Integrity & Compliance

A Culture of Integrity and Empowerment

Every employee is expected to uphold our high standards. Each employee hears this message from their first day on the job and throughout their career with GDELS. Not only do we foster an ethical work environment, we work to create an environment where employees feel safe, empowered and equipped to speak up and do the right thing.

Leadership Commitment to Ethics

The General Dynamics' leadership team lives our values and serves as an example to our employees, customers and shareholders.

Our board and our key financial professionals are required to follow ethics codes specific to their roles, which they commit to annually. These codes have been carefully crafted by leadership to align with our ethos. With their signature, our chairman, board members and financial leaders promise to manage our business in accordance with the highest standards of ethical conduct.

Ethical and Sustainable Practices

Leaders throughout the company make decisions through an environmental, social and governance lens to foster ethical and sustainable business practices. This perspective is applied to every step in the process of delivering a product, service or solution to a customer, and when engaging with the communities in which we live and work.

Readily Available Tools and Resources

Our commitment to ethics is highly visible, readily available and continually reinforced. We equip our employees with the tools and resources they need to do the right thing.

Code of Conduct

We provide each employee with our ethos and our standards of business ethics and conduct. Available in 18 languages, the code of conduct establishes our standard that all employees conduct business in accordance with our Ethos, applicable law and our company policies.

Code of Conduct

Guidance and Support

Our leadership teams and the ethics, human resources and legal departments are equipped to assist and provide guidance upon need as confidential resources to raise questions, get advice and express concerns. They strive to foster an open and safe environment and embed our ethos and commitment to ethics in ongoing communications.

Awareness

Each GDELS facility is equipped with prominent awareness centers that reinforce our commitment to our ethos, outline tools available to employees, and list the Ethics Help Line website and toll-free number. A message from our CEO is included in each awareness center to further demonstrate our position.

24/7 Ethics Help Line

Confidential Investigations and Accountability

Ethics Helpline Website

Ethics Help Line
The GD Business Ethics Help Line is available 24/7 via phone or the web in 13 languages.
Confidential Reporting
Employees can raise questions or concerns, either anonymously or otherwise. All reported concerns are investigated promptly and in confidence.
Action and Accountability
If we find that our standards have been violated we take action, including involuntary termination and disciplinary action, implementing systemwide changes and notifying governmental offices or agencies, customers and/or suppliers.

We strictly prohibit retaliation against anyone who raises an ethics or compliance issue in good faith.

Global Network of Ethics Officers

Senior Ethics Officers (EO)

Each business of General Dynamics has one senior ethics officer (EO) who has direct access to leadership to discuss trends, opportunities and communication strategies. These senior EOs also meet regularly as a group to discuss best practices that can be shared across our portfolio. In addition, they work with other defense industry EOs through the Defense Industry Initiative to share best practices, which helps us continuously improve our programs.

Local Ethics Officers

In support of the EOs, every site has at least one part-time local ethics officer (LEOs). Our LEOs, selected by their leadership based on proven character, are embedded in the locations with our largest employee populations. Working side by side with other employees, LEOs are accessible resources who answer questions, provide communications and training, conduct investigations and further ingrain ethics into the everyday activities within our work environment.

Ethical Business Around the World
Compliance with International Laws and Regulations

As a leader in the aerospace and defense industry, we provide services and products to governments around the world. The laws and regulations relating to doing business with government customers and public officials are complex. As such, we provide our employees with the appropriate resources to comply with applicable laws and regulations.

Global Compliance and Anti-Corruption Commitment

Trade Compliance

We abide by the laws and restrictions regarding the import and export of our products, information, and technical data, including the U.S. International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR). Nearly every country has laws and regulations that control the international movement (e.g., imports, exports, re-exports and technology transfers) of specified product information and services.

We comply with the U.S. Foreign Corrupt Practices Act and other global anti-corruption laws

Our robust anti-corruption compliance program is rooted in our Ethos and tailored to potential risks faced in our business. Designated anti-corruption officers and other compliance professionals at each business unit help carry out the program and serve as a resource. Elements of the program include written policies and procedures, training, risk-based management and third-party due diligence, multiple reporting systems, and compliance audits.

Code of Ethics

GD Code of Conduct for Members of the Board of Directors GD Code of Ethics for Financial Professionals GD Standard of Business Ethics

Compliance with Council Regulation (EU) No. 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilizing the situation in Ukraine

General Dynamics European Land Systems strictly adheres to Council Regulation (EU) No. 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilizing the situation in Ukraine in its various contractual relationships and compliance programs.

GDELS will not enter into contractual relationships unless permitted by the regulation.

Due diligence guidelines for responsible minerals sourcing OECD

General Dynamics European Land Systems' (GDELS) program follows the OECD due diligence guidelines for responsible minerals sourcing and requests its supplier to do the same.

GDELS furthermore recognizes the human rights issues that occur when sourcing materials in mines related to tin, tantalum, tungsten and gold, and our program seeks to conduct due diligence back to the mine sources and requests our suppliers to do the same.

The GDELS risk assessment will validate sourcing as it relates to the Democratic Republic of Congo (DRC) and adjoining countries as well as any conflict-affected and high-risk areas CAHRAs designated by the EU Commission.

While not a direct importer into the EU, GDELS understands the need for enhanced due diligence and continues to seek year-on-year improvement to promote transparency in the sourcing of tin, tungsten, tantalum and gold (3TGs).

GDELS expects its suppliers support this effort in gathering upstream source of origin information and share that as it relates to GDELS products.

Declaration for GDELS-Mowag

General Dynamics European Land Systems-Mowag GmbH adheres to the requirements of Article 964j ff. of the OR (Swiss Code of Obligations) and of the Swiss Ordinance on Due Diligence and Transparency Regarding Minerals and Metals from Conflict Areas and Child Labor (VSoTr), implementing the following in order to ensure compliance with the applicable legislation:

GDELS-Mowag, as part of the General Dynamics Group, adheres to the OECD Conflict Minerals Guide from April 2016, with corresponding consolidated reporting for the entire General Dynamics Group to the SEC, and
GDELS-Mowag regularly checks whether there is a founded suspicion of child labor.

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