Many countries, including the United States, the United Kingdom and Australia, have established economic sanctions regimes and export and import controls that prohibit or restrict dealings with certain countries, regions, and parties (including businesses and individuals). Tronox also chooses to restrict dealings in certain jurisdictions based on factors, such as risk of corruption, risk to intellectual property, potential harm to the reputation of our brand, lack of fairness and transparency of local legal processes, and the likelihood that counterparties will fail to comply with contractual commitments. It is the responsibility of all Tronox employees who engage in international trade to understand which countries are completely restricted and which countries are considered high risk. We have officially designated the two categories as:
- Jurisdictions that are strictly off limits where Tronox will not do business, either sell products or procure raw materials or services.
- Jurisdictions where before doing business — either selling goods or procuring raw materials or services — employees should check with the Legal Department so that due diligence can be conducted.
Employees should review policy 60.17 for the listing of jurisdictions.