Code of Business Ethics and Conduct - DRS Technologies

CODE OF BUSINESS ETHICSAND CONDUCTCommitted to Making the Right ChoicesThis Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions andconduct of all DRS full- and part-time employees, agents, subcontractors and board members.

TABLE OF CONTENTSOUR CODEOur Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IScope and Applicability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IIValues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IIIThe DRS Code of Business Ethics and Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IVAccurate Books and Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Anti-Trust . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2Anti-Corruption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3Bribes and Kickbacks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5Electronic and Telephonic Communications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6Environmental, Health and Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7Former U.S. Government Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8Gifts, Entertainment and Business Courtesies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9Insider Trading . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Intellectual Property . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11International Trade . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12Labor Charging . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14Lobbying . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15Non-Discrimination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Non-Harassment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17Organizational Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18Political Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19Personal Conflicts of Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20Record Retention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22Substance-Free Workplace . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23U.S. Government Contracting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24Use of Company Property . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25Use of Third Party Intermediaries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26Personal Commitment and Acknowledgement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27A REFERENCE TOOL FOR MAKING DECISIONSEvery day DRS personnel make decisions that are critical to our success. This Code of BusinessEthics and Conduct provides information and guidance for making good decisions. It is intendedto be a helpful supplement to our detailed DRS policies and procedures, which can be found onthe DRS Intranet site.In each section of this Code you will see:A brief overview of the titled subject;“What You Need to Know,”which provides some important information from our policies;“Red Flags,”which are examples of behaviors or situations that may be relevant when consideringthe titled subject;“Other Resources,”which provide references to additional detailed information for you.Because this Code is a summary, if you have questions or want more information, you areencouraged to consult the “Other Resources” and read the related policies, and ask for advice orclarification.DRS is committed to keeping this Code of Business Ethics and Conduct up to date. Therefore, themost current version of this document is available on the DRS Intranet.Always check the DRS Intranet to ensure that you are consulting the most recent versions of theCode and our DRS policies.I

SCOPE AND APPLICABILITYVALUESALL EMPLOYEES(full-time, part-time, contract and temporary, directors and officers)As a DRS employee, or other person who is responsible for complying with this Code ofBusiness Ethics and Conduct, you must ensure that your actions are in accordance with theDRS Core Values and the principles set forth in this Code of Business Ethics and Conduct.• Understand Company policies and check the DRS Intranet site for policy updates;• Become familiar with the many resources available to you;• Ask questions, when in doubt, to clarify any gray areas;• Report violations of the Code or DRS policy.MANAGEMENT AND SUPERVISORSIn addition to the responsibilities set forth above for all employees, as leaders you are alsoresponsible to:• Establish and maintain an ethical culture and work environment that upholds the DRSCore Values and the principles of the Code of Business Ethics and Conduct;• Communicate by your actions and your words a commitment to the DRS Core Values andCode of Business Ethics and Conduct;• Promote an atmosphere where employees feel free to ask questions, raise issues andknow they can report a concern without fear of retaliation or retribution;• Take necessary actions to ensure all employees and others understand and abide by thestandards of our Code of Business Ethics and Conduct.OTHERS(consultants, sales representatives, agents and distributors)Others who work with DRS must abide by the principles set forth in the Code of BusinessEthics and Conduct and comply with the applicable policies of DRS.UPHOLDING THE DRS CORE VALUESThe DRS Core Values are the foundation for our conduct at DRS. They form the basis for ourworking relationships, workplace behavior and commitment to our stakeholders. All DRSemployees are expected to conduct business in accordance with our Core Values.INTEGRITYWe value a culture of trust, honesty and respect. We demand ethical conduct where ethics andaccountability always come first.QUALITYWe set high standards of performance for ourselves and others. We settle for nothing less.CUSTOMER FOCUSWe go above and beyond to meet customer needs. We will work to make our customerssatisfied and will strive to meet their goals.DIVERSITYWe accept unconditionally the value that every human being has to offer. We cooperatetogether as a diverse workforce serving a diverse population.LEADERSHIPWe help and inspire people to succeed. We believe that all employees in their own right,regardless of level or position, can lead.IIIII

ANTI-TRUSTANTI-CORRUPTIONDRS fully complies with the anti-trust laws of the U.S., whether they are applicable at home orabroad. Generally, it is illegal to attempt to or to actually restrict competition through collusivebehavior or abuse of market position. The misconduct of even one employee can result in costlylitigation, fines or other penalties against DRS and against the individuals involved.DRS is committed to conducting business with integrity and ensuring that business decisions are free fromcorruption. We must always compete and make buying decisions fairly on the basis of price, quality,performance and service without using or submitting to improper practices. The U.S. Foreign CorruptPractices Act (FCPA) prohibits the direct or indirect payments, offers, promises or giving of anything of valueto foreign government officials, political parties, party officials and candidates for public or political partyoffice for any corrupt purpose, including obtaining or retaining business or any improper advantage. TheFCPA applies to any U.S. company, wherever it does business, including outside the U.S. A number of othercountries have related anti-corruption laws.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSTerminate immediately and notify the General Counsel ofany conversations with competitors or team membersregarding pricing policies, bids, discounts, promotions,royalties, warranties, terms of sale, production volume,marketing policies, sales capacity, distribution methods,market share or other pricing, bidding or sales information.Never engage in price-fixing, bid-rigging, market divisions,misrepresenting or harassing a competitor, stealing tradesecrets, bribery, kickbacks or any practices or behaviors thatactually or attempt to illegally restrict competition.Comply with all U.S. anti-trust laws, and recognize thatthese laws apply also to international activity that affectsU.S. commerce. Also, learn and comply with the laws andregulations of other countries where business is conductedor planned.Ask questions or report suspected anti-trust violations tothe General Counsel’s office.Discussing pricing strategy with competitors oragreeing with competitors to raise, lower, maintain,stabilize or otherwise fix prices or levels of output.Agreeing with competitors to control productionvolume, product development or market divisions.Having improper discussions with teamingpartners or competitors.Never accept anything of value which exceeds DRS policylimits, may influence your decisions or give others theperception that your actions or favor are being influencedimproperly by those who do or want to do businesswith DRS.Never give anything of value or make payments, includingbribes, kickbacks, illegal political contributions or other illicitpayments, that attempt or could be perceived to improperlyinfluence U.S. or foreign Government officials or otherparties to conclude a business transaction.Ensure that DRS contractors, vendors, consultants,distributors, third-party representatives and otherintermediaries are reputable and that they commit touphold all U.S. anti-corruption policies and laws, and theanti-corruption laws of other countries.Be wary of third-party intermediaries who may requestexcessive fees, commissions, expenses, who demand cashpayments or who demand that payment be made to thirdparties or third countries.Using agents, representatives or other thirdparties to make or offer to make an improper orillegal payment.Concern that all or part of a payment, cash or otherconsideration may be passed on to a foreigngovernment official, political party, party official orcandidate for public or political party office inviolation of law.Determining that third-party intermediaries lacksuitable experience, qualifications or references, orhave high-risk third-party relationships or businesspartners (e.g., foreign officials on payroll, officials orclose relatives who are foreign officials, employmentof close relatives of foreign officials.)Refusal of a third-party intermediary to certifycompliance with the FCPA, sign an FCPA certificationor comply with the DRS Code of Business Ethics andConduct or DRS policies and procedures.Related DRS Policies and Other Resources:DRS Policy – Anti-Trust;DRS Policy – Prevention of CollusiveBidding and KickbacksRelated DRS Policies and Other Resources:DRS Policy – Compliance with International Anti-Corruption Laws; DRS International Anti-Corruption Compliance Guide; DRS Policy – Bribes and Kickbacks; DRS Policy – Restrictions onGifts, Entertainment or Business Courtesies; DRS Policy – Guide to Agreements withInternational Intermediaries2 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-time3employees, agents, subcontractors and board members.employees, agents, subcontractors and board members.

BRIBES AND KICKBACKSCOMMUNICATIONSDRS employees may not solicit, accept or attempt to accept directly or indirectly from a third partya bribe, kickback or other payoff in connection with a transaction entered into by the Company.Violations of this policy could result in the imposition of both criminal and civil penalties.DRS is committed to truthfully disclose and to distribute in a timely and accurate mannermaterial information relating to the performance of the Company, significant events and othernews that could have an effect on Finmeccanica’s stock price. There are civil and criminalpenalties (both for DRS and involved employees) associated with making false, fraudulent ormisleading statements to the Government and others with whom we communicate.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSDRS does not seek to gain any advantage through theimproper use of gifts or other inducements and strictlyprohibits DRS employees from accepting, providing,attempting to provide or offering to provide funds or otherassets to or from suppliers or customers in the form ofbribes, kickbacks or other payoffs.Bribes, kickbacks and payoffs include any money, fee,commission, thing of value or compensation of any kindthat is provided directly or indirectly to anyone for thepurpose of improperly obtaining or rewarding favorabletreatment in connection with a business transaction.Favorable treatment, which may constitute the giving orreceiving of something of value, may include the followingactivities:Offering anything of value to a contractor orcustomer in order to obtain favorable treatment.Soliciting a kickback.Receiving anything of value for the purpose ofrewarding favorable treatment to a subcontractor.Including the amount of a kickback in thecontract price charged to the customer.Not including an anti-kickback clause in DRSsubcontracts, as required.DRS authorizes only a limited number of publicspokespersons and prohibits others from making publicstatements to the news media or providing informationrelated to DRS business, or commenting on any plans orcustomer business activities without prior approval.Obtain approval from the appropriate DRS official beforemaking external communications regarding business plans,performance prospects, management changes, acquisitionsor dispositions of assets or other material events.Do not attempt to answer questions from someone outsideof DRS unless you are authorized to do so. Refer all personsto the appropriate DRS official.Speaking to the public or making statementsto the media, including newspapers, magazines,radio, TV, Internet web sites and chat rooms, onbehalf of DRS without prior approval of anauthorized Company official.Distributing advertisements, promotionalmaterials, publications, financial information orother statements without prior approval.Altering or substituting logos or trademarkswithout prior approval.• Receiving confidential information on competitors, suchas prices, delivery schedules, costs, etc.• Obtaining unwarranted extensions, waivers ofdeadlines or price increases.• Obtaining acceptance of substandard goods.Related DRS Policies and Other Resources:DRS Policy – Commercial Bribes and Kickbacks; DRS Policy – Collusive Bidding and Kickbacks;DRS Policy – Accuracy of Books and Records; DRS Policy – Restrictions on Gifts,Entertainment or Business Courtesies; DRS Policy – Lobbying; DRS Policy – Restrictions onGifts and Political Contributions to Members of Congress and their Staff; DRS Policy –Unallowable CostsRelated DRS Policies and Other Resources:DRS Policy – Corporate Communications4 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-time5employees, agents, subcontractors and board members.employees, agents, subcontractors and board members.

ELECTRONIC AND TELEPHONIC COMMUNICATIONSENVIRONMENTAL, HEALTH AND SAFETYComputers, software, email, voice mail and other electronic means of communicationare intended primarily for Company business. Information transmitted, received orstored on or by DRS electronic and telephonic communications systems is Companyproperty.Protecting employee and public health and safety is of utmost importance. We expect you tocomply with all federal, state and local environmental, health and safety laws and regulations.You should be alert to and report potentially dangerous conditions and take safety precautions,as needed, to prevent injury to yourself and others.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSUse DRS communications tools to accomplish Companybusiness objectives.Incidental use of communications equipment for personaluse is permitted only if it is not improper, does not wastetime or otherwise adversely affect productivity or the workenvironment, increase costs or harm DRS’s reputation.Be aware that DRS may access, monitor and disclose thecontents of electronic or telephonic communications andcomputer or email accounts without notice.Keep in mind that Internet connections can be traced toDRS when you send email, post to newsgroups, transferfiles or visit external web sites.Conducting personal business, such as usingCompany resources to promote goods or servicesunrelated to DRS.Creating a personal blog or web site using DRSsystems or referring to confidential or businesssensitiveactivities or business on any blogor web site.Downloading, storing or installing items such asgames, pornography, personal software, copyrightedmusic or videos or unapproved software programs.Misrepresenting, suppressing or replacing auser’s identity on electronic systems.Transmitting information about social, religiousor political causes, or other non-work relatedactivities that have not been approved by Companymanagement.Take responsibility for your workspace. Be alert to and,where possible, immediately correct unsafe practicesor conditions.Report all accidents to your supervisor or the safety officeno matter how minor; reporting a minor injury may preventa more serious accident.Report environmental and safety concerns, including unsafeequipment and practices, to your supervisor or thesafety office.Ensure the reports are accurate and complete if atransaction requires environmental, health or safety records.Failure to use protective equipment or followsafety guidelines.Disabled or missing safety controls or guards onequipment or machinery.Inadequate emergency systems, including blockedemergency exits, non-working emergency alertdevices, or insufficient or unclear emergencyinstructions or training.Environmental, health and safety complaintsfrom employees, customers or neighbors.Failure to report accidents or injuries, or failure ofmanagement to respond appropriately.Improper labeling, management, shipping,transportation or disposal of hazardous products,chemicals or materials.Related DRS Policies and Other Resources:DRS Corporate IT Guidelines; DRS Policy –Use of Company Property; DRS Policy –Personal Conflicts of InterestRelated DRS Policies and Other Resources:DRS Policy – Environmental, Health and Safety;DRS Policy – General Safety and Health6Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.7

FORMER U.S. GOVERNMENT EMPLOYEES(EMPLOYMENT DISCUSSIONS WITH AND HIRING OF)GIFTS, ENTERTAINMENT AND BUSINESS COURTESIESThere are laws, regulations and policies concerning employment discussions with, hiring of andrestrictions on the employment of current and former U.S. Government employees. They apply tothe hiring of employees, consultants and independent contractors. There are restrictions relatingto work assignments that former U.S. Government personnel can perform. The post-Governmentemployment restrictions are complex and may require the involvement and cooperation amongDRS functional areas, such as Legal, Human Resources and Ethics.DRS competes solely on the merits of our products and services. We must never engage in anybehavior that could result in even the appearance of impropriety or unfair advantage. It isDRS policy to comply with all statutory and regulatory requirements related to prohibitionsagainst gifts, entertainment or business courtesies to U.S. or foreign government personnel.WHAT YOU NEED TO KNOWObtain prior approval from Human Resources before anydirect or indirect communications or negotiations with anycurrent U.S. Government personnel regarding possibleemployment with DRS. In certain circumstances, particularlywith high-level U.S. Government personnel, writtenapproval of applicable DRS legal counsel is required.Certain U.S. Government personnel cannot holdemployment discussions with a company without priorwritten approval from their designated agency ethicsofficer.Be aware that certain former U.S. Government personnelmay be prohibited from representing or appearing onbehalf of DRS before any department or agency in whichthey served for a period of time. (i.e., one year, two yearsor lifetime ban.)Obtain written approval from DRS applicable legal counselprior to any change in the work assignment of any formerU.S. Government employee with work restrictions in effect.Related DRS Policies and Other Resources:DRS Policy – Employment Discussions with andHiring of U.S. Government PersonnelRED FLAGSDirect or indirect discussion with a U.S.Government employee concerning possible DRSemployment.Certain U.S. Government employees have notrequested and received a U.S. Governmentagency ethics opinion to clarify any workrestrictions.During the restriction period, a former U.S.Government employee, who is currently a DRSemployee, appears at a meeting with the agencywith which the employee was employed orparticipates in negotiations related to a contract overwhich the DRS employee had authority whileemployed by the U.S. Government.WHAT YOU NEED TO KNOWComply with all laws, regulations and Company policieswhen offering, providing or accepting any gifts,entertainment or business courtesies.Know the permissible dollar limits for accepting, offeringand providing gifts, entertainment or business courtesies, asprovided in DRS policy.Never offer or provide any gift, entertainment or businesscourtesy with the intent to influence or reward favorabletreatment or accept a gift, entertainment or businesscourtesy that could be perceived as affecting yourobjectivity or influencing your decisions.DRS employees responsible for procurement, purchasingand supply chain may never offer or provide a vendor orsupplier with a gift or entertainment of any value nor shallthey ever accept a gift or entertainment of any value from avendor or supplier.Make sure permissible gifts are open, transparent andreasonable for the circumstances.Know the specific laws and regulations related to offeringor providing items of value to employees of the U.S.Related DRS Policies and Other Resources:DRS Policy – Restrictions on Gifts, Entertainment or BusinessCourtesies; DRS Policy – Restrictions on Gifts and PoliticalContributions to Members of Congress and Their StaffExecutive and Legislative Branches, which include theDepartment of Defense, the military services, civilianagencies, Congress and federal departments.Know and comply with the Foreign Corrupt Practices Actand all applicable country, state and local laws beforeoffering, providing or accepting gifts, entertainment orbusiness courtesies.RED FLAGSProviding business courtesies that are intendedto influence, or appear to influence, businessdecisions.Accepting frequent meals or entertainment bythose doing business or attempting to do businesswith DRS.Offering or providing gifts, entertainment orbusiness courtesies to U.S. Government Executive orLegislative Branch personnel.Accepting gifts or entertainment valued over theDRS policy limit.Soliciting gifts, entertainment, favors or personaldiscounts on services.8 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-time9employees, agents, subcontractors and board members.employees, agents, subcontractors and board members.

INSIDER TRADINGINTELLECTUAL PROPERTYU.S. laws prohibit buying or selling securities, such as stocks and bonds, based onmaterial information that is not yet available to the public. This information givesinsiders an unfair advantage and can misrepresent market value.Intellectual Property is any information that is not public and is valuable to the Company. Itmay be in electronic or print form, or in the minds of DRS employees. Some forms ofIntellectual Property (ideas, discoveries and inventions) are protected as patents or tradesecrets, and other forms (confidential financial, marketing and strategic information) areprotected as proprietary information. Intellectual Property is among our most valuable andunique assets.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSDo not trade in Company securities while in possession ofnon-public information you have obtained as a result ofyour employment.Do not disclose inside non-public information to spouses,family members, friends or others who might pass thisinformation to others or trade on the basis of suchinformation.Information related to material non-public transactions orevents should not be discussed in public places, such aselevators, restaurants or airports.Executive officers, directors and certain other personsidentified by the Company must comply with additionalsecurities trading and reporting requirements.Contact the General Counsel prior to engaging in stocktransactions, if you have questions.Trading in securities just before announcement of asignificant Company event.Recommending that someone buy or sellsecurities when you have inside information.Trading in the stock of another company basedon information disclosed in a private presentationmade to DRS, whether or not DRS chooses to dobusiness with that company.Purchasing the stock of another company withwhom DRS is about to announce a major transactionor relationship.Friends or family of employers, officers,directors, contractors, customers or vendors whoachieve financial gain through trading securities justprior to major announcements or earnings releases.Identify Intellectual Property and prepare appropriatedisclosure information to your Intellectual PropertyCommittee.Identify Intellectual Property that is to be protected as eitherCompany or third-party proprietary information and instructemployees how to handle and safeguard its confidentiality.Prevent intentional and/or inadvertent disclosure ofIntellectual Property and proprietary information belongingto DRS or others, including customers and suppliers.Properly dispose of Intellectual Property and proprietaryinformation in accordance with the DRS Record Retentionpolicy.Ensure the IT department properly and completely deletesall such information from computers to be redeployed,donated or sold.Discussing Intellectual Property and ProprietaryInformation with non-DRS employees withoutwritten authorization.Failure to establish safeguards for newemployees to prevent them from disclosing or usingIntellectual Property or Proprietary Information of aformer employer or customer.Failing to protect passwords or storing sensitiveinformation on unsecured computers.Copying Company-owned proprietary,trademarked or licensed software for personal use.Accepting or using Intellectual Property fromothers without written agreement.Removing proprietary information from DRSpremises without permission.Related DRS Policies and Other Resources:DRS Policy – Insider Trading; DRS Policy – PersonalConflicts of Interest; DRS Request for PersonalConflict of Interest Determination FormRelated DRS Policies and Other Resources:DRS Policy – Intellectual Property;DRS Policy – Record Retention10 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-time11employees, agents, subcontractors and board members.employees, agents, subcontractors and board members.

INTERNATIONAL TRADEINTERNATIONAL TRADEU.S. and foreign laws govern the export and import of DRS products, services and technology. Inthe U.S., these laws and regulations control exports, imports, re-exports/re-transfers, tradesanctions, restricted trade practices and economic embargoes. Engaging in international tradeand transactions without appropriate U.S. Government authorization or improperly restrictingtrade can result in substantial administrative, civil and criminal penalties for DRS and individualemployees, including fines, imprisonment, loss of the Company’s export/import privileges and theability to contract with the U.S. Government.WHAT YOU NEED TO KNOWComply with all U.S. and foreign laws and regulations governingthe export and import of products, services and technology,restrictive trade practices (e.g., boycotts) and economic embargoesenforced by the United States.Be aware that export and import laws and regulations applybroadly to transactions in addition to the actual exports andimports of goods, such as: (1) licensing of software, (2) transfer oftechnology in any form (such as plans, designs, specifications,manuals, training, consulting and technical assistance) by anymeans (e.g., verbal, email, fax, video conference, web posting,etc.), (3) use of consultants or representatives to assist in marketingand/or sale of DRS products, services or technology, and (4) theemployment of foreign persons in the United States and abroad.Know that U.S. restrictions can apply to foreign-made productsthat incorporate U.S. origin parts or components or that are basedon U.S. technology. Foreign origin products are also subject toU.S. law once they enter the United States and may requireexport authorization to leave the country.Be familiar with factors that impact what U.S. Governmentauthorizations are required for the export of products, services ortechnology, such as whether an item was specifically developed,modified or adapted for a military application.Recognize that the U.S Government prohibits exports by denyingexport licenses and other approvals for sanctioned countries,specific end-users (e.g., companies and individuals engaged inthe proliferation of weapons of mass destruction, trade withsanctioned countries, terrorists and drug smugglers) and end-uses(e.g., sanctioned missile, nuclear or CBW projects).Do not agree to comply with or support a foreign boycott that isnot sanctioned by the United States. This includes: (1) refusing todo business with countries subject to such boycotts (e.g., Israel),their companies or companies blacklisted by boycotting countries,(2) discriminating against U.S. companies that trade with aboycotted country, (3) discriminating against (or furnishinginformation about) persons based on race, religion, sex ornational origin, and (4) providing information (usually in the formof a written or oral request) about DRS’s relationships withboycotted countries or companies.Consult with appropriate DRS personnel for guidance onunderstanding and complying with laws and regulationsgoverning international trade.RED FLAGSA party to your transaction is identified on a U.S. Government list as subject to sanctions.Customer or purchaser is reluctant to provide information regarding the proposed end user or enduse or is evasive as to whether the purchased product, service or technology is for use domestically orabroad.Product capabilities do not fit the buyer’s line of business, such as an order for sophisticatedcomputers for a company that would not require use of the DRS product.Technology requested for export is incompatible with the technical level of the specified foreigncountry.Customer offers to pay cash for an expensive item that seems destined for use abroad.Delivery dates are vague or the shipping route or method is abnormal for the product anddestination, such as delivery to foreign trade zone or warehouse.Participating in or cooperating with restrictive trade practices that are not sanctioned by U.S. law.Related DRS Policies and Other Resources:DRS Export Compliance Manual and ImportCompliance Manual; DRS Policy – Anti-Boycott12Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.13

LABOR CHARGINGLOBBYINGProper labor charging is critical to doing business on U.S. Government contracts. Labormischarging and overcharging may distort proper cost allocations and historical data, andimpact the Company’s ability to accurately propose future costs. Mischarging or overchargingmay result in criminal and civil penalties, and contract and administrative actions against acontractor and its employees.The lobbying of U.S. Government officials, including Congressional members and staff,and policy-making Government officials in the Executive Branch, is highly regulated.All such lobbying activity must have prior approval in accordance with DRS Policy.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSAbide by U.S. Government and contractual requirementsestablishing standards for labor charging.Charge your time daily, accurately and completely andcomply with applicable rules and contract requirements.Contractors may be subject to comprehensive audits oflabor charging, including employee time cards, by theDefense Contract Audit Agency (DCAA) or otherGovernment agencies.Charging labor costs to incorrect accounts orcontracts, such as charging time to a costreimbursementcontract for time actually spent on afixed-price contract.Not recording actual time spent on a project.Requiring employees to sign time cards prior tothe end of the work period with time filled in bythe supervisor.Transferring labor costs without writtenjustification between Contracts, U.S. Governmentand commercial work, fixed-price and costreimbursementcontracts, or direct andindirect accounts.Most oral and written communications, and relatedpreparation time with “covered federal officials” for thepurpose of influencing Government actionconstitute “lobbying.”Never use funds received through a U.S. Governmentcontract to lobby decision makers for federal awards,including extensions or modifications of current contracts.Be aware that attempts to influence covered federalofficials about the following types of U.S. Governmentaldecisions may be subject to lobbying disclosure laws:• The introduction or adoption of proposed federalrules, programs, policies, legislation or otherGovernmental positions;• The administration or execution of federal contracts,programs or policies.Contacting Congressional members or staff orpolicy-level Executive Branch officials concerningnon-clerical matters without prior approval.Contacting any U.S. Government office oremployee to influence awards (exceptcommunications necessary for normal procurementprocesses) without prior approval.Engaging in lobbying activities without properlyrecording and charging time and expenses.Retaining an outside person to lobby withoutproper approval.Charging political or lobbying costs to a federalcontract.Related DRS Policies and Other Resources:DRS Policy – Labor Charging;DRS Policy – Accuracy of Books and RecordsRelated DRS Policies and Other Resources:DRS Policy – Lobbying14 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-time 15employees, agents, subcontractors and board members.employees, agents, subcontractors and board members.

NON-DISCRIMINATIONNON-HARASSMENTA diverse workforce of individuals with different backgrounds, experience, perspectives andtalents creates a more productive, reliable, innovative and competitive global company. DRS iscommitted to maintaining a discrimination-free workplace, where employees are valued fortheir character, skills and commitment, and are rewarded on the basis of their contributionsinstead of physical, cultural or other personal characteristics.DRS does not tolerate harassment of its employees on the basis of race, color, religion,national origin, gender, sexual orientation, age, mental or physical disability, veteranstatus, marital status or other personal characteristics protected by law. Everyemployee of DRS is entitled to be treated with respect and to be free from anyconduct that is offensive, hostile or intimidating.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSMake all employment decisions on the basis of jobqualifications, education, prior experience and meritwithout regard to race, color, religion, national origin,gender, sexual orientation, age, mental or physical disability,veteran status, marital status or other personalcharacteristics protected by law.Create a positive work environment where every individualis appreciated for his or her contributions.Treat all employees with dignity, respect and fairness.Demonstrate good faith efforts for and comply with equalopportunity laws and the DRS Affirmative Action Program.Apply DRS affirmative action policies fairly to recruit, hireand promote qualified minorities, women, disabled personsand veterans.Use diverse viewpoints and perspectives to spark creativedecision-making and innovation without creating anenvironment where an employee feels singled out fordifferences in culture, heritage and other non-job relatedcharacteristics.Unfair treatment of employees based on personalcharacteristics protected by law.Use of words or gestures that have a derogatory,discriminatory or otherwise offensive meaning.A non-diverse workforce when the pool ofqualified workers is significantly more diverse.Division of responsibilities or exclusion ofqualified individuals from Company activities basedon personal, non-job related characteristics protectedby law.Avoid inappropriate actions, comments or images thatcreate a hostile or offensive work environment.Do not verbally, visually or physically degrade, intimidate orthreaten other DRS employees, customers, contractors,vendors, suppliers or competitors.Do not participate in, condone or tolerate jokes, materials,comments and actions that may ridicule or offend others.Do not tolerate or engage in sexual harassment, whichincludes making or receiving unwelcome advances orphysical contact, or the threat or promise of employmentactions based on the refusal or the granting ofsexual favors.Abusing the dignity of a person throughunwelcome or inappropriate teasing, or epithetsor derogatory comments.Tolerance by supervisors of offensive,inappropriate or derogatory remarks or behaviorwhile in the workplace or otherwiserepresenting DRS.Use of foul language, threats, bullying and otherbehavior found intimidating or threatening by others.Display of pornography.Unwelcome sexual advances or physical contact.Related DRS Policies and Other Resources:DRS Policy – Equal Employment Opportunity andAffirmative Action; DRS Policy – Sexual & OtherUnlawful Harassment; DRS Policy – Federal StatutesRegarding EmploymentRelated DRS Policies and Other Resources:DRS Policy – Sexual & Other UnlawfulHarassment; DRS Core Values16 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.employees, agents, subcontractors and board members.17

ORGANIZATIONAL CONFLICTS OF INTERESTPOLITICAL ACTIVITIESFederal law may limit the ability of the Company to pursue a U.S. Government contract whereDRS previously has assisted the U.S. Government with the subject matter of the procurement,or has had access to competitively sensitive information. Such contract performance or accessto information can cause an Organizational Conflict of Interest (OCI).Corporations are prohibited from making direct or indirect political contributions orexpenditures in connection with federal elections. DRS has properly established anemployee funded Political Action Committee (“PAC”). Contributions to the PACare voluntary.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSBe aware of prior activities and relationships that mayprevent DRS from being awarded a U.S. Governmentcontract, including providing systems engineering andtechnical direction to the U.S. Government on relatedprojects, preparing specifications or work statements,providing technical evaluation, advisory and assistanceservices or obtaining access to proprietary information.Recognize and avoid OCI in which one business unit’sactivities may preclude the pursuit of a related activity byanother DRS business unit.Investigate the past activities and contracts of potentialconsultants to determine whether they have knowledgethat would create an unfair advantage or other OCI andpreclude DRS from pursuing contracts related tothat information.Any task order, contract, subcontract orpurchase order that contains an OCI clause, orprovides for technical services for system engineeringand technical direction, preparing specifications orstatements of work, technical evaluation or advisoryassistance services to the U.S. Government, or thatinvolves obtaining access to source selection orproprietary information.Consultants who have worked for U.S.Government agencies or competitors and mayhave access to proprietary information related to DRSbusiness or business pursuits.Acquisition of a company or business unit thathas prior knowledge of confidential U.S. Governmentor proprietary competitor information.Do not use Corporate funds, services, facilities, property orother resources for political purposes (including election orcampaign related) without prior written approval.Do not engage in any impermissible political activity(including election or campaign related) on Company timeor using Company resources.No DRS employee will be reimbursed or otherwisecompensated in any manner for making a politicalcontribution or engaging in impermissible political activity.Never offer, promise, authorize or make any payment ofmoney or anything else of value to any domestic or foreigngovernment official or employee for the purpose ofinfluencing any official act or decision of that person or agovernment, or securing any improper advantage for DRS.A Corporation may pay the cost of creating andadministering an employee-funded PAC, including theexpenses associated with the PAC, but the PAC must use itsown funds to make political contributions and expenditureson behalf of candidates.Using DRS’s name, facilities or personnel forpolitical purposes (election or campaign related),other than for authorized PAC activities.Seeking or collecting non-PAC politicalcontributions on Company premises or usingDRS resources.Seeking reimbursement for political contributionsor expenditures.Bundling contributions of others by collectingand forwarding contribution checks to a campaignor providing envelopes or postage with which tosend contributions.Related DRS Policies and Other Resources:DRS Policy – Organizational Conflicts of InterestRelated DRS Policies and Other Resources:DRS Policy – Restrictions on Gifts and Political Contributionsto Members of Congress or Their Staff; DRS Policy –Compliance with International Anti-Corruption Laws18 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.employees, agents, subcontractors and board members.19

PERSONAL CONFLICTS OF INTERESTPERSONAL CONFLICTS OF INTERESTAll DRS employees must conduct their affairs in a manner that does not conflict withthe Company’s interests. A personal conflict of interest occurs when you have apersonal or financial interest that influences, or appears to influence, your ability tomake fair and objective business decisions that are in the best interest of DRS. Neitheryou, nor those with whom you have a close relationship, should take any action whereyour personal interest may interfere or conflict with the interests of DRS.WHAT YOU NEED TO KNOWAvoid or disclose any financial interests, employment andpersonal relationships that may conflict with your ability toact in the best interest of the Company or that may appearto cast doubt on your ability to act objectively.Disclose any potential personal conflict of interest, includingbut not limited to, if:• Your financial interests in any organization couldbenefit from your position with DRS;• You hold more than 5% financial interest in anycompany that competes with DRS;• You plan to engage in outside employment, includingconsulting, advisory or part-time employment, withactual or potential competitors, suppliers orcustomers;• Your family member or close friend (or other closepersonal relationship) is employed by or acting as aconsultant to a DRS competitor, potential competitor,supplier or contractor or is in any position to provideor receive benefits to or from DRS.If it is determined that a personal conflict of interest exists,you may, in coordination with the Legal department,remove yourself from a conflict position or receive specificapproval of the applicable DRS legal counsel.Obtain approval from applicable DRS legal counsel beforeaccepting a position as an officer or director of anyoutside company.Avoid putting yourself in situations where you could beinfluenced to act out of personal gain or not in the bestinterests of DRS.Do not use DRS resources in a way that would benefit yourpersonal financial situation, or that of a second employer,family member or friend to the detriment of the Company.RED FLAGSOwning a significant interest in a business that is seeking to do business with DRS.Accepting gifts or discounts offered to you by actual or potential competitors, suppliers,vendors or customers, especially if you are in a position to influence their relationshipwith DRS.Receiving payment or services offered to you and not to others by an outside companyseeking to do business with DRS.Improper use of an opportunity or information obtained through your position withthe Company to achieve personal gain.Not disclosing that family works for actual or potential competitors, suppliers, vendorsor customers.Hiring, promoting or supervising a family member or without proper approval.Awarding business contracts to companies owned or managed by family.Related DRS Policies and Other Resources: DRS Policy – Personal Conflicts ofInterest; DRS Policy – Insider Trading; DRS Policy – Restrictions on Gifts,Entertainment or Business Courtesies; Gifts, Entertainment or BusinessCourtesies brochure; DRS Request for Conflict of Interest Determination Form20Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.21

RECORD RETENTIONSUBSTANCE-FREE WORKPLACECertain corporate records must be retained for specified periods to satisfy legal, operational,fiscal, policy or contractual requirements. Records shall be retained and destroyed inaccordance with the DRS record retention policy.DRS is committed to providing a safe and substance-free workplace. Employees maynot be at work while under the influence of alcohol, illegal drugs or in an impairedcondition from any substance. It not only affects an individual employee’s physical andmental health, but it threatens the health and safety of co-workers and impairs thequality of work.WHAT YOU NEED TO KNOWRED FLAGSWHAT YOU NEED TO KNOWRED FLAGSComply with DRS document management procedures, aswell as all relevant laws and regulations and contractrequirements related to the preservation and destruction ofdocuments and records.Review documents scheduled for destruction to ascertainwhether there is a legal, business or other reason to retainthem that supersedes the document destruction policy orlegal right to destroy them.Do not destroy documents that are related to litigation orinvestigation that is ongoing or that you know or havereason to believe is forthcoming, regardless of thedocument destruction schedule. Consult with applicableDRS legal counsel if you have questions.Treat e-mail and other electronic data the same as printedrecords and retain them pursuant to the DRS RecordRetention policy.Inadequate controls to preserve documentsrelated to pending or reasonably foreseeablelitigation, audits and investigations.Destruction of documents relevant to an ongoingor upcoming investigation.Disposal of documents without knowing what isbeing destroyed or whether the documents aresubject to retention requirements.Destruction of documents outside the schedule fordocument disposal set forth in the DRS RecordRetention policy.Possession, use, sale, distribution or production of illegalsubstances on Company time, on Company property or atCompany-sponsored events is prohibited.Using illegal substances (including illegal use of prescriptiondrugs) or being intoxicated while on DRS property, at DRSsponsoredevents, conducting DRS business or in vehiclesused for DRS business may result in disciplinary action,including dismissal.Submission to drug and alcohol screening tests can berequired.Be aware of side effects of your prescription and over-thecounterdrugs that could impact product quality orworkplace safety.Use good judgment when consuming alcohol, prescriptionor over-the-counter medications off-premises and afterwork hours. You will be held accountable for your actionsthat could adversely affect the Company, includingbreaching confidentiality or revealing DRS privateinformation.Unauthorized use of beer, wine or otheralcoholic beverages at a Company-sponsoredevent or on Company premises.Any use of illegal drugs or improper use ofprescribed medications on Company property, atCompany-sponsored events or while transactingCompany business.A pattern of absences from work oruncharacteristic and inappropriate behavior at workor Company-sponsored events.Consistent difficulty meeting deadlines, alternatingperiods of high and low efficiency, unrealisticexcuses for lowered work quality, increasedabsenteeism and conflict with co-workers.Related DRS Policies and Other Resources:DRS Policy – Record RetentionRelated DRS Policies and Other Resources:DRS Policy – Substance Abuse22 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.employees, agents, subcontractors and board members.23

U.S. GOVERNMENT CONTRACTINGUSE OF COMPANY PROPERTYOur relationship with our customers is vital to DRS. There are many laws and regulations thatgovern doing business with the U.S. Government. Some of these laws deal with GovernmentProperty, Procurement Integrity, Representations and Certifications, Subcontracting, Cost andPricing Data, Gifts and Gratuities to Government Officials, and Labor Charging.Company property is for business purposes. Use good judgment when using Companyproperty, including communication systems, information resources, material, facilitiesand equipment. Secure Company property when not in use to avoid waste, theft,destruction or misuse.WHAT YOU NEED TO KNOWBe aware of applicable laws, regulations and rules for U.S.Government contractors and subcontractors. Seek adviceand assistance from your supervisor, contracts professionalor applicable DRS legal counsel if you have questions.Procurement Integrity rules apply to all aspects of selling tothe U.S Government, including marketing, proposals andcontract performance.Never seek to obtain or use any non-public information,such as U.S. Government source-selection informationrelating to programs that are being pursued, including U.S.Government evaluations or rankings of competitiveproposals, trade secrets or other competition-sensitiveinformation of our competitors, cost or pricing data,indirect rate information or proprietary solutions containedin competitors’ proposals.Violations may result in criminal sanctions, civil penalties,loss of contracts or lawsuits by competitors. Violation ofthese rules may result in enforcement action against theCompany and its employees, including criminal sanctionsand exclusion from future U.S. Governmentcontract competition.RED FLAGSAccepting oral or written extracts of informationthat appear to be U.S. Government source-selectionor contractor bid or proposal information.Changes to contract requirements made by U.S.Government officials other than thecontracting officer.Failure to perform all contractually required testingand inspections, even those believed to beunnecessary or duplicative.Making false, inaccurate or misleadingrepresentations or certifications.WHAT YOU NEED TO KNOWProtect all Company-owned or leased property andequipment, including tangible assets such as money,inventory, tools, supplies, documents, electronic data andvehicles, as well as intangible assets such as plans, tradesecrets, computer programs, employee and businessinformation and other proprietary information.Proprietary Information obtained or developed as part of aDRS employee’s job is also property that should beprotected, because its unauthorized disclosure coulddiminish its value to the Company and provide an unfairadvantage to others.Limit any personal use of Company property to reasonable,incidental use that is not improper, does not adverselyimpact the Company’s reputation, cause significantadditional cost, or interfere with or affect your jobperformance or that of any other person or organization.Never use Company property or assets to support apersonal activity, business, consulting or similarprivate venture.Return all Company documents, records and propertyin your possession at the termination of youremployment with DRS.RED FLAGSBorrowing, giving away, loaning, selling orotherwise disposing of Company propertywithout specific authorization, regardless ofcondition.Theft, damage or misuse of Company property.Removing Company property from DRS orcustomer premises without properauthorization.Related DRS Policies and Other Resources: DRS Policy – Accuracy of Books and Records; DRS Policy – Contract Representationand Certification; DRS Policy – Updating Cost or Pricing Data for Definitizing a Negotiated Procurement (TINA); DRS Policy –Government Property; DRS Policy – Preventions of False Claims and False Statements; DRS Policy – Post-Award ContractReview; DRS Policy – Procurement Integrity; DRS Policy – Product Substitution; DRS Policy – Sale of Commercial Items andServices; DRS Policy – Subcontracting; DRS Policy – Progress Payments; DRS Policy – Unallowable CostsRelated DRS Policies and Other Resources:DRS Policy – Use of Company Property; DRS Policy –Personal Conflicts of Interest; DRS Request forPersonal Conflict of Interest Determination Form24 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.employees, agents, subcontractors and board members.25

USE OF THIRD-PARTY INTERMEDIARIES(CONSULTANTS, CONTRACTORS AND INTERNATIONAL INTERMEDIARIES)It may be helpful or necessary to use third-party intermediaries in the course of DRS business.Never use consultants, contractors or temporary help to circumvent any DRS procedures orpolicies. All third-party intermediaries must comply with the DRS Code of Business Ethics andConduct, the laws and regulations of the U.S., and, if applicable, with foreign countries inwhich they operate.WHAT YOU NEED TO KNOWWhen engaging consultants, contractors or other parties,determine their reputation for integrity and seek to identifyany former employment or contracts that may create aconflict of interest or the appearance of a conflictof interest.Hold anyone representing DRS to a standard consistentwith the DRS Code of Business Ethics and Conduct andapplicable policies, including the protection of DRS orcustomer trade secrets or other information that is securityclassified, proprietary, inside information or otherwisecapable of giving DRS or another company an unfair orillegal competitive advantage.Ensure that any agreement allows DRS to terminate theagreement for default if a consultant, contractor or otherparty fails to abide by DRS Code of Business Ethicsand Conduct.Abide by DRS procedures and rules applicable to control,protection, preservation and maintenance of U.S.Government property in the possession or control of DRS orits subcontractors.Carefully review each new DRS contract. Identify andadhere strictly to all contract requirements.RED FLAGSRefusal of consultants, contractors or otherparty to abide by the DRS Code of BusinessEthics and Conduct or applicable DRS policies orprocedures, or applicable laws and regulations.Requests for unusual structuring of thetransaction or payments.Rumors of improper payments or other unethicalpractices by the intermediary.Incomplete or inaccurate information in requireddocumentation or disclosures.Expectations of or requests for unusually largediscounts, commissions, expenses or other paymentsthat appear excessive in relation to theservice rendered.Using a consultant to engage in business practicesthat are a violation of DRS policies or the Code ofBusiness Ethics and Conduct.ANNUAL PERSONAL COMMITMENT AND ACKNOWLEDGEMENTEvery DRS employee is required to provide an annual certification and acknowledgement of thisCode of Business Ethics and Conduct.I have received and read the DRS Code of Business Ethics and Conduct. I understand that by signing my namebelow I am acknowledging and committing that I will uphold my responsibilities as an employee of DRS and willcomply with the Code requirements.I will promptly report information concerning any violation of the Code.I understand that I will be subject to disciplinary action, up to and including termination, if I violate any provisionof this Code, including my obligation to report violations.In addition, I hereby certify that I am not aware of any unreported violations of the provisions of this Code.SignaturePrint NameDepartmentDateRelated DRS Policies and Other Resources:DRS Policy – Consultants; DRS Policy – Domesticand Foreign Agreements; DRS Guide toAgreements with International Intermediaries26 Note: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeNote: This Code of Business Ethics and Conduct is intended as a summary. DRS policies govern the actions and conduct of all DRS full- and part-timeemployees, agents, subcontractors and board members.employees, agents, subcontractors and board members.27