Corporate Governance
When ATK was formed in 1990, the new company's Board of Directors recognized that a solid commitment to corporate governance was critical to establishing trust and credibility with investors. That commitment has grown even stronger over the years, providing ATK with a framework for principled leadership, responsible decision-making, and monitoring financial performance and compliance with legal requirements.

At the heart of our corporate governance program is the ATK Business Ethics Code of Conduct, which serves as a foundation for everything we do — from how we conduct business and make decisions, to how we treat each other.

Corporate Governance Ranking
As of July 1, 2009, our Corporate Governance Quotient ratings, which are published by RiskMetrics Group after evaluating approximately 7,400 companies on up to 65 corporate governance variables, show that we outperformed 65.7% of the companies in the S&P 400 MidCap Index and 82.8% of the companies in the Capital Goods group.

Corporate Governance Guidelines
Our business is managed through the oversight and direction of our Board of Directors. Our Corporate Governance Guidelines include qualifications for directors, guidelines for determining director independence, and provisions for reporting concerns to the Board's Audit Committee regarding accounting, internal controls, and directors' potential conflicts of interest. Our committee charters are also available in this section of the website.

Regular Reviews and Updates
Our Board regularly compares our policies, guidelines, and committee charters to best practice standards and reviews corporate governance developments, including legal and regulatory changes, and makes modifications as warranted. All updates of our policies and procedures will be available on this website.

Business Ethics Code of Conduct
We have a written Code of Conduct, which applies to all directors, officers, and employees. Our corporate governance guidelines provide that the Board will not permit any waiver of our ethics policies.

Communications with Directors
Procedures for stockholders, or anyone else, to communicate directly with ATK's directors are available on this website. Concerns regarding the Company's accounting, internal controls or auditing matters will be referred to the Audit Committee.

Independent Director Meetings
As a matter of policy, meetings of our independent directors as a group are a part of all regularly scheduled meetings of the Board of Directors. The chair of the Nominating and Governance Committee is designated as the chair of the independent director meetings.