POLICY ON TRADING IN SECURITIES

Insider Trading Policy
Directors, officers and employees of Ducommun Incorporated ("Ducommun") and its subsidiaries (collectively, the "Company") shall not trade in Ducommun securities while in possession of material nonpublic information. Further, directors, officers and employees of the Company shall not disclose any such information to others who might use it for trading, or might pass it on to others who might use it for trading. Likewise, directors, officers and employees of the Company shall not trade in securities of any other company while in possession of material nonpublic information about that company which they obtained in the course of their employment or in the course of their service as a director with the Company.

Blackout Policy
Directors and officers of Ducommun, and the persons designated by the Board of Directors of Ducommun as listed on Exhibit A attached hereto, shall not trade in the securities of Ducommun during any blackout period.

Preclearance Policy
Directors and officers of Ducommun, and presidents of the significant subsidiaries of Ducommun, shall obtain preclearance of any trade in Ducommun securities. Preclearance shall be obtained from the general counsel of Ducommun, or if he is not available, from either the chief executive officer or the controller of Ducommun. Preclearance must be provided in writing.

Definitions
As used herein, the following definitions apply:

• "Blackout Period" is the period beginning on the first day of a fiscal quarter of Ducommun and ending either (i) 72 hours after the issuance of a press release reporting Ducommun's full-year financial results, or (ii) 48 hours after the issuance of a press release reporting Ducommun's quarterly financial results. In addition to the standard end-of-quarter blackout period, Ducommun may, from time to time, impose other blackout periods upon notice to those persons who are affected.
  
  
• "Material" information is information that a reasonable investor would very likely consider important in deciding whether to purchase or sell a security and that could affect the price of the security.
  
  
• "Nonpublic" information is information that is not publicly available.
  
  
• "Securities" include common stock, preferred stock, put and call options, convertible debentures, and debt securities such as bonds and notes.
  
  
• "Trading" includes buying or selling, as well as writing options. Trading does not include purchasing stock under an employee stock option, even if the exercise price is paid in Ducommun stock and stock is withheld to pay an employee's employment-related taxes in connection therewith, provided that no Ducommun stock is sold in the public markets in connection with the stock option exercise.
  
  

Return to Corporate Governance