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Antitrust, sales practices and competitive information

Antitrust and antitrust rules prohibit agreements that eliminate or restrict competition. Violations of these laws lead to severe fines or imprisonment. We comply with the antitrust and competition laws of all countries in which we do business.

We are committed to fair and competitive sales practices. We will not take any measures that unfairly restrict trade or exclude competitors from the market. We will not formally or informally compete with competitors to set and control prices, divide markets, boycott customers or suppliers, or restrict product sales.

We will not make false statements about our competitors or attempt to spy on or exploit secret information from competitors in an improper manner.

As far as antitrust laws and competitive practices are concerned, you are required to:

• avoid even informal or informal conversations with employees of a competitor about prices, products or customers

• never express themselves in a false or derogatory way about competitors

Conflicts of interest

A conflict of interest arises when your private interests in any way conflict with or interfere with the interests of General Dynamics. You should focus on business decisions on the needs of society rather than your own or your family or friends’ interests or your desire for personal gain. You should not do business with companies in which you or your family have a substantial financial interest. Each of us should behave in our dealings with suppliers, customers, and others so as to avoid even the appearance of a conflict between our personal interests and those of General Dynamics. Talk to the Ethics Officer of your division and disclose any situations that may or may pose a conflict of interest.

The following situations could easily create a conflict of interest:

Personal business relationships

You should disclose to the Ethics Officer of your Division any significant interests that you or a close family member may have in any of our suppliers, customers or competitors. Sharing a publicly traded company that is a competitor could be a real or potential conflict of interest for you and our company. Make sure that your personal business relationships do not influence the decisions you make on behalf of General Dynamics.

Organizational relationships

If you or a close family member works as a general manager, executive or consultant for a company that does business with us, you must disclose these obligations to the Ethics Officer of your business, even if this activity is unpaid.

Secondary activity

Before accepting a second job, consider whether this second activity could create a conflict of interest with your work or could have a negative impact on the performance of your job. Having a side job can be difficult because you may not always be able to see clearly where your loyalty should be. Do not take on any side jobs with our competitors, suppliers or customers.

Gather information about competitors

Properly collected business information is valuable. However, you should only gather information about our competitors from public sources that are freely available to others. To obtain information about competitors must never be spied or stolen. Ask for advice if you think someone is giving you sensitive information that you should not have. Protect all sensitive business information that you receive through your work, except for its disclosure is permitted.

Gifts and entertainment: Trading partners

Gifts. We compete only by the merits of our products and services. When exchanging gifts in business, it may seem that favors are being made to influence a business decision. We may offer gifts, meals, refreshments and entertainment of reasonable value to our business partners or non-governmental employees provided that this practice does not conflict with our principles or the principles of the recipient’s company. You should not make or offer a gift if, under the circumstances, such a gift might seem inappropriate.

Acceptance of gifts

In general, 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 to the relationship. Small gifts of little value may be accepted.

In some countries, it can be common to accept gifts of considerable value. These gifts are the property of the company and must be reported and handed over to the Ethics Officer of your division. For example, they may be purchased from the company at a fair price or donated to a suitable charity on behalf of General Dynamics.

In terms of giving or receiving gifts, you are required:

■ not to offer or make gifts when their acceptance is prohibited by the recipient’s policies, standards or guidelines

■ Do not accept or make gifts that are more than a low value when dealing with business customers to ensure that meals and entertainment serve a real business purpose

before you offer or keep a gift that has more than nominal value, contact the Ethics Officer of your division

Inside information and securities trading

You may obtain material information about General Dynamics or other companies before they become known to the general public. This kind of information is called “inside information”. You are prohibited by law from buying or selling shares based on inside information, or sharing that information with others who will then buy or sell stock before the information in question becomes generally public These rules also apply to more complex transactions, including options, puts and calls, and methods such as bear speculation. When information is published in newspapers or on television, one can be sure that it is public information.

To comply with securities laws in the countries in which we do business, you are required to:

■ not to engage in securities trading on the basis of non-public information;

not invite others to engage in securities trading based on non-public information

■ do not share insider information with someone who does not need to know.