Exhibit 1.02 – Conflict Minerals Report
Based on the results of the RCOI, eight business units conducted due diligence as a result of responses from suppliers that Conflict Minerals contained in certain products supplied to the business units may have originated in one or more Covered Countries.
Due Diligence Measures
We and our business units have undertaken measures to enact due diligence processes informed by the Due Diligence Guidance for Responsible Supply Chains of Minerals fromConflict-Affected andHigh-Risk Areas published by the Organization for Economic Cooperation and Development (the “OECD Guidance”).
Our and our business units’ due diligence efforts include:
| • | maintaining a team of both internal and external experts to support supply chain due diligence efforts; |
| • | incorporating ConflictMinerals-related contractual provisions into agreements with relevant suppliers; |
| • | conducting surveys of suppliers to obtain critical information about the presence and origin of Conflict Minerals in the products they supply to the business units; |
| • | compiling completed surveys and other supplier communications into business unit databases; |
| • | conducting analysis of supplier responses and evaluating the provided information in a manner designed to identify and assess minerals fromconflict-affected andhigh-risk areas in a business units’ product supply chain; |
| • | undertaking additional assessments for identified minerals fromconflict-affected andhigh-risk areas in a business units’ supply chain; |
| • | maintaining membership in industry organizations, such as the Aerospace Industry Association, to keep current on industry practices for Conflict Minerals regulatory compliance and to contribute to the development of those practices; and |
| • | reporting annually on Conflict Minerals due diligence efforts, including posting the most recent Form SD and Conflict Minerals Report at www.generaldynamics.com/conflictminerals. |
Information Concerning Processors and Country of Origin
As stated above, eight business units determined that they have a reason to believe that limited amounts of necessary Conflict Minerals in certain Completed Products may have originated in one or more Covered Countries. As a result, these business units exercised due diligence on the source and chain of custody of those Conflict Minerals, as required by Rule13-p1.
Specifically, the business units engaged in discussions with certain suppliers, which had represented that products provided to the business units likely contained Conflict Minerals that came from one or more Covered Countries. When engaged, many suppliers further represented that they had not yet been able to complete their own due diligence to determine whether the minerals financed or benefitted armed groups. As a result, these suppliers were unable to provide further details regarding: (1) the facilities used to process the necessary Conflict Minerals contained in products supplied to the business units; (2) the country of origin of the necessary Conflict Minerals contained in products supplied to the business units; or (3) efforts to determine the mine or location of origin of the necessary Conflict Minerals contained in products supplied to the business units.
In addition, other suppliers failed to respond to the business units’ due diligence efforts and the relevant business units have therefore been unable to ascertain further details regarding: (1) the facilities used to process the necessary Conflict Minerals contained in products supplied to the business units; (2) the country of origin of the necessary Conflict Minerals contained in products supplied to the business units; or (3) efforts to determine the mine or location of origin of the necessary Conflict Minerals contained in products supplied to the business units.
Continuing Efforts
Commensurate with the requirements of Rule13-p1, we and our business units will make efforts to continue to:
| • | assess the presence of Conflict Minerals in our product supply chains; |
| • | communicate our expectations to our suppliers regarding Conflict Minerals sourcing; and |
| • | encourage participation of suppliers in programs designed to share information within industry that are aimed at improving assessment of supplier due diligence in the supply chain of minerals fromconflict-affected andhigh-risk areas. |
