Compliance 

EU REACH and UK REACH


EU REACH is a European Union Regulation which came into force on 1 June 2008. UK REACH is a United Kingdom Regulation which came into force on 1 Jan 2021 and has the same purpose as the EU equivalent. Both regulations address the impact of chemical substances on human health and the environment. EU & UK REACH requires importers of substances into the EU & UK market register with the European Chemical Agency (for EU REACH) and Health and Safety Executive (for UK REACH) and ensure that all possible steps are taken to protect users from any hazards that may result from these substances. Importers who have not registered their substances will not be able to import them in quantities of above 1 tonne per year into either jurisdiction (EU/UK). Lipmann Walton & Co Ltd has grandfathered and will register all relevant substances in order to comply with UK REACH while our EU based subsidiary - Lipmann Walton Ireland Ltd has fully registered a number of metals and substances and is fully complying with EU REACH. As our customer you can be assured that we will fully comply with both of these regulations. If you have any questions regarding either UK REACH or EU REACH please do not hesitate to contact us. For further information please contact: Michael Husakiewicz




Conflict minerals


Dodd-Frank Section 1502/ Lipmann Compliance ref: Tantalum & Tungsten: This section of our website contains details of our policy towards compliance with Section 1502 of the U.S. Dodd Frank law governing conflict minerals. The Dodd-Frank Act which came into law in the USA in 2010, as a response to the Financial Crash of 2008, contains a sub-section (1502) addressing the issue of consumer responsibility towards ‘conflict minerals’ in the supply chain. The intended purpose of the act was to create a chain of transparency from the source of minerals in conflict zones, defined essentially as The Democratic Republic of Congo (DRC) and neighbouring countries. Modelled on ‘conflict diamonds’ initiatives, this piece of legislation seeks to change circumstances on the ground in producing countries. The aim is to prevent the proceeds of minerals sales getting into the hands of war-lords and mitigate the suffering of communities/effect on the environment in DRC, whose way of life has been dictated by compulsory artisanal mining, with side-effects of human-rights violations, (including rape, mutilation, use of child-soldiers). For further background information please click this link: https://www.sec.gov/rules/final/2012/34-67716.pdf Lipmann’s policy with regard to the two conflict minerals with which we work – Tantalum and Tungsten metal – is to trade these, where possible, in the form of high-purity scrap, suitable for delivery to end-users. Under OECD guidance, scrap is defined as: “Metals reasonably assumed to be recycled are excluded from the scope of this Guidance. Recycled metals are reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing. Recycled metal includes excess, obsolete, defective, and scrap metal materials which contain refined or processed metals that are appropriate to recycle in the production of tin, tantalum, tungsten and/or gold. Minerals partially processed, unprocessed or a bi-product from another ore are not recycled metals.” (Page 14 of pdf, page 12 of printed document) Scrap, therefore, as defined in the above paragraph, is regarded as ‘DRC-Conflict Free’. In spite of the foregoing, Lipmann Walton has instituted a management system to document and verify that all scrap purchased, is genuinely scrap (and not prime metal). This now forms part of our ISO management system, audited by Moodys. Where prime metal is sourced, Lipmann Walton will either purchase from companies listed under the ‘Conflict-Free Smelter Scheme’ (CFS), or, if not part of this scheme, carry out due diligence and obtain manufacturer’s certification, stating country/ specific mine from where raw material was sourced. It is important here to note that, under the guidance, it is not illegal to source raw material from conflict zones, if it is correctly ‘bagged & tagged’ (as per EICC/GeSI) from listed sources




Dual-Use


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, as retained under the EU (Withdrawal) Act 2018 for Great Britain. 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. Where applicable, Lipmann Walton Ireland Ltd (wholly-owned subsidiary of Lipmann Walton & Co Ltd) for the purpose of compliance with export controls of Dual-Use items, or for other regulatory purposes will take over responsibility as exporter on behalf of Lipmann Walton & Co Ltd for relevant goods exported from EU in accordance with EU and Irish Export Controls. Within Lipmann Walton & Co Ltd and on behalf of Lipmann Walton Ireland 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.