013), p.13: ‘Community Relationships General Dynamics actively supports the communities in which we do business. Our civic activities demonstrate good corporate citizenship. We encourage you to participate in volunteer opportunities and community events on your own time or during work periods with management approval.’

(p.9) : ‘Seek legal advice before contributing anything to a charity that is affiliated with a politician.’

Corporate Sustainability Report (June 2012), p.9: ‘General Dynamics is committed to supporting and sustaining the environments and communities in which our employees work and live. Our support is wide-ranging, from veterans and military families to the arts and education.’

(p.11) : ‘General Dynamics supports the communities where employees work and live through organizations that have an educational, social, civic and arts focus. Our business units develop and administer their own community service programs to align with their local community’s needs. They use employee-formed committees and employee input to GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

determine how the business unit can bring together its financial and volunteer resources.’

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A26: Does the company provide written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda?

Score:

Comments: Based on public information, there is limited evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. The Standards of Business Ethics and Conduct contains an Ethical Decision-Making Model and some conflicts of interest examples. The company therefore scores 1. To score higher the company would need to provide evidence of written guidance that contains scenarios to illustrate particular situations.

References: Public: Standards of Business Ethics and Conduct (June 2013), p.6: ‘Follow the steps in our Ethical Decision-Making Model: • Have I reviewed the facts carefully? • Have I used the resources available to me? • Have I considered all the issues? • Have I thought carefully about my options? • Have I considered the consequences of my choices? • Will my decision stand the test of time? The Ethical Decision-Making Model is a tool to help employees make good decisions. It can be found on the Ethics Helpline website at www.gd.ethicspoint.com.’

or your family, have a substantial financial interest. Each of us should deal with suppliers, customers, and others in ways that avoid even the appearance of a conflict between our personal interests and those of General Dynamics. Talk to your business unitʼs ethics officer and disclose any situation that presents or might present a conflict of interest.’

(p.8): ‘The following situations can easily give rise to conflicts of interest: Personal Business Relationships You should disclose to your business unitʼs ethics officer 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 conflicts of interest for you and our company. Be careful that your personal business relationships do not influence the decisions you make on behalf of General Dynamics. Organizational Relationships If you or an immediate family member serve as a director, officer, or consultant for any company that does business with us, you must disclose these obligations to your business unitʼs ethics officer even if this service is unpaid. Outside Employment Before you accept outside employment, consider if this second job could create a conflict of interest with your work here or negatively impact your ability to do your job. Taking a second job can be tricky because you may not always see clearly where your loyalties should lie. Do not accept outside employment with our competitors, suppliers, or customers.’

(p.18): ‘We make the following tools and resources available: • Policies and procedures • Training and education • Confidential resources where you can ask questions, get advice, and make reports • The General Dynamics Business Ethics Helpline, available via telephone or on the web at www.gd.ethicspoint.com • Ethics and compliance offices in the business units and at corporate headquarters’

Corporate Sustainability Report (June 2012), p.4: ‘In addition, a variety of initiatives reinforce the General Dynamics ethics program, including the ones highlighted below. - Regular ethics related columns in the employee newsletters of several of our business units. - An “Ethical Moments” video vignette initiative at Gulfstream and Information Technology explores the ethical dilemmas employees may face on the job and provides guidance on ethical decision-making. - An annual “Ethics Arts Festival” allows employees from across Armament and Technical

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Products to use artistic creativity to promote ethics in the workplace. - The “President’s Ethics and Integrity Award” at Advanced Information Systems recognizes individuals who exemplify our ethical standards in their everyday conduct. - Information Technology launched the “TeamTalks” ethics communications program to facilitate ongoing communications and discussions between managers and employees about their responsibilities and to enhance understanding of our standards of ethical business conduct.’

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A27: Does the company have a training programme that explicitly covers anti- corruption?

Score:

Comments: Based on public information, there is evidence that the company has a training programme on its ethics programme. However, evidence does not suggest the company has an explicit anti-corruption module as part of this programme. The company therefore scores 1.

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http://www.generaldynamics.com/about/about-our-ethics/

Standards of Business Ethics and Conduct (June 2013), p.18: ‘As an employee, you are expected to: • Read, understand, and use the Blue Book • Learn the details of the policies that specifically impact your work assignments • Use the resources available to you for guidance and assistance • Take the training required to do your job • Perform your job in accordance with our business ethics standards • Hold co-workers accountable for ethical work standards • Share concerns about possible ethical misconduct with your supervisor, ethics officer, another member of management, or the Ethics Helpline • Cooperate with any internal investigations about a reported ethics or compliance matter When you are uncertain about the right course of conduct, ask questions and get answers before you act.’

Proxy Statement 2014, p.9: ‘Our ethics program also includes a 24-hour ethics helpline, which employees can access via telephone or online to communicate any business-related ethics concerns, and periodic training on ethics and compliance topics for all employees.’

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A28: Is anti-corruption training provided in all countries where the company operates or has company sites?

Score:

Comments: Based on public information, there is evidence that the company’s training on its ethics programme, which includes an anti-corruption policy, is provided to all employees.

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A29: Does the company provide targeted anti-corruption training to members of the Board?

Score:

Comments: Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

References: Public: NA

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A30: Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Score:

Comments: Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions. TI notes that the company states that employees receive training on any specific topic areas that are critical to the performance of their jobs. However, there is no suggestion that this is tailored anti-corruption training for employees in sensitive positions.

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-Receiving reports of employee concerns regarding ethical matters; and -Conducting and overseeing prompt, thorough and objective investigations of all reported allegations of suspected ethical misconduct and taking corrective action, if necessary.’ http://www.generaldynamics.com/about/about-our-ethics/

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A31: Does the company have a clear and formal process by which employees declare conflicts of interest?

Score:

Comments: Based on public information, there is evidence that the company has a clear and formal process by which employees declare conflicts of interest, which involves conflicts being reported to their business unit’s ethics officer.

(p.8): ‘The following situations can easily give rise to conflicts of interest: Personal Business Relationships

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You should disclose to your business unitʼs ethics officer 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 conflicts of interest for you and our company. Be careful that your personal business relationships do not influence the decisions you make on behalf of General Dynamics. Organizational Relationships If you or an immediate family member serve as a director, officer, or consultant for any company that does business with us, you must disclose these obligations to your business unitʼs ethics officer even if this service is unpaid. Outside Employment Before you accept outside employment, consider if this second job could create a conflict of interest with your work here or negatively impact your ability to do your job. Taking a second job can be tricky because you may not always see clearly where your loyalties should lie. Do not accept outside employment with our competitors, suppliers, or customers.’

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A32: Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Score:

Comments: Based on public information, there is evidence that the company is explicit in its commitment to apply disciplinary procedures to all employees who violate the Code of Conduct. The company uses wording that signifies an explicit commitment such as ‘will.’ However, evidence does not show that the company has a commitment to apply disciplinary procedures to Board members.

References: Public: Standards of Business Ethics and Conduct (June 2013), p.18: ‘If we find that our standards have been violated, we will take action, including imposing disciplinary action, implementing system-wide changes, or notifying the right governmental office or agency as appropriate. Not only will we deal with a specific situation, but we will also make changes so that similar problems do not recur.’

(p.20): ‘Disciplinary Action Violations of laws, regulations, principles, this Blue Book, or our policies can have severe consequences for you and for General Dynamics. Some violations may be criminal in nature and punishable by fine or imprisonment. Violations can jeopardize our relationships with our customers and suppliers, and could result in loss of the privilege to do business in the countries where we operate. Employees who violate the laws, regulations, this Blue Book, or our policies are subject to disciplinary action, in accordance with applicable laws, which may involve any of a variety of measures as appropriate, up to and including dismissal. All disciplinary action is decided on a case by case basis.’

Code of Conduct for Members of the Board of Directors (August 2013), p.2: ‘If we learn of any violation of this Code, or any violation of laws involving the Company or GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

any of us, as members of the Board, we will promptly report the matter to the Company’s General Counsel.’ NOTE: This Code of Conduct does not address bribery or corruption

Code of Ethics for Financial Professionals (August 2013), p.1: ‘You are expected to proactively promote ethical behavior and you will be held accountable for any violations of this Code, with consequences up to and including termination of employment.’

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A33: Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Score:

Comments: Based on public information, there is evidence of multiple, well-publicised channels that are accessible and secure for employees to report concerns or instances of suspected corrupt activity. Employees are able to report to their business unit’s ethics officer, the Legal Department or the corporate Ethics Office. An Ethics Helpline managed by a third party is available 24/7, by Freephone or by online reporting tool, which allows anonymous reporting. Calls can be accepted in 30 different languages and the Ethics Helpline website lists numbers for every country in which the company has employees.

References: Public: Company website: About Our Ethics ‘In addition to communicating our standards in the Blue Book, the ethics program also helps sustain our reputation by detecting and addressing unethical conduct early. Our program includes a 24-hour-a-day, seven-day- a-week, confidential Business Ethics Helpline. Employees can contact the Helpline via telephone or secure website to communicate any business ethics-related concerns or seek guidance on inquiries. Callers may remain anonymous if they wish. The helpline accepts calls in 30 different languages. All matters are investigated and resolved promptly.’ http://www.generaldynamics.com/about/about-our-ethics/

Corporate Governance Guidelines (May 2014), p.9: ‘Accounting Concerns or Complaints. Concerns or complaints regarding the Company’s accounting, internal accounting controls or auditing matters, may be communicated directly to the Audit Committee. Such communications may be confidential and anonymous, and can be submitted in writing or reported by telephone. Written communications should be GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

submitted to the chair of the Audit Committee in care of the Ethics Officer of the Company, at the address set forth on the Company’s website. Telephone reports may be made by employees of the Company via a toll-free helpline number that is provided to all employees. All communications will be reviewed, investigated and addressed in the ordinary course by the Company’s Ethics Officer unless otherwise instructed by the Audit Committee. The status of all such concerns and complaints will be reported to the Audit Committee on a quarterly basis, or more frequently as determined by the Committee. The Audit Committee may direct that certain matters be presented to the full Board and may direct special treatment, including the retention of outside advisors or counsel, for any concern or complaint addressed to it.’

Standards of Business Ethics and Conduct (June 2013), p.19: ‘You can contact our Ethics Helpline at any time to ask a question, express a concern or report a possible violation of laws, regulations, or policies. When reporting a concern, you may be asked to provide the time, location, names of the people involved, and other details so that we can investigate your concerns. Every report to the Helpline is handled promptly, discreetly, and professionally. You may access the Helpline at www.gd.ethicspoint.com or call toll-free.’

(p.20): ‘If you believe that someone associated with General Dynamics has violated our standards, you are expected to bring the matter in good faith to the attention of your supervisor or manager, your business unitʼs ethics officer, Legal Department, or the GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

corporate Ethics Office so that we can conduct a prompt and thorough investigation. You can make reports by telephone, through e-mail, by making an appointment, or by contacting our Helpline. Web reports are accepted at www.gd.ethicspoint.com. You may also contact the Audit Committee of the General Dynamics Board of Directors to report concerns about accounting or auditing matters by writing to: Audit Committee, General Dynamics, P.O. Box 2161, Merrifield, Virginia, 22116-2161, U.S.A.’

EthicsPoint website: General Dynamics Ethics Helpline ‘General Dynamics has high ethical standards for conducting our business. If you believe someone has violated our standards, we want you to tell us so that we can investigate and, if necessary, correct any problems. If you have a question or concern about potential misconduct, there are many resources available to help you. You can talk to your supervisor, Human Resources, your Ethics Officer, or another member of management. We also encourage you to use this Helpline as a resource to ask questions, seek guidance, or report any suspected misconduct.’ www.gd.ethicspoint.com

Helpline Frequently Asked Questions, p.1: ‘The Helpline is operated by EthicsPoint, an independent third-party contractor. EthicsPoint’s independence from General Dynamics is designed to give employees an added level of comfort and security that their reports will remain confidential.’ ‘The Helpline has two methods of intake. The first is by toll-free telephone number, which is staffed 24 hours a day, seven days a week, every day of the year. When you call, a professionally trained EthicsPoint intake specialist will guide you through a series of questions designed to identify the relevant details of your report or question. If you wish to give your name and contact information, the intake specialist will note that information as well. You may choose to remain anonymous’

(p.2): ‘General Dynamics has established toll-free numbers in every country in which the company has employees. Multilingual operators are available so that callers can make reports or ask questions in their native tongue.’

(p.3): ‘In all countries except those that prohibit anonymous reporting, you may choose to remain anonymous. Although it may be easier in many cases to resolve your issue by having you identify yourself, you are not required to do so. If you choose to remain anonymous, no effort will be made by either EthicsPoint or General Dynamics to identify you.’ https://secure.ethicspoint.com/domain/media/en/gui/29084/faq.pdf

Additonal Ways to Report – Ethics Resources (May 2014) Provides the contact details for Ethics Officers in different business units, the Audit Committee and the U.S. Department of Defence Hotline

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https://secure.ethicspoint.com/domain/media/en/gui/29084/additional.pdf

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A33(a): Are the whistleblowing channels available to all employees in all geographies?

Score:

Comments: Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. For example, employees can report to the Ethics Helpline, their business unit’s ethics officer, the Legal Department, or the corporate Ethics Office.

References: Public: Standards of Business Ethics and Conduct (June 2013), p.19: ‘You can contact our Ethics Helpline at any time to ask a question, express a concern or report a possible violation of laws, regulations, or policies. When reporting a concern, you may be asked to provide the time, location, names of the people involved, and other details so that we can investigate your concerns. Every report to the Helpline is handled promptly, discreetly, and professionally. You may access the Helpline at www.gd.ethicspoint.com or call toll-free.’

(p.20): ‘If you believe that someone associated with General Dynamics has violated our standards, you are expected to bring the matter in good faith to the attention of your supervisor or manager, your business unitʼs ethics officer, Legal Department, or the corporate Ethics Office so that we can conduct a prompt and thorough investigation. You can make reports by telephone, through e-mail, by making an appointment, or by contacting our Helpline. Web reports are accepted at www.gd.ethicspoint.com. You may also contact the Audit Committee of the General Dynamics Board of Directors to report concerns about accounting or auditing matters by writing to: Audit Committee, General Dynamics, P.O. Box 2161, Merrifield, Virginia, 22116-2161, U.S.A.’

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(p.20): ‘If you believe that someone associated with General Dynamics has violated our standards, you are expected to bring the matter in good faith to the attention of your supervisor or manager, your business unitʼs ethics officer, Legal Department, or the corporate Ethics Office so that we can conduct a prompt and thorough investigation. You can make reports by telephone, through e-mail, by making an appointment, or by contacting our Helpline. Web reports are accepted at www.gd.ethicspoint.com. You may also contact the Audit Committee of the General Dynamics Board of Directors to report concerns about accounting or auditing matters by writing to: Audit Committee, General Dynamics, P.O. Box 2161, Merrifield, Virginia, 22116-2161, U.S.A.’

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A33(b): Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Score:

Comments: Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively.

References: Public: NA

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A34: Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Score:

Comments: Based on public information, there is evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption- related issues. For example, employees can raise ethics concerns with their business unit’s ethics officer, the Legal Department or the Ethics Helpline.

References: Public: Standards of Business Ethics and Conduct (June 2013), p.6: ‘You have many resources to help you with questions about ethics and compliance. If you know the answer to an ethics question and are comfortable with your decision, you can act with confidence. If not, you have several places where you may turn for advice and guidance: • Your supervisor or manager • Your local ethics office representative • Your business unitʼs ethics officer • The Human Resources Department • The Environmental, Safety, and Health representative • The Security Department • The Finance or Internal Controls Department • The Legal Department • The General Dynamics corporate Ethics Office • The General Dynamics Ethics Helpline Contact information for the business unit and corporate ethics officers is available on the Ethics Helpline website under Additional Resources at www.gd.ethicspoint.com. On the website, you can also find toll-free Helpline telephone numbers from every country in which

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General Dynamics has employees.’

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A35: Is there a commitment to non-retaliation for bona fide reporting of corruption?

Score:

Comments: Based on public information, there is evidence that the company has a commitment to non- retaliation for bona fide reporting of corruption. However, there is no evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.

References: Public: Company website: About Our Ethics ‘An extremely important facet of the Blue Book is the prohibition against retaliation for any person who raises in good faith an ethics or compliance issue.’ http://www.generaldynamics.com/about/about-our-ethics/

Corporate Governance Guidelines (May 2014), p.9: ‘The Company’s Standards of Business Ethics and Conduct handbook prohibits retaliation against any person who raises in good faith an ethics or compliance issue.’

Standards of Business Ethics and Conduct (June 2013), p.20: ‘Prohibition Against Retaliation General Dynamics will not retaliate against any person who brings to our attention in good faith an ethics or compliance issue. Individuals who raise concerns or who help us resolve reported matters are protected against retaliation. Anyone who uses the ethics and compliance program to spread falsehoods, threaten others, or damage another personʼs reputation will be subject to disciplinary action. Discouraging other employees from making a report or getting the help they need is prohibited and could result in disciplinary action.’

Corporate Sustainability Report (June 2012), p.3: GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM

‘The Blue Book strictly prohibits retaliation against anyone who raises an ethics or compliance issue in good faith.’

Helpline Frequently Asked Questions, p.2: ‘General Dynamics strictly forbids retaliation of any kind against those who have chosen to use the Helpline to make good faith reports about ethics concerns.’

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Information sources:

Company website: www.generaldynamics.com http://investorrelations.gd.com

Annual Report 2013 http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol- reportsAnnual

Audit Committee Charter (May 2014) http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol- govHighlights

Code of Conduct for Members of the Board of Directors (August 2013) http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

Code of Ethics for Financial Professionals (August 2013) http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

Corporate Governance Guidelines (May 2014) http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol- govHighlights

Corporate Sustainability Report (June 2012) http://www.gd.com/downloads/pdf/about/GD_Corporate_Sustainability_Re port.pdf

Helpline Frequently Asked Questions https://secure.ethicspoint.com/domain/media/en/gui/29084/faq.pdf

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Nominating and Corporate Governance Committee Charter (May 2014) http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol- govHighlights

Proxy Statement 2014 http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=proxy

Standards of Business Ethics and Conduct (June 2013) http://investorrelations.gd.com/phoenix.zhtml?c=85778&p=irol-govconduct

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