Stock Price: 133.76 +0.06 5/25/2018 3:59 PM ET

Stock Price: 133.76 +0.06 5/25/2018 3:59 PM ET

Related Anti-Corruption Policies

Below are short summaries of Orbital ATK’s policies related to its anti-corruption program. These policies are a cornerstone of the company's anti-corruption program. For additional information about the other critical components of Orbital ATK’s anti-corruption program, please click here.

1-C-1100 Ethics and Compliance. Orbital ATK and its employees will conduct worldwide business operations with the highest standards of business ethics and conduct and in compliance with the spirit and letter of the policies, law and regulations that govern the business.

1-C-1120 Ethics and Compliance Program. It is the policy of Orbital ATK to promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law and to exercise due diligence to prevent and detect violations of the law. This policy provides a framework for Orbital ATK’s ethics and compliance program.

2-C-1102 Government Contract Mandatory Disclosures. Orbital ATK’s mandatory disclosure procedure goes beyond the strict requirements of the Federal Acquisition Regulation rule in order to facilitate internal reporting and analysis. This policy is designed to facilitate Orbital ATK’s compliance with the Federal Acquisition Regulation mandatory disclosure rule.

2-C-1105 Facilitating Payments. Orbital ATK employees and its international partners are prohibited from making facilitation payments unless it is necessary to protect an individual’s immediate health and safety.

2-C-1106 Political and Charitable Contributions Outside the U.S. Orbital ATK, its employees and its international partners do not make political contributions relating to any level of a foreign government. Charitable contributions outside the U.S. must be approved in advance after a review by legal counsel. This policy outlines the requirements for legal and business review of any requests.

2-C-1107 Retaining and Managing International Partners. Orbital ATK will only retain an international representative, consultant, joint venture partner, offset service provider or distributor who complies with the highest standards of legal and ethical conduct and which has demonstrated strengths and abilities which makes it well suited to represent the interests of Orbital ATK within a particular country or region. This policy provides definitions and the requirements for conducting and reviewing due diligence, drafting agreements, payments, and managing the ongoing relationship with the international partners. Orbital ATK has a risk-based approach to due diligence, review and approvals.

2-C-1108 Personal Conflicts of Interest. Orbital ATK employees should avoid all actual or perceived personal conflicts of interest unless expressly waived by Orbital ATK’s legal department. This policy includes guidelines to identify and avoid personal conflicts of interest and the process by which employees disclose potential and actual personal conflicts of interest to Orbital ATK’s legal department for review.

2-C-1109 Records Retention. This policy defines the business and legal requirements for the retention of business records and other company documents.

2-C-1111 Bribery Kickbacks. Orbital ATK employees must never offer, give, solicit, or accept any form of bribe or kickback in any aspect of our business, including our commercial transactions as well as our dealings with government officials and employees.

2-C-1112 Organizational Conflicts of Interest. Orbital ATK employees are required to identify and mitigate any business relationships or situations that might result in an organizational conflict of interest. This policy establishes a consistent, coordinated process to evaluate potential conflicts of interest and to draft the required mitigation plans.

2-C-1114 Gifts, Gratuities and Business Courtesies. Orbital ATK does not seek improper advantage through the use of gifts, gratuities or other business courtesies. This policy sets forth the guidelines with to respect to the offering and receiving of gifts, gratuities or business courtesies.

3-C-0233 Purchasing Card Program. The purchasing card program is designed to streamline the purchasing and accounts payable process by reducing the paperwork generated by small-dollar transactions. The cardholder’s signature on the Cardholder agreement indicates that the cardholder understands the intent of the program and agrees to adhere to the guidelines established for the program including allowable and prohibited purchases.

3-C-0680 Travel and Expense Reimbursement Policy. This policy provides guidelines on appropriate methods and processes to provide business travelers with safe, cost-effective, efficient and equitable travel options while meeting Orbital ATK’s business goals and on reimbursement of business-related expenses. The guidelines are based on established business practices and are intended to conform to the U.S. Federal Acquisition Regulations, Federal Travel Regulations and Internal Revenue Service directives.

3-C-1100 Cash and Bank Accounts. All bank relations, cash management, borrowing, and investment of excess funds for all locations are conducted under the direct supervision and control of the Treasurer.

4-C-7003 Recruiting, Hiring and Employment of Current and Former U.S. Government Employees. Orbital ATK shall not recruit, hire or consult with current or former U.S. Government Employees in a manner that would cause a conflict of interest among the employee, Orbital ATK and the Government or would be in violation of any applicable law.

5-C-1060 Procurement Integrity and Ethics. Orbital ATK’s supply chain employees are expected to act with integrity and comply with the policies, laws and regulations that govern their work. This policy communicates the guidelines relating to the Anti-Kickback Act, related parties, former employees, personal business with suppliers, confidentiality, internal audit and reporting violations.

8-C-1003 Charitable Contributions Policy. Orbital ATK supports a program of charitable sponsorship and support for programs that are related to our mission, vision and values, each making a contribution to the quality of life in the communities where our employees work and live. This policy provides overarching guidelines for company-specific charitable contributions including areas of support, restrictions and application procedure.

11-C-1000 Offset Policy. International contracts entered into by Orbital ATK may contain offset requirements and potentially include penalties for non-compliance. The policy outlines functional responsibilities for obtaining approvals, managing any obligations, and reporting of offset obligations internally and to the U.S. Government.

12-C-0001 Political Engagement and Compliance Policy. Orbital ATK engages at the federal, state and local levels of the U.S. government on political and public policy issues that affects its businesses, employees, customers and stockholders. A Political Disclosure and Compliance Report outlining Orbital ATK’s lobbying and political contributions to federal candidates through the Orbital ATK Political Action Committee is available on Orbital ATK’s website.

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