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(p.5): ‘Business Ethics and ComplianceWhen we talk about business ethics, we refer to the commitments that make our companygreat. We deal fairly with our companyʼs customers, suppliers, and competitors, as well aswith each other. Each of us should strive to be: Law abiding Honest and trustworthy Responsible and reliable Fair and cooperativeWhen we talk about compliance, we refer to the laws, rules, regulations, and policies thatcontrol and direct both our actions and those of our company. The Blue Book includesinformation 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 topromote a culture of ethics and integrity that defines how we do business. At the core, weare in business to earn a fair return for our shareholders. To that end, our Board of Directorsbelieves that a commitment to good corporate governance helps us compete moreeffectively, sustain our success over the long term and enhance shareholder html?c 85778&p proxyCorporate Sustainability Report (June 2012), pp.1-2:‘Throughout our history, we at General Dynamics have endeavored to deliver the highestquality 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 interactwith employees, customers, partners and shareholders. We also bring this culture and ourcorporate values in our approach to sustaining the environments in which we work and live.These values of ethical behavior, integrity, innovation and continuous improvement havebeen evident since our beginnings in the 1950s, when General Dynamics was createdthrough the combination of Electric Boat, Canadair, Consolidated Vultee and StrombergCarlson. They were evident in our earliest accomplishments and they continue to be evidenttoday throughout our four business groups: Aerospace, Combat Systems, InformationSystems and Technology and Marine Systems.Our values have empowered us to produce innovative products and services, such as thebest-in-class business jets built by Gulfstream, which have a global reputation for superioraircraft design, quality, safety and reliability. They manifest themselves in our production ofthe Stryker family of combat vehicles which, along with the Abrams main battle tank, havebecome a mainstay of the U.S. Army’s ground vehicle fleet and are now in demand amongAllied nations as well.These same values are present in the Information Systems and Technology group, in ourprovision of the U.S. Army’s next-generation broadband on-the-move tactical network, aGENERAL DYNAMICS TIONS.GD.COM

prime example of continuous improvement and innovation in action. What’s more, thesevalues drive the manufacturing of our state-of-the-art combatant and auxiliary ships andsubmarines, such as the Virginia-class submarines, which are essential to the U.S. Navy’smissions worldwide.Our accomplishments are not limited to the equipment we manufacture and the services weprovide. 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 andextending through our communities and the physical environment we all inhabit, GeneralDynamics is committed to leadership and excellence. We bring our culture of ethicalbehavior, integrity, innovation and continuous improvement to these environments. Inshort, we endeavor to “do the right thing,” and we are equally proud of ouraccomplishments in, and our attention to, these environments.’(p.3): ‘The Blue Book clearly states our expectation that all employees will conduct GeneralDynamics’ business in accordance with the law, our policies, our values and our businessethics 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 sustainGeneral Dynamics’ ethical business reputation by adhering to our principles of integrity,honesty and D Corporate Sustainability Report.pdfGENERAL DYNAMICS TIONS.GD.COM

A5:Does the company belong to one or more national or international initiativesthat promote anti-corruption or business ethics with a significant focus onanti-corruption?Score:2Comments:Based on public information, there is evidence that the company is a member of IFBEC and asignatory of the DII.References:Public:IFBEC website: Our MembersGeneral Dynamics and General Dynamics European Land Systems are members of IFBEC.http://ifbec.info/our-members/DII website: SignatoriesGeneral Dynamics is a signatory.http://www.dii.org/signatoriesGENERAL DYNAMICS TIONS.GD.COM

A6:Has the company appointed a Board committee or individual Board memberwith overall corporate responsibility for its ethics and anti-corruptionagenda?Score:2Comments:Based on public information, there is evidence that the company’s Audit Committee hasoverall corporate responsibility for the company’s ethics programme. The Committeemonitors the management’s implementation of the policies and practices of the Standardsof Business Ethics and Conduct Programme.References:Public:Company website: About Our Ethics‘The General Dynamics ethics program provides many resources to help employees “do theright thing.” Day-to-day oversight is provided at the corporate office by an ethics programmanager. Overall leadership is provided by a chief ethics officer who reports directly to theChairman and CEO on all ethics program matters. The ethics officer briefs the AuditCommittee of the Board of Directors twice a year at regularly scheduled meetings. Inaddition, 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 localethics 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 ethicsprogram 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 makedecisions;-Receiving reports of employee concerns regarding ethical matters; andGENERAL DYNAMICS TIONS.GD.COM

-Conducting and overseeing prompt, thorough and objective investigations of all reportedallegations of suspected ethical misconduct and taking corrective action, if about-our-ethics/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; thequalifications, performance and independence of the Corporation’s independent auditors;the performance of the Corporation’s internal audit function; and compliance by theCorporation with legal and regulatory requirements. The Committee will also prepare areport as required by the Securities and Exchange Commission (the “Commission”) to beincluded in the Corporation’s annual proxy statement.’(p.4): ‘Corporation Policies. The Committee will monitor management’s implementation ofthe 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 .zhtml?c 85778&p irol-govHighlightsNominating and Corporate Governance Committee Charter (May 2014), p.1:‘Purpose. The Nominating and Corporate Governance Committee (the “Committee”) of theBoard of Directors (the “Board”) will assist the Board in identifying qualified individuals toserve as Board members, recommending committee assignments and responsibilities to theBoard, evaluating Board and management effectiveness, developing and recommending tothe Board corporate governance guidelines, and generally advising the Board on corporategovernance and related matters.’(p.2): ‘The Committee will develop and recommend to the Board corporate governanceguidelines that comply with all applicable legal and regulatory requirements. Updates to theguidelines will be recommended by the Committee periodically as the Committee deemsappropriate.’‘The Committee will monitor developments, trends and best practices in corporategovernance, and take such actions in accordance therewith as it deems enix.zhtml?c 85778&p irol-govHighlightsProxy Statement 2014, p.12:GENERAL DYNAMICS TIONS.GD.COM

Audit Committee responsibilities include‘Monitors management’s implementation of the policies, practices and programs of thecompany in several areas, including business ethics and conduct, employee safety andhealth standards, and environmental matters’(p.13): Nominating and Corporate Governance Committee responsibilities include:‘ Advises the Board on corporate governance matters and monitors developments, trendsand best practices in corporate governance Recommends to the Board corporate governance guidelines that comply with legal andregulatory requirements’GENERAL DYNAMICS TIONS.GD.COM

A7:Has the company appointed a person at a senior level within the company tohave responsibility for implementing the company’s ethics and anticorruption agenda, and who has a direct reporting line to the Board?Score:1Comments:Based on public information, there is evidence that the company has appointed a ChiefEthics Officer with responsibility for implementing the company’s ethics programme. TheChief Ethics Officer has overall leadership of 13 business unit ethics officers and 120 localethics officers who implement the ethics programme; he or she reports directly to theChairman and CEO, and the Audit Committee. The company therefore scores 1. To scorehigher the company would need to provide evidence that the Chief Ethics Officer isidentifiable by name.References:Public:Company website: About Our Ethics‘The General Dynamics ethics program provides many resources to help employees “do theright thing.” Day-to-day oversight is provided at the corporate office by an ethics programmanager. Overall leadership is provided by a chief ethics officer who reports directly to theChairman and CEO on all ethics program matters. The ethics officer briefs the AuditCommittee of the Board of Directors twice a year at regularly scheduled meetings. Inaddition, 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 localethics 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 ethicsprogram 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 makeGENERAL DYNAMICS TIONS.GD.COM

decisions;-Receiving reports of employee concerns regarding ethical matters; and-Conducting and overseeing prompt, thorough and objective investigations of all reportedallegations of suspected ethical misconduct and taking corrective action, if 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 ChiefEthics Officer who reports directly to the Chairman and Chief Executive Officer on all ethicsprogram matters, and regularly briefs the Audit Committee of the board of directors.’GENERAL DYNAMICS TIONS.GD.COM

A8:Is there regular Board level monitoring and review of the performance of thecompany’s ethics and anti-corruption agenda?Score:2Comments:Based on public information, there is evidence of regular Board level monitoring and reviewof the performance of the company’s ethics and anti-corruption agenda. The Chief EthicsOfficer briefs the Audit Committee twice a year at scheduled meetings on all ethicsprogramme matters.References:Public:Company website: About Our Ethics‘The General Dynamics ethics program provides many resources to help employees “do theright thing.” Day-to-day oversight is provided at the corporate office by an ethics programmanager. Overall leadership is provided by a chief ethics officer who reports directly to theChairman and CEO on all ethics program matters. The ethics officer briefs the AuditCommittee of the Board of Directors twice a year at regularly scheduled meetings. Inaddition, 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 localethics 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 ethicsprogram 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 makedecisions;-Receiving reports of employee concerns regarding ethical matters; and-Conducting and overseeing prompt, thorough and objective investigations of all reportedGENERAL DYNAMICS TIONS.GD.COM

allegations of suspected ethical misconduct and taking corrective action, if about-our-ethics/Company website: Corporate Governance – Highlights‘The General Dynamics Board of Directors believes that a commitment to good corporategovernance enhances shareholder value. To that end, the Board has adopted governancepolicies and processes to ensure effective governance of the Company. These governancepolicies are embodied in the General Dynamics Corporate Governance Guidelines, which,along with the charters of the Board's committees and the Company's Certificate ofIncorporation and Bylaws, provide the framework for the oversight of the Company'sbusiness and operations. The Board of Directors conducts periodic governance reviews of allBoard and committee governance documents and updates these documents as necessaryand enix.zhtml?c 85778&p irol-govHighlightsAudit 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; thequalifications, performance and independence of the Corporation’s independent auditors;the performance of the Corporation’s internal audit function; and compliance by theCorporation with legal and regulatory requirements. The Committee will also prepare areport as required by the Securities and Exchange Commission (the “Commission”) to beincluded in the Corporation’s annual proxy statement.’(p.4): ‘Corporation Policies. The Committee will monitor management’s implementation ofthe 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.’Corporate Governance Guidelines (May 2014), p.1:‘In addition to its general oversight of management, the Board or its committees performthe following principal functions: reviewing, approving and monitoring the Company’s business strategies, annual operatingplan and significant corporate actions; selecting, evaluating and compensating the CEO; providing counsel and oversight on the selection and evaluation of senior management;GENERAL DYNAMICS TIONS.GD.COM

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 theintegrity of relationships with customers, suppliers and other stakeholders; and advising and counseling nix.zhtml?c 85778&p irol-govHighlightsGENERAL DYNAMICS TIONS.GD.COM

A8(a):Is there a formal, clear, written plan in place on which the review

GENERAL DYNAMICS 18/06/14 WWW.GENERALDYNAMICS.COM HTTP://INVESTORRELATIONS.GD.COM FINAL ASSESSMENT GENERAL DYNAMICS CORPORATION . '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