Notice of voestalpine High Performance Metals, Ltd. ITAR Compliance Program

    The U.S. International Traffic in Arms Regulations (“ITAR”), 22 C.F.R. Parts 120- 130, sets forth U.S. Government export and re-export controls on articles specifically designed or modified for military or space applications, and technical data and services related to such articles. Pursuant to the Canadian Exemption at Section 126.5 of the ITAR, eligible U.S. companies can send “build-to-print” and “build/design-to-specification” technical data for the manufacture of certain specified ITAR-controlled articles to Canadian companies that are registered with the Canadian Government Controlled Goods Directorate (“CGD”) without a license or other written authorization from the U.S. Department of State Directorate of Defense Trade Controls (“DDTC”).

    U.S. companies must be properly registered with the DDTC for the exemption to apply. voestalpine High Performance Metals, Ltd. (hereinafter “vHPML”) is registered with the CGD and is therefore eligible to receive technical data on various defense articles as permitted under the ITAR Canadian Exemption. vHPML’s CGD registration number is 29871. vHPML’s registration status can also be confirmed through a search of the CGD registration database, available at https://www.tpsgc-pwgsc.gc.ca/pmc-cgp/recherche-search-eng.html, and by telephoning the CGD information desk at 1-866-368-4646 or via e-mail at ncr.cgd@pwgsc.gc.ca.

    vHPML is also certified pursuant to the U.S./Canadian Joint Certification Program (“JCP”). Under the JCP, vHPML is certified to receive technical data governed, in the U.S., by U.S. Department of Defense Directive 5230.25 and, in Canada, by the Technical Data Control Regulations (subject to compliance with U.S. and Canadian export and import control laws). vHPML’s JCP Registration number is 29871 and their certification is valid until 2026/06/07.

    vHPML view compliance with ITAR, U.S. Department of Defense, and Canadian Department of National Defence requirements as a priority. Their export controls compliance program includes: • Secured network systems that restrict access to ITAR controlled technical data • Physical security and access controls at all company facilities • Management commitment to ITAR compliance To further ease its customer’s use of the ITAR Canadian Exemption, vHPML have retained U.S. legal counsel to advise its customers on the Exemption’s specific requirements. Alternately, a U.S. company can apply for an export license or other authorization from the DDTC to export articles, data, and/or services which does not fall under the ITAR Canadian Exemption to vHPML.

    (Updated: September 17, 2021)

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