Stock Price: 131.91 +0.26 12/15/2017 4:02 PM ET

Stock Price: 131.91 +0.26 12/15/2017 4:02 PM ET

Anti-Corruption Program

Anti-corruption is a top priority for Orbital ATK’s Board of Directors and senior leadership, and we are firmly committed to building our business with integrity.

“At Orbital ATK, the Board of Directors and senior leadership are committed to Orbital ATK’s anti-corruption culture of compliance. We lead the way by acting with the highest ethical and legal standards in everything we do. Orbital ATK does not tolerate bribery or corrupt activities in any aspect of our business.” - David W. Thompson, President and Chief Executive Officer.

The cornerstone of Orbital ATK’s anti-corruption program is its anti-corruption policies. The policies require compliance with the U.S. Foreign Corrupt Practices Act, the U.K. Anti-Bribery Act, and applicable anti-corruption laws in other countries where Orbital ATK conducts or seeks to conduct business. Further, the policies require that Orbital ATK’s employees and its international partners:

Critical Components of Orbital ATK’s Anti-Corruption Program

Assessment. As Orbital ATK’s business environments and risks evolve, so does our compliance program. Orbital ATK’s anti-corruption compliance program is evaluated as part of the company’s annual compliance risk assessment. The results of the annual assessment are reported to the Board of Directors. In addition, Orbital ATK regularly assesses the operation of the program and making adjustments to ensure the program is appropriately meeting our business and operating risks.

Leadership and Communication. To foster communication and operational integration, Orbital ATK has established an inter-departmental working group. The working group is comprised of stakeholders from Ethics & Compliance, Finance, International Business Development, Business Group, Internal Audit and Legal. They coordinate efforts on changes to the program, training, assessments, and policies.

Training. Orbital ATK is committed to continuing and reinforcing our strong ethical culture and promoting Orbital ATK's values and principles through training. Effective training helps employees and our international partners identify potential trouble spots and raise issues when there are concerns. Orbital ATK provides a mix of web-based and in-person anti-corruption training conducted at varying frequencies depending on job responsibilities. The training covers applicable anti-corruption laws (including local laws), Orbital ATK’s policies and procedures and provides real-life examples.

Supply Chain. Orbital ATK has adopted the Defense Industry Initiative’s (“DII”) Model Supplier Code of Conduct for its suppliers and vendors (including its international representatives and consultants). Compliance with the DII code is included in Orbital ATK’s standard terms and conditions for its suppliers and in its agreements with its international representatives and consultants.

The anti-corruption program is embodied in a number of policies, summaries of which can be found here.

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