Becton, Dickinson & Company

Medical*
NYSE: BDX
USA
BD

[email protected]

In 2018, the U.S. state of Michigan listed Becton, Dickinson & Company on its state lists of Companies Doing Business with Iran, rendering Becton, Dickinson & Company ineligible for investment and/or state contracting.

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"In 2013 and 2014 Michigan divested $45 million from Becton Dickinson and Co., a U.S. medical supplies company that sells to Iran legally under federal regulations.

A Becton Dickinson spokesman said the firm was unaware it was a target of divestment by Michigan until contacted by Reuters. It said in a statement that its trade with Iran is authorized by the U.S. Treasury Department’s Office of Foreign Assets Control, which oversees federal sanctions." (Reuters, 4/13/2015). 

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According to correspondence filed with the SEC in 2010: "The Company’s sales into Iran during fiscal years 2009 and 2010 were $2,932,134 and $4,415,097, respectively, and we estimate fiscal year 2011 sales to be $3,140,758. The Company sold medical products pursuant to U.S. government licenses to Iranian pharmaceutical companies and through independent, third-party distributors that distribute the medical supplies and devices to end-users in Iran. The medical products sold into Iran are eligible for re-export to Iran under the Trade Sanctions Reform and Export Enhancement Act of 2000 (“TSRA”) “Ag/Med” program.

To the Company’s knowledge, the sales into Iran, Sudan and Syria were made in compliance with BD’s Global Trade Management System and complied with applicable laws and regulations.
The Company anticipates continued sales into the Middle East, including into Iran, Sudan, and Syria, and the Company will seek and obtain any required U.S. and other government licenses or authorizations to conduct such activities in full compliance with applicable laws. The Company reviews its export activities on a regular basis to ensure compliance with applicable economic sanctions and export control laws and mandates trade compliance training for all associates involved in the export, re-export or transfer of products, materials or technology originating from any BD location and shipped or transferred to any customer, vendor or distributor worldwide."

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Over the last three presidential administrations, the United States government has granted Becton, Dickinson & Company 49 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

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"This medical device company and its French subsidiary were licensed to export goods, the precise nature of which OFAC redacted, to Iran." (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)