Denied Parties Screening Trade Compliance Manager David Ross Trade Compliance Manager H.C. STARCK MA Export Center 11-3-11

Today’s Agenda Overview: H.C. Starck Inc Best Practices for Screening Denied Parties, The H.C. Starck process Live Demo Q&A

OVERVIEW: H.C. STARCK INC Headquarters: Newton, MA Owned by: The Carlyle Group and Advent International Sales 2010: $1.3 billion 550 Employees in the USA More than 3,200 employees worldwide 13 sites and sales offices in more than 30 countries Leading supplier of refractory metal products - Molybdenum - Niobium - Rhenium - Tantalum - Tungsten

10% of Sales US Aerospace & Defense FABRICATED PRODUCTS - KEY MARKETS 26% of Sales Consumer Electronics 10% of Sales US Aerospace & Defense

US MANUFACTURING SITES Sensitive Company Information FPR Sites Worldwide USA Coldwater, Michigan Euclid, Ohio Newton, Massachusetts Europe & Asia Calne, United Kingdom Hermsdorf, Germany Taicang, China

US SITE INFORMATION: EUCLID, OHIO Key Statistics Sales ($ Million): 140 Headcount: 246 Major Processes: Rolling Pressing and Sintering of Tungsten Heavy Alloys Machining

US SITE INFORMATION: COLDWATER, MICHIGAN Key Statistics Sales ($ Million): 70.7 Headcount: 130 Major Processes: Molybdenum Powder Production Pressing and Sintering of Molybdenum and Tungsten Extrusion and Rotary Forging Arc Melting

US SITE INFORMATION: NEWTON, MASSACHUSETTS Key Statistics Sales ($ Million): 62.1 Headcount: 180 Major Processes: Ta Powder Processing EB and VAR Melting Forging and Rolling Fabrication

Powder Production & Development Particle Size Chemistry Morphology

Extrusion and Rotary Forging Bars Tubes Shapes

Energy Related Products - Photovoltaic Tubular and Planar Sputtering Targets - Nuclear Fuel Processing Hardware - Nuclear Shielding - Thermal Solar Mirrors

Planar Sputtering Targets for Flat Panel Display Molybdenum Tungsten Mo Alloys

- Explosively Formed Penetrators - Shaped Charge Liners Warhead Liners - Explosively Formed Penetrators - Shaped Charge Liners - Mo and Ta Forging Blanks - Alternate Materials - Prototype Machining Javelin Missile Example

Machined Tungsten Alloy Products

Corrosion Resistant Solutions for Chemical Processing Tantalum Tubing

Aerospace/Defense - Aircraft Balance/Ballast Weights - Ailerons, rudder, stabilizer - Helicopter Rotor/Blade Weights - Missile counterweights - Engine flame sensors/shields - Propulsion Nozzles - Ordnance/Warheads

Denied Party Screening Essentials Screen at the beginning and end of the order/shipping process Ideally, at quote stage, then at the time of shipment Be wary of “close matches” Investigate thoroughly Any doubts should be discussed with Trade Compliance and/or the Legal Department HAVE THE RIGHT SCREENING TOOL IN PLACE!!!

Lists To Check Denied Parties List Entities List Specially Designated Nationals List Un-Verified List Debarred List (Defense Items Only)

Screening Guidelines Best search method is “Name” “Contains” (Company Name) If a hit list comes out, screen for a match If a list doesn’t come out, hit “Search for Closest Matches” Screen for a match If a match or close match appears, contact Trade Compliance/Legal HOLD THE SHIPMENT UNTIL ISSUES ARE RESOLVED!!! In either case of a match or no match, print out results sheet and place in the customer order file.

Web Based Screening Guidelines Using the customer name, perform a Yahoo or Google search on the internet Locate the customer’s home page Read the “About” section off the homepage. This will give you a high level look at the company and it’s products As a secondary screen read about the products offered in the “products” section Look for anything related to chemical, biological, missile tech, nuclear or military applications Also look for types of customers (i.e. government, defense, educational) If found, contact Trade Compliance to investigate further If product offering appears clean, print a copy of the “About” or other relevant part of the website and place in the customer order file If no website is available, this is a RED FLAG. Contact Trade Compliance

Example: Drop Shipment, Buffalo, NY, US Location

Denied Party Screening Lesson Learned? KNOW YOUR CUSTOMER

Thank you!! Q&A Contact Info: David Ross Trade Compliance Manager H.C. Starck Inc. 45 Industrial Place Newton, MA 02461 Office: (617)-630-5978 Cell: (617)-803-9369 Email: david.ross@hcstarck.com