Lipmann Walton & Co Ltd., policy on ‘Dual Use’ metals and materials
It is the policy of Lipmann Walton’s directors and employees to be compliant and aware of the rules governing ‘Dual Use’ metals and materials with which our company may be involved.
All employees and directors are encouraged to read the available information on the UK Export Control Organization (ECO) website as well as to study manuals explaining the rules governing the export of ‘Dual Use’ goods. Lipmann Walton also maintains a manual and checking system, to ensure our company takes steps to be compliant at all times. Training involves attendance at Export Control Organization (ECO) courses.
All employees are aware of EU Regulation 428/2009, which is the governing law, and easily available on the internet.
Even more important than our manual is having an attitude that considers the implications of any metals we handle falling into wrong hands, which we have a duty to prevent.
Members of Lipmann Walton are aware that we are a specialist metals merchant and that part of our business touches dual use materials; for example when our company is involved in the transfer of metals, through trade, from the nuclear to civil sectors. This may involve, for example, the handling of production scrap of nuclear grade metals and other non-radioactive by-products. This is a legitimate trade necessary for civil industry to acquire metals or compounds needed in a range of civil or even household products. Taking Hafnium as an example of a Dual Use metal, this is required as an addition in super alloys for aerospace and in the manufacture of wires used within plasma-cutting tips. Another example is high purity Dual Use nuclear grade zirconium, needed in several specialist alloys for aerospace or robotics as well as many other applications. Furthermore, there are other elements or substances, not yet handled by the company, which could come into Dual Use scope and, for this reason, all employees are aware, in this event, of their collective and individual responsibility for compliance. Employees are required to bring to each other’s attention any areas of doubt and to assist each other in compliance with the law.
Within Lipmann Walton & Co Ltd., Michal Husakiewicz is appointed Officer in Charge of Dual Use & Export Control compliance and Karolina Jackiewicz as Assistant Export Control Officer, however, as mentioned above, Lipmann Walton promotes a culture of knowledge so that our entire company fully plays its part in the chain of national compliance with the Nuclear Non-Proliferation Treaty and other similar and relevant international laws.