Northrop Grumman Innovation Systems Veba Trust

“Part VI, Section A, Line 1 Orbital ATK, Inc. has designated the Orbital ATK, Inc. Pension Investment Committee (PIC) as the governing body with respect to oversight of plan assets in the trust and the Orbital ATK, Inc. Pension and Retirement Committee (PRC) with respect to administration of medical and life insurance benefits funded by the trust.”

“Part VI, Section A, Line 3 US Bank National Assoc. has been further appointed as an independent corporate trustee with respect to the trust. The Trustee holds, administers, invests and reinvests, and disburses trust funds in accordance with the powers and restrictions set forth in the trust agreement.”

“Part VI, Section A, Line 7A & 7B Members of the PIC and PRC are designated in their respective governing charters and in the terms of the underlying Company benefit plan documents. The PIC and PRC, in turn, have the authority to certify to the Trustee the name of the person(s) (in addition to the Chief Financial Officer, Treasurer, and Assistant Treasurer) having authority on behalf of the Company to direct the Trustee with respect to disbursement of trust funds for plan purposes, and the name of the person(s) having authority on behalf of the Company to communicate with the Trustee with respect to any other matter relating to the trust.”

“Form 990, Part VI, Line 9 The Trustee, U.S. Bank, cannot be reached at the organization's mailing address. Current contact information for the Trustee is: U.S. Bank, C/O Lisa Foster, 60 LIVINGSTON AVENUE, ST PAUL, MN 55107.”

“Form 990, Part VI, Line 11b The final Form 990 and its various schedules were prepared by a national CPA firm, and reviewed by the key officers and trustee of the Trust. Identified changes were incorporated prior to filing Form 990 with the IRS.”

“Part 990, Part VI, Line 12C While the VEBA itself does not have a conflict of interest policy, it is governed and administered by individuals subject to the policies of Orbital ATK, Inc., including the conflict of interest and reporting provisions set forth in the Orbital ATK, Inc. Code of Ethics and Business Conduct. The trustee has adopted a code of business conduct and ethics that includes a section on conflict of interest. The trustee requires key staff members to annually (a) disclose their outside connections and ownership interest in a conflict of interest policy disclosure and return it to the office of the general counsel and (b) affirm that they have reviewed and are in compliance with a number of the trustee's policies including the code of business conduct and ethics and its guidelines relating to standards of conduct, which also includes a section on conflicts of interest. Potential conflicts of interest are disclosed immediately.”

“Form 990, Part VI, Line 19 Financial status is provided yearly via Summary Annual Reports (SARs). The SARs are consolidated into one document and are sent to all active EEs, retirees, beneficiaries and terminated EEs who were employed during the calendar year 2017 or terminated EEs entitled to future benefits. The Annual Report is filed with the Employee Benefits Security Administration (EBSA). Additionally a statement of the assets and liabilities of the plan, governing documents and conflict of interest policy is available upon request by writing to Orbital ATK, Inc., Employee Solutions, 5995 Opus Parkway, Suite 330, Minnetonka, MN 55343.”