Commitment to Ethics
We Pride Ourselves On Our Responsible And Ethical Practices
With approximately 69% of our revenue from the U.S. government, and with our Aerospace segment subject to rigorous FAA oversight, we operate in a highly regulated environment. We are subject to regular audit and review by multiple U.S. government agencies to assess our compliance with applicable laws, regulations and standards.
The U.S. government also reviews the adequacy of, and compliance with, internal control systems and policies, including our purchasing, property estimating, material, earned value management and accounting systems.
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 General Dynamics. 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 act with integrity.
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.
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.
- We provide each employee with our Ethos and Our Standards of Business Ethics and Conduct. Available in 17 languages, the code of conduct establishes our standard that all employees conduct business in accordance with our Ethos, our company policies and applicable law.
- Our management and leadership teams and the ethics, human resources and legal departments are equipped to assist and provide guidance as needed for our employees who raise questions, seek advice or express concerns. They strive to foster an open and safe environment and embed our Ethos and commitment to ethics in ongoing communications.
- Each GD 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 commitment to upholding ethical behavior.
- The General Dynamics Business Ethics Help Line is available in 13 languages and is open 24 hours a day, accessible by phone or the web, and available to employees and other external stakeholders, such as suppliers, customers and community members. Questions or concerns can be raised using the Help Line, anonymously or otherwise.
All reported concerns are investigated promptly and in confidence. If we find that our standards have been violated, we take appropriate action, including disciplinary measures up to and including involuntary termination; implementing systemwide changes; and/or 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, and we take action against those who are found to have retaliated.
Our expectations to operate with integrity go beyond our employees. Suppliers, contractors and joint-venture partners are expected to develop effective
ethics and compliance programs as well.
Our senior leadership team regularly reviews our ethics program and briefs the Audit Committee at least annually. In addition, we support auditing activities to assess the effectiveness of our ethics program and governance controls.
Global Network of Ethics Officers
Each business 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 EOs in the defense industry through the Defense Industry Initiative to share best practices, which helps us continuously improve our programs.
In support of the EOs, we have 80 part-time local ethics officers (LEOs). Our LEOs, selected by their leadership based on proven character, are embedded in 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
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.
- We abide by the laws and restrictions regarding the import and export of our products, services, 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, and we work to remain in compliance with these laws and regulations..
Our robust anti-corruption compliance program is rooted in our Ethos, embodied in our Standards of Business Ethics and Conduct, and tailored to potential
risks faced in our business. Designated anti-corruption officers and other compliance professionals at each business unit carry out the program and serve as a resource for employees. Elements of the program include written policies and procedures, annual training, risk-based management and due diligence on third-parties, assessment of conflict of interests or other reputational risks, and reporting. We test the efficacy of our anti-corruption compliance program through regular monitoring and auditing.
In addition, to promote and advance ethical cultures in companies that provide products and services to the U.S. government, General Dynamics is a founding member of the nonprofit, volunteer organization, the Defense Industry Initiative (DII). Partnering with 16 other working group members, we deliver an annual, in-person Best Practices Forum, offer quarterly webinars to assist ethics officers with their ethics and compliance programs, and host an online community to enable real-time discussions and field questions relating to ethics. We also launched an initiative sponsoring multiple small and medium-sized companies, offering them access to a model supplier code of conduct, a small- business tool kit and the opportunity to network with others in the DII.
General Dynamics is also a founding member and active participant in the International Forum on Business Ethical Conduct (IFBEC), partnering with peers in the aerospace and
defense industry to promote the development of global, industrywide ethical standards.
Standards of Business Ethics and Conduct
Below, you'll find PDFs of the code of conduct for our Board of Directors and financial professionals, as well as copies of the "Blue Book" in 17 languages.
