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United Nations Security Council & Australian Autonomous SanctionsHigher Degree by Research – Compliance & Risk Assessment Form
INTRODUCTIONFrom 1 July 2011, the Autonomous Sanctions Act 2011 has provided a new framework designed to strengthen Australia's existing autonomous sanctions by consolidating them to a single piece of legislation. The sanctions framework includes regulations designed to drive a strict liability regime under which Australian organisations (including universities) could be liable for a breach if they are unable to demonstrate that they have taken ‘reasonable precautions’ and ‘exercised due diligence’ in the development and implementation of Autonomous Sanctions (AS) related policies, procedures, and educational/training programs.
Sanctions are coercive or punitive measures imposed by governments as a means of influencing regimes to alter their behaviour. Australia imposes two main types of sanctions measures:
Multilateral sanctions based on resolutions made by the United Nations Security Council; and Australian Autonomous Sanctions.
Sanctions impose restrictions on activities related to designated individuals and entities, with designated products, or in designated locations. A number of university activities may give rise to risks under sanctions laws.
The University of Tasmania and its staff are obliged to comply with the sanctions as they apply to countries where there is prohibition on providing a 'sanctioned-service', and will breach the Act if they are unable to demonstrate that they have taken 'reasonable precautions' and exercised 'due diligence'. The Autonomous Sanctions regime imposes serious penalties for breaching sanctions laws. The University could be liable for fines of up to $1.7 Million or three times the transaction value (whichever is higher). Individual staff members can also be personally liable, with a maximum of 10 years imprisonment and/or fines of up to $425,000 or three times the transaction value.
PURPOSEThe purpose of this Form is to undertake a risk assessment to ensure an application for admission and/or scholarship for a Higher Degree by Research (HDR) does not breach any of Australia's international sanctions. All proposed or nominated supervisors must be involved in the special assessment of applications from citizens of sanctioned countries that they wish to support for an offer of admission. Supervisors must also sign this assessment form and the form must be endorsed by the Head of School and the Associate Dean or Director of Research (ADDR) of the appropriate College or Institute.
CURRENT SANCTIONS REGIMESPlease view the current Australian sanction laws implement United Nations Security Council (UNSC) sanctions regimes and Australian autonomous sanctions regimes online as these are subject to frequent, rapid and significant changes. Accordingly, this Form is also subject to change.
Please return this form to the Candidature Management Advisor in Word format (not PDF):
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SECTIONS TO COMPLETE (CANDIDATURE MANAGEMENT ADVISOR TO COMPLETE CHECKLIST)The following is a guide of what sections of this form need to be completed, depending on the applicant’s citizenship. Please check the sections that need to be completed for this applicant;
☒ Section A: All Applicants☒ Section B: All Applicants☒ Section C: All Applicants☐ Section D1: Citizens of Iran☐ Section D2: Citizens of Syria☐ Section D3: Citizens of Russia, Crimea & Sevastopol☐ Section D4: Citizens of Democratic People’s Republic of Korea☐ Section D5: Citizens of all other sanctioned countries/regimes☒ Assessment & Approvals: All Applicants
Please ensure that the information is complete, true and accurate to the best of your knowledge. Failure to do so will result in significant delays of this Autonomous Sanctions review and the application for admission/scholarship for entry into a Higher Degree by Research program at the University of Tasmania.
SECTION A: APPLICANT DETAILS (TO BE COMPLETED BY THE CANDIDATURE MANAGEMENT ADVISOR)Family Name: Given Name(s): Sanctioned Country of Citizenship:
Date of Birth: UTAS ID:
1. Does the applicant have dual (Australian or other) citizenship? ☐ Yes ☐ No2. Is the applicant a Permanent Resident of Australia? ☐ Yes ☐ No3. Does the applicant hold an Australian Humanitarian VISA? ☐ Yes ☐ No4. Does the applicant’s name appear on the DFAT Consolidated List? ☐ Yes ☐ No5. Does the applicant hold a sponsorship OR receive financial support from an
institution/government located in a sanctioned country?☐ Yes ☐ No
If YES, please provide details:
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SECTION B: PROGRAM INFORMATION (TO BE COMPLETED BY THE PRIMARY SUPERVISOR)B1: HDR Program & SupportProposed School/Centre:
In the Degree Program:
☐ Doctor of Philosophy (PhD)
☐ Professional Doctorate
☐ Master by Research
Course Code: Primary Supervisor:
B2.1: Title of Proposed Project
B2.2: Project Description (Please ensure this description is non-technical and can be understood by a non-discipline specific person. DO NOT copy and paste the project proposal from the Application Part 1 document, this is insufficient for this compliance and risk assessment to be undertaken, this form will be sent back to you to be corrected and may cause delays in the application process.)
B3: Classification of Research (as per Australian Bureau of Statistics guidelines)
☐ Pure basic research**☐ Strategic basic research
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☐ Applied research☐ Experimental development
**DFAT apply the definition of ‘basic scientific research’ as: ‘experimental or theoretical work undertaken principally to acquire new knowledge of the fundamental principles of phenomena or observable facts, not primarily directed towards a specific practical aim or objective’, and is therefore ‘insufficiently specialised to constitute “technical” training’.
B4.1: Does the proposed project involve the use, development, or training/technical advice in the use, development or maintenance of any of the following ‘arms or related material’? (Tick all that apply)
Weapons, ammunition, military vehicles and equipment ☐ Yes ☐ No
Any spare parts or accessories for weapons, military vehicles, equipment and/or technology
☐ Yes ☐ No
Paramilitary or law enforcement equipment (e.g. body armour, anti-riot gear, restraints etc)
☐ Yes ☐ No
If YES, please provide details:
B4.2: Does the proposed project involve technology or software which has NOT already been made available without restrictions upon its further dissemination (i.e. is NOT already in the public domain)?☐ Yes☐ No
If YES, please provide details:
B4.3: Does the proposed project involve or require any external organisations?(in terms of funding, intellectual property, research collaboration or deliverables)
☐ Yes☐ No
If YES, please provide details:
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SECTION C: AUTONOMOUS SANCTIONS LEGISLATIONS COMPLIANCE (TO BE COMPLETED BY THE PRIMARY SUPERVISOR)ALL APPLICANTSC1.1: Please consider the goods & technologies included on The Australia Group Common Control Lists.Goods and technologies on the List:
Chemical weapons precursors; Dual-use chemical manufacturing facilities and equipment and related technologies and software; Dual-use biological equipment and related technology and software; Biological agents; Plant pathogens; and Animal pathogens.
Does the research topic or project involve, or could it be reasonably expected to involve, any of the goods and technologies included on those Lists?
☐ Yes☐ NoIf YES, please provide details:
Applicable list; The goods and/or technologies; and How the applicant’s research topic, project or otherwise necessitates their involvement with the
relevant goods or technologies
C1.2: Please consider the Defence and Strategic Goods List(maintained by the Department of Defence).Examples of goods and technologies caught on the List:
Military goods (those goods or technology that is designed or adapted for military purposes including parts and accessories thereof);
Non-military lethal goods (equipment that is inherently lethal, incapacitating or destructive such as non-military firearms, non-military ammunition and commercial explosives and initiators);
Dual-use goods (equipment and technologies developed to meet commercial needs but which may be used either as military components or for the development or production of military systems or weapons of mass destruction);
Category 0 - Nuclear Materials; Category 1 - Materials, Chemicals, Microorganisms and Toxins; Category 2 - Materials Processing; Category 3 - Electronics; Category 4 - Computers; Category 5 - Telecommunications and Information Security; Category 6 - Sensors & Lasers; Category 7 - Navigation and Avionics; Category 8 - Marine; Category 9 - Aerospace and Propulsion.
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See Appendix 1 for further detail.
Does the research topic or project or otherwise that the applicant is proposing involve, or could it be reasonably expected to involve, any of the goods or technologies included on that List?
☐ Yes☐ NoIf YES, please provide details:
Applicable goods and technologies; and How the applicant's research topic, project or otherwise necessitates their involvement with the
relevant goods or technologies
C1.3: Will the research project involve the use of, relate to the manufacture of, or potentially increase the sanctioned country's capacity to manufacture or use of any controlled goods listed in Appendix 1?☐ Yes☐ NoIf YES, please include provide details, including an assessment of whether the project constitutes pure/basic research or applied research.
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SECTION D1: TO BE COMPLETED FOR CITIZENS OF IRAN (BY PRIMARY SUPERVISOR)D1.1: For an applicant who is a citizen of Iran, does the research project provide training in, or lead to improvements in the use, extraction, manufacture or maintenance of any of the following?
a. Any goods listed in Autonomous Sanctions (Export and Import Sanctioned Goods – Iran) Amendment Specification 2016
☐ Yes ☐ No
b. Involve or is financially supported by any of the persons or entities listed in Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Iran) List 2018?
☐ Yes ☐ No
If YES, please provide details and how are you going to mitigate the risks identified?:
D1.2: Please consider the goods and technologies included on:- The Charter of the United Nations (Sanctions—Iran) (Export Sanctioned
Goods) List Determination 2016.- The International Atomic Energy Agency Information Circular
“INFCIRC/254/Part 1” as in force; - The International Atomic Energy Agency Information Circular
“INFCIRC/254/Part 2” as in force; and- UN Security Council document S/2015/546
Does the research topic or project or otherwise that the student is undertaking involve, or could it be reasonably expected to involve, any of the goods or technologies included on that List?
☐ Yes☐ NoIf YES, please provide details:
Applicable goods and technologies; and How the applicant's research topic, project or otherwise necessitates their involvement with the
relevant goods or technologies
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SECTION D2: TO BE COMPLETED FOR CITIZENS OF SYRIA (BY PRIMARY SUPERVISOR)D2: For an applicant who is a citizen of Syria, does the research project provide training in or lead to improvements in the use, extraction, manufacture or maintenance of any of the following?
a. Gold, precious metals and/or diamonds? ☐ Yes ☐ Nob. Any goods listed in Autonomous Sanctions (Export Sanctioned Goods –
Syria) Specification 2012#?☐ Yes ☐ No
c. Any goods listed in Autonomous Sanctions (Import Sanctioned Goods – Syria) Specification 2012 and Designation 2012##?
☐ Yes ☐ No
d. Involve or is financially supported by any of the persons or entities listed in Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Syria) List 2018
☐ Yes ☐ No
e. Newly printed or unissued Syrian denominated bank notes or newly minted or unissued Syrian denominated coinage?
☐ Yes ☐ No
f. Provide technical advice or training in regard to specified crude oil, petroleum products or petrochemical products?
☐ Yes ☐ No
If YES, please provide details:
#Please note: In August 2013, this list was principally devoted to goods, equipment, technology and software related to crude oil, natural gas, petrochemicals, power plants for electricity production, the monitoring or interception of internet or telephone communications, and certain luxury goods. The document is subject to change, however and should be consulted when assessing all applications for admission to a graduate research degree. Any proposed additions to the goods listed as noted on the DFAT website should be taken into consideration.
##Please note: In August 2013, this list was principally devoted to chemicals, micro-organisms, toxins and materials processing goods and equipment. The document is subject to change, however and should be consulted when assessing all applications for admission to a graduate research degree.
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SECTION D3: TO BE COMPLETED FOR CITIZENS OF RUSSIA, CRIMEA & SEVASTOPOL (BY PRIMARY SUPERVISOR)D3: For an applicant who is a citizen of Russia, Crimea or Sevastopol, does the research project provide training in or lead to improvements in the use, extraction, manufacture or maintenance of any of the following?
a. Goods, equipment, technology and software related to crude oil, natural gas, petrochemicals or power plants for electricity production
☐ Yes ☐ No
b. Goods, equipment, technology and software related to transport, telecommunications, energy production and/or the exploitation of oil, gas and mineral reserves
☐ Yes ☐ No
c. Goods, equipment, technology and software related to deep water and/or Arctic Circle oil exploration or producing oil from resources located in shale formations by way of hydraulic fracturing
☐ Yes ☐ No
d. Any goods listed in Schedule 1 – List of Goods of Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2015?
☐ Yes ☐ No
e. Any goods listed in Schedule 2 – Sanctioned Commercial Activity of Autonomous Sanctions (Russia, Crimea and Sevastopol) Specification 2015?
☐ Yes ☐ No
If YES, please provide details:
SECTION D4: TO BE COMPLETED FOR CITIZENS OF DEMOCRATIC PEOPLE’S REPUBLIC OF KOREA (DPRK, ALSO KNOWN AS NORTH KOREA) (BY PRIMARY SUPERVISOR)D4.1: For an applicant who is a citizen of the Democratic People’s Republic of Korea (DPRK), does the research project provide training in any of the following?
a. Goods related to nuclear and/or atomic energy technology (as listed in Charter of United Nations (Sanctions – Democratic People’s Republic of Korea) (Documents) Instrument 2017), luxury goods mentioned in the Charter of the United Nations (Sanctions – Democratic People’s Republic of Korea) (Luxury Goods) Instrument 2017 or goods determined by the United Nations Security Council or the Committee to be prohibited items ?
☐ Yes ☐ No
If YES, please provide details:
D4.2: Is the applicant involved or financially supported by any of the persons or entities listed in Autonomous Sanctions (Designated Persons Entities – Democratic People’s Republic of Korea) List 2018?
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☐ Yes☐ NoIf YES, please provide details:
SECTION D5: TO BE COMPLETED FOR CITIZENS OF ALL OTHER UNITED NATIONS & AUSTRALIAN SANCTIONED COUNTRIES/REGIMES (BY PRIMARY SUPERVISOR)D5.1: If the applicant is a citizen of a ‘sanctioned-service’ country (other than those in D1 through D4), does the research project provide training in or lead to improvements in the use, extraction, manufacture or maintenance of any of the following?
a. Military or paramilitary items or items with a military or paramilitary application (including weapons, ammunition, military vehicles and equipment, paramilitary equipment or spare parts for any of these)?
☐ Yes ☐ No
b. Items with an application in nuclear, chemical or biological weapons programs or in the development of weapons delivery systems (such as missiles)?
☐ Yes ☐ No
c. Technical training, advice, services or assistance (including financing and financial assistance, investment, brokering or other services, and transfer of financial resources or services) related to ‘the supply, manufacture, maintenance of use of such items, or military activities generally’?
☐ Yes ☐ No
d. Rough diamonds? ☐ Yes ☐ Noe. Iraqi cultural property, other items of archaeological, historical, cultural,
rare scientific and religious importance illegally removed since August 1990?
☐ Yes ☐ No
If YES, please provide details:
Please note: These lists include chemical weapons, precursors, dual use chemical manufacturing facilities and equipment and related technology and software, dual use biological equipment and related technology and software, biological agents, plant agents, and animal pathogens.
While there may be some duplication with goods on the Defence and Strategic Goods List (DSGL) Quick Reference Guides in Appendix 1, both of these lists should be consulted when assessing all applications for admission to a higher degree research program.
D5.2: Is the applicant involved or financially supported by any of the persons or entities listed in; Autonomous Sanctions (Designated Persons and Entities and Declared Persons - Libya) List 2018, orAutonomous Sanctions (Designated Persons and Entities and Declared Persons – Ukraine) List 2014, orAutonomous Sanctions (Designated and Declared Persons – Former Federal Republic of Yugoslavia) List 2018, or
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Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Zimbabwe) List 2018 , or
The Consolidated List of persons and entities to which the Charter of the United Nations Act 1945 and the Autonomous Sanctions Act 2011 currently applies?☐ Yes☐ NoIf YES, please provide details:
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SANCTIONS COMPLIANCE – ASSESSMENT & APPROVALSRESPONSIBLE CANDIDATURE MANAGEMENT ADVISOR It is the responsibility of the CMA to check that all required sections of this form are completed. If this is not the case, please return the form to the Primary Supervisor to complete the missing sections.
Name of CMA: College:
Date:
PRIMARY SUPERVISOR DECLARATIONIt is the responsibility of the Primary Supervisor to ensure all supervisors are aware of this risk assessment and compliance form. By signing this form, the Primary Supervisor confirms that all supervisors have agreed to the content within this form.
I declare that:
I am aware of the Australian Autonomous or United Nations regime and the procedures and processes put in place by this University to ensure compliance with the regime; and
I am aware that applicants who are subject to sanctions will not be approved as external candidates; and
All information and assessments provided on or appended to this Form are true and correct to the best of my knowledge, information and belief; and
If the applicant is admitted, the project, project requirements and research environment will be monitored for compliance at confirmation and progress reviews; and
Any change in the status of this project, project requirements or research environment that may affect compliance with the Autonomous Sanctions regime will be reported to the Head of School, College Associate Dean of Research and the Dean of Graduate Research.
Primary Supervisor Name:
Staff ID:
School/College/Institute/External
Organisation:
Signature:
HEAD OF SCHOOL DECLARATIONIt is the responsibility of the Head of School to review the information included in this compliance assessment form and to the best of their ability, ensure that it is accurate and true.
I declare that:
I am aware of the Australian Autonomous or United Nations Sanctions Regimes and this College or Institute has mechanisms in place to ensure that the HDR admissions and candidature management procedures and processes put in place by the University to ensure compliance with the regimes are being followed; and
This compliance assessment of the proposed project has been completed in accordance with UTAS procedures by the Primary Supervisor, with the requisite methodological and theoretical expertise to provide a rigorous and meaningful risk assessment; and
If the applicant is admitted, appropriate procedures and processes are in place to monitor the project, project requirements and research environment and any changes will be reported to the ADDR and the Dean of Graduate Research in a reasonable timeframe.
HoS Name: Staff ID:
School/College/Institute/External
Organisation:
Signature:
HoS Comments:
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DELEGATED AUTHORITY ASSESSMENT (TO BE COMPLETED BY GRO/ODGR STAFF)Following a review of this compliance assessment form, and a cross-check against the relevant pieces of Autonomous Sanctions and/or United Nations legislation, the following risk rating has been determined.
RECOMMENDED RISK RATING
☐ Low-Risk Shows no discernible association or breach of Autonomous Sanctions legislation Project approved
☐ Medium-Risk
Shows a tenuous or possible association or breach of Autonomous Sanctions legislation Further information requested from Primary Supervisor and/or advice requested from DFAT
☐ High-Risk Shows a clear association and is in breach of Autonomous Sanctions legislation Project and/or application rejected
Assessment Notes:
Assessors Name: Staff ID: Divisional Area:
Signature:
DEAN OF GRADUATE RESEARCHI declare that:
I am aware of the Australian Autonomous or United Nations Sanctions Regimes and this College or Institute has mechanisms in place to ensure that the HDR admissions and candidature management procedures and processes put in place by the University to ensure compliance with the regimes are being followed, and
The above recommendation is: ☐ Accept
ed ☐ Rejected
Name: Staff ID: Signature:
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Any additional comments:
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APPENDIX 1: DEFENCE & STRATEGIC GOODS LIST QUICK REFERENCE GUIDEOn advice from DFAT, higher degree research projects involving nationals of countries on the United Nations (UN) and Australian Autonomous Sanctions (AS) lists should be assessed to determine whether they provide technical assistance or training that assists with the manufacture, maintenance or use of certain controlled goods.
There is no single list of controlled goods, however, which applies to all sanctioned countries. Rather, Australian law gives effect to a variety of export control regimes including those related to ‘arms and related materiel’ in the Charter of the United Nations Regulations and the Autonomous Sanctions Regulations. There are, in addition, country specific sanctions, regulations and controlled goods.
To assist with the special assessment of higher degree research applications, DFAT has indicated that the Defence and Strategic Goods List may be used as a proxy, in the first instance, for a comprehensive controlled goods list.
Below is a Quick Reference Guide, in two parts, which should be used to answer Section C, Question 2 of the Higher Degree Research Compliance Assessment Form. Please note that the “Part 1—Munitions List” is included here for comprehensiveness. The vast majority of controlled goods relevant to research projects carried out at the University will appear on the Part 2—Dual Use Goods List.
The full DSGL is available at https://www.legislation.gov.au/Details/F2016C00970 and should be consulted.
A permit from the Department of Defence is required to export, supply, publish or broker goods, software or technology that are on the DSGL. The Online DSGL Tool may also assist you to establish whether a permit is required: https://dsgl.defence.gov.au/Pages/Home.aspx
In addition, the Australian Autonomous Sanctions regime prohibits the provision of training to nationals of certain sanctioned countries in how to use, manufacture or maintain certain controlled goods, or how to improve the goods’ use, manufacture or maintenance. DFAT has determined that higher degree research training may pose a higher than normal risk of breaching Autonomous Sanctions regulations in these areas.
PART ONE – MUNITIONS LIST Military Goods ML1 Smooth bore weapons calibre <20mm
Other weapons calibre ≤ 12.7mm (calibre 0.50 inches) Components and accessories
ML2 Smooth bore weapons >20mm Other weapons calibre > 12.7mm (calibre 0.50 inches) Components and accessories
ML3 Ammunition and components for ML1, ML2 & ML12, Fuze settings for ML3 ML4 Bombs, torpedoes, rockets, missiles,, other explosive devices and charges, components and accessories
Equipment for launching, deploying, decoying, disruption, detection and jamming ML5 Fire control systems, components and accessories and their countermeasure equipment
Radar, surveillance, tracking systems, and their countermeasure equipment ML6 Ground vehicles and components ML7 Chemical or biological toxic agents, ‘riot control agents’, radioactive materials, related equipment,
components, and materials ML8 ‘Energetic materials’ (explosives & chemicals) and related substances ML9 Vessels of war, special naval equipment, accessories and components ML10 Aircraft, unmanned airborne vehicles, aero-engines and aircraft equipment, and related equipment and
components ML11 Electronic equipment not controlled elsewhere in the Munitions List specially designed for military useML12 High velocity kinetic energy weapon systems and related equipment ML13 Armour plate, body armour, and helmets and components ML14 Simulators and training equipment ML15 Imaging, infrared, thermal imaging and image intensifier equipment, and cameras ML16 Forgings, castings and other unfinished products specially designed for any products controlled by ML1 -
ML4, ML6, ML9, ML10, ML12 or ML19. ML17 Miscellaneous goods, including diving equipment, robots, ferries, containers specially designed or modified
for military use, goods treated for or providing signature suppression ML18 Production and test equipment ML19 Directed energy weapon systems, countermeasure and related equipment, (e.g. lasers and particle beam
systems)
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ML20 Cryogenic and superconductive equipment, as follows, and specially designed components and accessories ML21 Software for listed goods ML22 Technology for listed goods Non - Military Goods ML901 Non-military firearms including rifles, carbines, muskets, pistols, revolvers, shotguns, and smooth bore
weapons, not specified ML1 ML902 Ammunition, projectiles and specially designed for ML901 ML904 Accessories, including silencers, mountings, magazines, sights, flash suppressors, for ML901 ML905 Air guns, with specific characteristics ML908 Energetic materials other than those in ML8, excluding those specially formulated for toys, novelty goods
and fireworks ML909 Detonators or other equipment for the initiation of non-military energetic materials specified in Item ML908 ML910 Charges and devices containing “energetic material” specified in ML908 PART TWO – DUAL USE GOODS 0 Nuclear Materials; Facilities and Equipment
Nuclear reactors, gas centrifuges, and equipment and materials especially designed for nuclear use 1 Materials, Chemicals, Micro-organisms and Toxins
Toxic chemicals, viruses, bacteria, protective and detection equipment, body armour, radiation shielding windows, and metal powder production equipment
2 Materials Processing Crucibles, valves, robots, vibration test systems, vacuum pumps, chemical processing, and handling equipment
3 Electronics Microwave components, acoustic wave devices, high energy devices, switching devices, and detonators
4 Computers Radiation hardened computers, neural and optical computers, and related equipment.
5 Telecommunications and Information Security Part 1 – Telecommunications. Telecommunications systems, optical fibre cables, radio equipment, jamming equipment, and telemetry and telecontrol equipment Part 2 – Information Security (Cryptography). Cryptographic equipment, and communications cables systems
6 Sensors and Lasers Marine acoustic systems, hydrophones, imaging cameras, optical mirrors, lasers, and magnetometers
7 Navigation and Avionics Gyros, accelerometers, inertial navigation systems, and flight control systems
8 Marine Submersible vehicles, remotely controlled manipulators, underwater vision systems, noise reduction systems, and air independent power systems
9 Aerospace and Propulsion Aero gas turbine engines, rocket propulsion systems, UAVs, rocket motors, ramjet engines, sounding rockets, and acoustic vibration test equipment
Note 1 - Each of the above Dual-Use Goods categories (0-9) has the following divisions:
A. – Systems, Equipment and ComponentsB. – Test, Inspection and Production EquipmentC. – MaterialsD. – SoftwareE. – Technology
Note 2 - Materials, software and technology related to controlled goods are also controlled.
Note 3 - Terms with specific meaning are enclosed in double quotation marks where they appear throughout the DSGL document. An index of these terms appears in the front pages of the full DSGL document.
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