General Dynamics (GD) is exposed to significant actual and potential human rights risks. The use of its defense
products and services may violate the rights to life, liberty, personal security, and privacy. The UN Guiding Principles on Business
and Human Rights (UNGPs) constitute the global authoritative framework outlining human rights responsibilities of states and
businesses, and expectations are heightened for companies with business activities in conflict‑affected and high‑risk areas.
Companies' human rights responsibilities are independent of the state's export licensing determinations, as reiterated in a recent
United Nations note.

GD's Human Rights policy is not aligned with the UNGPs, and investors lack evidence it is effectively implemented across
business functions. Disclosure of HRIAs and remedies is absent. Insufficient human rights monitoring exposes GD and its
investors to legal, financial, and reputational risks.

GD sells products and provides services to authoritarian regimes, such as Saudi Arabia. A recent US government report highlights
the US' failure to monitor whether its weapons or services have been used by the Saudi‑led coalition to attack civilians. A GD
component was linked to a 2018 school bus bombing, which killed dozens of children in Yemen and has been recognized as a war
crime. The Company faces increasing legal risk, as a group of Yemeni nationals sued GD and peer defense contractors in 2023 for
their complicity in war crimes in Yemen.

GD also supplies artillery munitions and bombs to Israel, which have been reportedly used in attacks on Palestinian civilians in
Gaza, that may constitute war crimes, and, according to the International Court of Justice, may plausibly amount to genocide.
Although, in June 2024, UN experts called on companies to immediately end arms transfers to Israel, even if approved by State
export licensing, or risk complicity in violations of human rights and international humanitarian law, GD continues to sell weapons
to Israel.
Furthermore, GD has $28 billion in contracts for work on nuclear weapons, which are prohibited under international law.
Failure to meet its human rights responsibilities exposes GD to divestment risk. Most recently, Norges Bank decided to exclude
GD from its Government Pension Fund Global, the world's largest sovereign wealth fund, since the company produces "key
components to nuclear weapons."

New guidance from the American Bar Association explains how an HRIA can reduce risks, including divestment, export bans, and
civil liability. An HRIA can mitigate GD's continuity risks, as increased federal oversight on customer end‑use may limit or cancel
existing or future contracts.

1) https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf
2) https://www.ohchr.org/sites/default/files/2022‑08/BHR‑Arms‑sector‑info‑note.pdf
3) https://www.reuters.com/article/us‑generaldynamics‑canada‑saudi/
general‑dynamics‑canada‑wins‑saudi‑deal‑worth‑up‑to‑13‑billion‑idUSBREA1D1EF20140214; https://www.gdarabia.com/
experience/
4) https://www.gao.gov/assets/gao‑22‑105988.pdf
5) https://www.hrw.org/news/2018/09/02/yemen‑coalition‑bus‑bombing‑apparent‑war‑crime#