UK

Alco Valves

Industry
Manufacturing
Country
UK
Sources

Arsam Pishro, an Iranian company located in Tehran, lists Alco Controls products on its website and furthermore states that "Valves and Controls Alco, which is a subsidiary of Emersan products, has been able to fit our country into a good position in the air-conditioning industry with a wide range of products and brilliant backgrounds. Ventilation expansion valves and all types of jumpers are one of the most practical products of this company in Iran."

Response

“Alco Valves is a wholly owned entity, we have no affiliation with Alderley, only in the conduct of supplying our product from time to time. The inclusion of Alco Valves on these Vendor Lists is before my tenure with the Business, the position of Alco Valves Group is to not knowingly supply direct to Iran, we conduct due diligence where applicable with our Distributors, however, we cannot guarantee that our Valves will not find their way to Iran via a 3rd or 4th party.” (October 20, 2021)

Servomex Group

Industry
Engineering
Country
UK
Sources

Servomex is featured on the website of the Iranian energy services firm Sima Mehr.

Response

"Servomex has not done business in Iran, directly or indirectly, since the US withdrew from the JCPOA in 2018. With regards to Sima Mehr, Servomex have had no business transactions with them since 2018…In the circumstances, we will attempt to have Sima Mehr remove references to Servomex from their website." (6/29/2021)

Smith & Nephew PLC

Industry
Medical*
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "The Group does not have a legal entity based in Iran, but in 2019 it exported certain medical devices to Iran, via sales by non- US entities, to a privately owned Iranian distributor for sale in Iran. Sales by the distributor were made to hospitals that we understand are owned or controlled by the Government of Iran.

The Group’s direct and indirect sales of US origin medical devices into Iran are permitted pursuant to section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations, and its indirect sales of non-US origin medical devices into Iran are made in accordance with applicable law. The Group also provides training to its distributor(s) and surgeons in Iran as necessary and ordinarily incident to the safe and effective use of the medical devices, which is also permitted by applicable law.

In 2019, Smith+Nephew’s gross revenues from sales to Iran were approximately US$6.2m and net losses were approximately US$1.0m.

The Group is reporting the entire gross revenues and net losses for the activities described above, which figures include sales of US origin medical devices. Although the Group is not required to disclose the sales of US origin medical devices because such sales to Iran are licensed under US law, the Group is including sales of these devices in its total gross revenue and net profit figures as it does not separately break out revenues and profits by country of origin."  

--

According to its Annual report filed with the SEC for fiscal year 2018: "The Group does not have a legal entity based in Iran, but in 2018 it exported certain medical devices to Iran, via sales by non- US entities, to a privately owned Iranian distributor for sale in Iran. Sales by the distributor were made to hospitals that we understand are owned or controlled by the Government of Iran.

The Group’s direct and indirect sales of US origin medical devices into Iran are permitted pursuant to section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations, and its indirect sales of non-US origin medical devices into Iran are made in accordance with applicable law. The Group also provides training to its distributor(s) and surgeons in Iran as necessary and ordinarily incident to the safe and effective use of the medical devices, which is also permitted by applicable law.

In 2018, S&N’s gross revenues from sales to Iran were approximately US$3.4m and net losses were approximately US$1.1m.

The Group is reporting the entire gross revenues and net profits for the activities described above, which figures include sales of US origin medical devices. Although the Group is not required to disclose the sales of US origin medical devices because such sales to Iran are licensed under US law, the Group is including sales of these devices in its total gross revenue and net profit figures as it does not separately break out revenues and profits by country of origin."

--

According to its Annual Report filed with the SEC for fiscal year 2017: "The Group does not have a legal entity based in Iran, but in 2017 it exported certain medical devices to Iran, via sales by non-US entities, to a new privately owned Iranian distributor for sale in Iran. Prior to 2017, the Group had sold products via non-US entities to a privately owned distributor based in the UAE who sold products into Iran. In both cases, sales were to hospitals that we understand are owned or controlled by the Government of Iran.

The Group’s direct and indirect sales of US origin medical devices into Iran are permitted pursuant to section 560.530(a)(3)(i) of the Iranian Transactions and Sanctions Regulations, and its indirect sales of non-US origin medical devices into Iran are made in accordance with applicable law.  The Group also provides training to its distributor(s) and surgeons in Iran as necessary and ordinarily incident to the safe and effective use of the medical devices, which is also permitted by applicable law. In 2017, the Group’s gross revenues from sales to Iran were approximately $5.2m and net losses were approximately $4.0m, due in part to the transition to the new distributor. For prior years, approximate gross revenues and net profits of the Group from sales to Iran were: 2016: gross revenues $1.2m, net losses $0.4m; 2015: gross revenues $4.0m, net profits $0.8m; 2014: gross revenues $3.8m, net profits $1.1m; and 2013: gross revenues $3.5m, net profits $1.2m."

RELX

Industry
Media
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "During 2019,

  •  our Scientific, Technical & Medical business provided subscriptions to online products and print publications to a number of universities, hospitals and other entities, including those listed below;
  • our Risk & Business Analytics business provided online subscription services to a number of oil, petrochemical and other companies, including those listed below; and
  • our Exhibitions business provided exhibition space to companies including IRIB Media Trade.

Numerous Iranian nationals attended conferences organised by our Exhibitions and Risk & Business Analytics businesses. Individuals located in Iran also subscribed to or purchased certain of our scientific, medical and technical publications. Many of these individuals are researchers, doctors or other professionals who have obtained subscriptions or purchased publications in their individual capacity, but who may be employed by government agencies in Iran or by hospitals, universities or other entities owned or controlled by the government of Iran. In addition, we work with authors, other contributors and journal editorial board members who are located in Iran, many of whom are employed at hospitals, universities or research institutions that are owned or controlled by the government of Iran. We also sometimes receive payments from authors located in Iran who pay us to make their articles publicly available. From time to time, we may employ or engage individuals in Iran to assist with transactions in Iran.

Our aggregate revenue during the fiscal year ended December 31, 2019 attributable to these Iran-related activities was approximately £1.8 million compared to £7.1 million in 2018. We do not customarily allocate net profit on a subscription-by-subscription, individual customer or country-by-country basis. However, we estimate that our net profit during the fiscal year ended December 31, 2019 attributable to these activities was 0.02% of our net profit reported in our income statement for the fiscal year ended December 31, 2019 compared to 0.09% for the fiscal year ended December 31, 2018.

Entities that transacted with our Scientific, Technical & Medical Business in 2019

Ahvaz Jondishapour University of Medical Sciences, Aja University of Medical Sciences, Alborz University of Medical Sciences, Amirkabir University of Technology, Arak University of Medical Sciences, Ardabil University of Medical Sciences, Babol University of Medical Science, Birjand University of Medical Sciences, Bojnourd University, Boushehr University of Medical Sciences, Bu Ali Sina University, Fasa University of Medical Science, Ferdowsi University of Mashhad, Golestan University of Medical Sciences and Health Services, Gonabad University of Medical Sciences, Guilan University of Medical Sciences, Hamedan University of Medical Science, Health Electronic Library, Higher Education Center of Eghlid, Hormozgan University of Medical Sciences, Ilam University of Medical Sciences, Imam Hossein Hospital, Imam Khomeini Hospital, Imam Reza University, Iran University of Medical Sciences, Iran University of Science and Technology, Iranian Research Institute for Information Science and Technology, Isfahan University of Medical Sciences, Islamic Azad University, Islamic World Science Citation Center, Jahrom University of Medical Science, Jiroft University of Medical Sciences, Kashan University of Medical Sciences, Kerman University of Medical Sciences, Kermanshah University of Medical Sciences, Kharazmi University, KN Toosi University of Technology, Kurdistan University of Medical Sciences, Lorestan University of Medical Sciences, Maragheh University of Medical Sciences, Mashhad University of Medical Sciences, Mazandaran University of Medical Sciences, Medical University of Dezful, National Institute for Genetic Engineering and Biotechnology, North Khorasan University of Medical Sciences, Orumieh University, Persian Gulf University, Qazvin University of Medical Sciences, Qom University of Medical Sciences and Health Services, Rafsanjan University of Medical Sciences, Sabzevar University of Medical Sciences, School of Medicine & Affiliated Hospitals, School of Public Health, Semnan University, Semnan University of Medical Sciences and Health Services, Shahed University Faculty of Medical Sciences, Shaheed Beheshti University of Medical Sciences, Shahid Bahonar University of Kerman, Shahid Beheshti University, Shahid Chamran University, Shahid Rajaee Teacher Training University, Shahid Sadoughi University of Medical Sciences and Health Services, Shahrekord University, Shahrekord University of Medical Science, Shahroud University of Medical Sciences, Shariati Hospital, Shiraz University, Shiraz University of Medical Sciences, Tabriz University of Medical Sciences, Tarbiat Modares University, Tehran University of Medical Sciences, University of Isfahan, University of Kashan, University of Sistan and Baluchestan, University of Social Welfare and Rehabilitation Science, University of Tabriz, University of Tehran, Urmia University of Medical Sciences, Yasooj University of Medical Sciences Kohkiloyeh, Zabol University of Medical Sciences, Zahedan University of Medical Sciences, Zanjan University of Medical Sciences

Entities that transacted with our Risk & Business Analytics Business in 2019

Abadan Petrochemical Company, Bakhtar Commercial Company, Bakhtar Petrochemical Company, Esfahan Petrochemical Company, Excell Worldwide DMCC, Fanavaran Petrochemical Company, Ghaed Bassir Petrochemical Company, Iran Chemical Industries Investment Company, Laleh Petrochemical Company, Marun Petrochemical Company, Morvarid Petrochemical Company, National Petrochemical Company, Petro Paak Mashreq Zamin Company, Petrochemical Commercial Company, Polynar Corporation, Shazand Petrochemical Company, Tabriz Petrochemical Company, TOPCO, Yas Banafsh Tehran Trading Company, Zagros Petrochemical Company"

--

According to its Annual Report filed with the SEC for fiscal year 2018: "During 2018,

  • our Scientific, Technical & Medical business sold subscriptions to online products and print publications to a number of universities, hospitals and other entities, including those listed below;      
  • our Risk & Business Analytics business sold online subscription services to a number of oil, petrochemical and other companies, including those listed below; and   
  • our Exhibitions business provided exhibition space to companies including IRIB Media Trade and Faratech Company.

Numerous Iranian nationals attended conferences organised by our Exhibitions and Risk & Business Analytics businesses. Individuals located in Iran also subscribed to or purchased certain of our scientific, medical and technical."

--

According to its Annual Report filed with the SEC for fiscal year 2016: "During 2016,

  • our Scientific, Technical & Medical business sold subscriptions to online products and print publications to Ferdowsi University of Mashhad, the Institute for Studies in Theoretical Physics and Mathematics, the Iran Ministry of Health, the Iran Polymer & Petrochemical Institute, the Iranian Society of Ophthalmology, the Iran Ministry of Science Research and Technology, Islamic Azad University, Mashhad University of Medical Sciences, the National Research Institute of Tuberculosis and Lung Disease, the University of Bojnord, the University of Isfahan, the University of Tehran and the University of Zabol;      
  • our Risk & Business Analytics business sold online subscription services to National Petrochemical Company, Amir Kabir Petrochemical Company, Bakhtar Commercial Company, Bandar Imam Petrochemical Company, Behran Oil Company, Esfahan Petrochemical Company, Fanavaran Petrochemical Company, Farabi Petrochemical Company, Ghadeer Petrochemical Company, Ghaed Bassir Petrochemical Company, Jam Petrochemical Company, Jam Polypropylene Company, Kharg Petrochemical Company, Khorosan Petrochemical Company, Kimyagran Emrooz Chemical Industries, Pars Oil Company, Polynar Corporation, Sepahan Oil Company, Shazand Petrochemical Company and Mahan Air; and
  • our Exhibitions business provided exhibition space to IRIB Media Trade, AITO Iran, Hamiyan Co. Cooperation Company and the Cultural Centre of the Embassy of the Islamic Republic of Iran.

Numerous Iranian nationals attended conferences organised by our exhibitions business. Individuals located in Iran also subscribed to or purchased certain of our scientific, medical and technical publications. Many of these individuals are researchers, doctors or other professionals who have obtained subscriptions or purchased publications in their individual capacity, but who may be employed by government agencies in Iran or by hospitals, universities or other entities owned or controlled by the government of Iran. In addition, we work with authors, other contributors and journal editorial board members who are located in Iran, many of whom are employed at hospitals, universities or research institutions that are owned or controlled by the government of Iran. We also sometimes receive payments from authors located in Iran who pay us to make their articles publicly available. From time to time, we may employ or engage individuals in Iran to assist with transactions in Iran.

During 2016, our aggregate revenue from all of our Iran-related activities was approximately £8.2 million. We do not normally allocate net profit on a subscription-by-subscription, individual customer or country-by-country basis. However, we estimate that our net profit from these activities, after internal cost allocations, amounted to 0.12% of our net profit reported in our income statement for the year ended December 31, 2016."

--

According to its Annual Report filed with the SEC for fiscal year 2015: "During 2015,   

  • our Scientific, Technical & Medical business sold subscriptions to online products and print publications to the Institute for Studies in Theoretical Physics and Mathematics, the Iran Ministry of Health, the Iranian Society of Ophthalmology, the Iran Ministry of Science Research and Technology, Islamic Azad University, Sharif University of Technology, the University of Sistan and Baluchestan, and the University of Tehran; and hosted pre-existing informational content from Masih Daneshvari Hospital on an online platform;
  • our Risk & Business Analytics business sold online subscription services to National Petrochemical Company, Abadan Petrochemical Company, Bandar Imam Petrochemical Company, Esfahan Petrochemical Company, Ghaed Bassir Petrochemical Company, Jam Petrochemical Company, Kharg Petrochemical Company, Khorosan Petrochemical Company, Kimyagran Emrooz Chemical Industries, Polynar Corporation, Saman Bank Brokerage Company, Sepahan Oil Company, Shazand Petrochemical Company and Tabriz Petrochemical Company;
  • our Exhibitions business provided exhibition space to IRIB Media Trade, AITO Iran, Mahan Air and the Cultural Centre of the Embassy of the Islamic Republic of Iran; and     
  • our Legal business sold print publications to Bank Melli PLC.

Numerous Iranian nationals attended conferences organised by our exhibitions business. Individuals located in Iran also subscribed to or purchased certain of our scientific, medical and technical publications. Many of these individuals are researchers, doctors or other professionals who have obtained subscriptions or purchased publications in their individual capacity, but who may be employed by government agencies in Iran or by hospitals, universities or other entities owned or controlled by the government of Iran. In addition, we work with authors, other contributors and journal editorial board members who are located in Iran, many of whom are employed at hospitals, universities or research institutions that are owned or controlled by the government of Iran. We also sometimes receive payments from authors located in Iran who pay us to make their articles publicly available. From time to time, we may employ or engage individuals in Iran to assist with transactions in Iran."

--

According to its Annual Report filed with the SEC for fiscal year 2014: "

During 2014,

  • our Scientific, Technical & Medical publications business sold subscriptions to online products and print publications to the Iran Ministry of Health, the Iran Ministry of Science Research and Technology and Islamic Azad University; and hosted pre-existing informational content from Masih Daneshvari Hospital on an online platform;
  • our Business Information business sold online subscription services to National Petrochemical Company, Abadan Petrochemical Company, Arya Sasol Polymer Company, Bandar Imam Petrochemical Company, Khorosan Petrochemical Company, Kimyagran Emrooz Chemical Industries, Petrochemical Commercial Company FZE, Polynar Corporation, Sepahan Oil Company and Tabriz Petrochemical Company; and 
  • our Exhibitions business provided exhibition space to IRIB Media Trade, AITO Iran, Shahid Beheshti Medical University and the Cultural Centre of the Embassy of the Islamic Republic of Iran.

Numerous Iranian nationals attended conferences organised by our exhibitions business. Individuals located in Iran also subscribed to or purchased certain of our scientific, medical and technical publications. Many of these individuals are researchers, doctors or other professionals who have obtained subscriptions or purchased publications in their individual capacity, but who may be employed by government agencies in Iran or by hospitals, universities or other entities owned or controlled by the government of Iran. In addition, we work with authors, other contributors and journal editorial board members who are located in Iran, many of whom are employed at hospitals, universities or research institutions that are owned or controlled by the government of Iran. We also sometimes receive payments from authors located in Iran who pay us to make their articles publicly available."

--

According to its Annual Report filed with the SEC for fiscal year 2013: "During 2013, Tarbiat Modares University, Urmia University, Masih Daneshvari Hospital, Kharazmi University, Ferdowsi University of Mashad, the Iran Ministry of Science, Research and Technology, the Iran Ministry of Health and Tehran University of Medical Sciences purchased subscription access to our ScienceDirect online platform, and in some cases, also purchased print subscriptions or other publications from our scientific, medical & technical publications business. Petrochemical Commercial Company, National Petrochemical Company, Jam Petrochemical Company, Sepahan Oil Company, Zagros Petrochemical Company, Shazand Petrochemical Co., Bandar Imam Petrochemical Company, Tabriz Petrochemical Company, Arya Sasol Polymer Company, Polynar Corporation, Behran Oil Co., Ghaed Bassir Petrochemical Co., Fanavaran Petrochemical Co. and Farabi Petrochemical Company subscribed to our ICIS price reports relating to the global petrochemical, energy and fertilizer markets. Iran Air subscribed to our Flight Global aviation news and information service. Our exhibitions business provided exhibition space to the Cultural Centre of the Embassy of the Islamic Republic of Iran located in Japan.

During 2013, our aggregate revenue from the foregoing activities was approximately £4.45 million. We do not normally allocate net profit on a subscription-by-subscription, individual customer or country-by-country basis. However, we estimate that our net profit from these activities, after internal cost allocations, amounted to less than 0.075% of our net profit reported in our combined income statement for the year ended December 31, 2013.

Numerous individuals located in Iran subscribed to or purchased certain of our scientific, medical & technical publications. Many of these individuals are researchers, doctors or other professionals who have obtained subscriptions or purchased publications in their individual capacity, but who may be employed by government agencies in Iran or by hospitals, universities or other entities owned or controlled by the government of Iran. We work with authors, other contributors and journal editorial board members who are located in Iran, many of whom are employed at hospitals, universities or research institutions that are owned or controlled by the government of Iran. During 2013, we did not pay any fees or receive any revenues in connection with this activity. During 2013, numerous attendees at conferences organized by our exhibitions business were Iran nationals.

We believe these transactions and dealings were lawful under applicable laws and regulations, and anticipate that similar transactions or dealings may occur in the future."

--

According to its Annual Report filed with the SEC for fiscal year 2012: "Section 219 of the Iran Threat Reduction and Syrian Human Rights Act of 2012 (the “ITRA”), which added Section 13(r) to the Securities Exchange Act of 1934, as amended (the “Exchange Act”), requires disclosures regarding certain activities relating to Iran or with persons designated pursuant to various U.S. Presidential Executive Orders. These disclosures are required even where the activities, transactions or dealings were conducted in compliance with applicable law. During 2012, Sepahan Oil Company, Zagros Petrochemical Company and Petroleum Marketing Department (Sytrol) subscribed to our ICIS price reports relating to the global petrochemical, energy and fertilizer markets. Our gross revenues invoiced in 2012 from these subscriptions were approximately £33,000 (thirty-three thousand pounds sterling). We do not normally allocate net profit on a country-by-country or publication-by-publication basis. However, we estimate that our net profit from such sales, after internal cost allocation, amounted to less than 0.004% of our net profit reported in our combined income statement for the year ended December 31, 2012. In addition, during 2012 we processed subscription refunds relating to ICIS and BankersAlmanac products of approximately £41,000 (forty-one thousand pounds sterling) to Pars Oil Company, Parsian Bank, Real Estate Bank and Syria International Islamic Bank. We believe these transactions and dealings were lawful under applicable laws and regulations, and anticipate that similar transactions or dealings may occur in the future."

Prudential PLC

Industry
Insurance
Symbol
NYSE: PUK
Country
UK
Sources

According to its Annual Report filed with the SEC for fiscal year 2019: "Prior to the demerger, in the UK, The Prudential Assurance Company Limited operates a pension scheme for employees of the UK branch of government-owned Iranian bank. All members are inactive, in that no member contributions are being made. The scheme is closed to new members. The UK sanctions authority, the Office of Financial Sanctions Implementation (OFSI), was previously informed of this arrangement and in 2008 advised Prudential that following an analysis of the deeds, the fund is not owned, held or controlled by the Iranian bank. Previous payments out of the fund were approved by OFSI through a licence. This scheme is no longer with the Prudential Group, following demerger of M&G plc."

--

According to its Annual Report filed with the SEC for fiscal year 2016: "In the UK, The Prudential Assurance Company Limited operates a pension scheme for employees of the UK branch of government-owned Iranian bank. A total of 67 scheme members are receiving benefits, with 34 deferred members. All members are inactive in that no member contributions are being made."

--

According to its Annual Report filed with the SEC for fiscal year 2013: "In the UK, the Prudential Assurance Company Ltd operates a pension scheme for employees of the UK branch of government-owned Iranian bank. A total of 61 scheme members are receiving benefits, with 21 deferred members. All members are inactive in that no member contributions are being made or were made in 2013 although two payments in were received in September (approved by HM Treasury); £15k from the trustees into a cash fund and £1.9m from the bank into the pension to make good a funding deficit. The scheme is closed to new members. Due to the long term nature of a pension scheme it is not practical to advise the net profit, but the fund value at 31 December 2013 stood at £7,458,011.00. In return for administering the scheme there are standard Prudential scheme charges: an annual fee of £707, plus £11 per member, £57 per quote and a Trustee Accounts charge (£1,847.85). The annual invoice paid on 2 October 2013 was for £3,446.85. In addition to this an Annual Management Charge of 1.25 per cent is reflected in the fund value. The UK governmental sanctions authority, HM Treasury, has been informed of this arrangement and in 2008 advised us that following an analysis of the deeds, the fund is not owned, held or controlled by the bank. Payments out of the fund have been approved by HM Treasury through a license. There are no plans to discontinue with this contract in light of this license."

--

According to its Annual Report filed with the SEC for fiscal year 2012: "In the UK, the Prudential Assurance Company Ltd operates a pension scheme for employees of the UK branch of government-owned Iranian bank. A total of 58 scheme members are receiving benefits, with 49 deferred members. All members are inactive in that no member or scheme contributions are being made or were made in 2012. The scheme is closed to new members. Due to the long term nature of a pension scheme it is not practical to advise the net profit, but the fund value at 31 December 2012 stood at £5,510,527.00. In return for administering the scheme there are standard Prudential scheme charges: an annual fee of £692, plus £11 per member, £56 per quote and a Trustee Accounts charge (£1,849.50 currently), all subject to 20 per cent Value Added Tax and an annual review. The annual invoice submitted for the annual period to 31 July 2012 was for £4,675.80 (including VAT). In addition to this an Annual Management Charge of 1.25 per cent is reflected in the fund value. The UK governmental sanctions authority, HM Treasury, has been informed of this arrangement and in 2008 advised us that following an analysis of the deeds, the fund is not owned, held or controlled by the bank. Payments out of the fund have been approved by HM Treasury through a licence. There are no plans to discontinue with this contract in light of this licence."