CORPORATE GOVERNANCE

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. The Corporate Social Responsibility Report reinforces this commitment.

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 are committed to conducting business in an ethically and socially responsible manner. We expect all employees to fully comply with the 12 standards embodied in our Business Ethics Code of Conduct, which provides a framework for everything we do.

The Business Ethics Code of Conduct is also available in the following languages:

Albanian Arabic Bosnian Burmese
Chinese Simplified Russian Lao Somali
Spanish Tagalog Turkish Vietnamese

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 independent non-executive Chairman of the Board is designated as the chair of the independent director meetings.

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