UANI

The Danfoss Group is a private, family-owned global company that manufactures products and solutions for Refrigeration and Air Conditioning, Heating, Water, and Motion Controls.

According to its website, “Danfoss is one of the largest industrial companies in Denmark. The global group is a leader within research, development and production, sales and service of mechanical and electronic components for several industries. Danfoss has a large ownership share in one of the world’s leading manufacturers and suppliers of mobile hydraulics, Sauer-Danfoss. Danfoss seeks to obtain its goals with a minimal consumption of raw materials and energy, the least possible impact on its surroundings and the most efficient use of resources. Danfoss has a long tradition for a social responsibility towards both employees and the surrounding environment” (Company website).

Danfoss produces “about 250,000 items per day at 93 factories in 25 countries,” and encompasses “140 sales companies and more than 450 agents and distributors all over the world” (Company website).

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Danfoss lists twelve contacts for Iran on its sales and services page, eleven of which are distributors with offices in Tehran. (Company Contact page).

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Techno Service Commercial Co., one of the companies listed in Danfoss’s website, describes itself as “the agent of Danfoss for Plate Heat Exchangers in Iran.” The Danfoss logo and products appear throughout the website. (Iranian Distributor website)

According to its website, "Emerson (NYSE: EMR) is a diversified global manufacturing and technology company. We offer a wide range of products and services in the areas of process management, climate technologies, network power, storage solutions, professional tools, appliance solutions, motor technologies, and industrial automation. Recognized widely for our engineering capabilities and management excellence, Emerson has approximately 129,000 employees and 250 manufacturing locations worldwide" (Company website).

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The Iranian company Techno Service Commercial Co. features the logos of Emerson Climate Technologies, as well as Alco Controls and Copeland Scroll (both brands of Emerson), on its webpage. (Iranian distributor website)

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"The Emerson Climate Technologies logo is a trademark and service mark of Emerson Electric Co. Emerson Climate Technologies Inc. is a subsidiary of Emerson."

"Emerson Climate Technologies is the leading compressor manufacturer in Europe for residential and commercial applications" (Emerson Climate Technologies Company Profile).

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Emerson Climate Technologies lists a contact for Iran on its website. (Emerson Subsidiary website)
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Emerson Industrial Automation, another subsidiary of Emerson Electric, provides contact information for Iran on its website. (Emerson Subsidiary website)

Hitachi's subsidiary, Hitachi Construction Machinery Middle East, published an article about its dealers on its website, in which it discusses Iran-based Touranto Co P.J.S, a “privately owned company (that) supplies earth moving/material handling machinery and accessories to America, Asia and Europe from leading manufacturers such as Bobcat, Terex, Indeco, Montabert, and of course Hitachi” (Hitachi Company Website).

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Hitachi global's website lists Parkish Co. in Tehran as a service center (Hitachi Global Website).

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In a 2007 Correspondence with the SEC, Hitachi said the following:

"We have de minimis contacts in each of the five countries, Iran, the Sudan, Syria, North Korea and Cuba, designated as state sponsors of terrorism by the U.S. State Department. Total revenues received from all of the five countries combined were approximately ¥10 billion ($84 million), ¥8 billion ($67 million) and ¥4 billion ($37 million) for the years ended March 31, 2006, 2005 and 2004, respectively, which constitute approximately 0.1%, 0.09% and 0.05% of our consolidated revenues of respective fiscal year. We do not believe that the operations, either individually or in the aggregate, constitute a material investment risk to our security holders.

Revenues to these countries primarily comprise maintenance of thermal power plants, sales of turbo compressors for oil refining plants, induction motors for industrial plants, construction machinery, flat panel TVs and DVD cameras. In the year ended March 31, 2004, we recorded revenues amounted approximately ¥0.2 billion ($1.4 million) from sales in North Korea, which represent sales by Hitachi, Ltd. of nuclear power equipment through the Korean Peninsula Energy Development Organization, a multi-lateral organization established by the U.S., South Korea and Japan, following the agreement between the U.S. and North Korea aiming to freeze and ultimately dismantle North Korea’s nuclear program.

We have no assets or liabilities in any of these countries. Revenues during these periods were derived from sales to unaffiliated third parties by Hitachi, Ltd. and certain of our subsidiaries. The sales into these countries were immaterial to each of these entities.

We anticipate that our sales into the aforementioned countries will not change significantly in the near future, unless there is a dramatic change in the political and security climate in these countries. Due to the immaterial amount of sales into these countries both individually and in the aggregate, we do not believe that these operations constitute a material investment risk to our security holders."

(SEC Correspondence with Hitachi, 3/30/2007)

Gigabyte is a Taiwanese computer hardware manufacturer, specializing in motherboards. “Our reputation as a pioneer in motherboard innovation has allowed us to diversify our product range to include graphics cards, notebooks, desktop PCs, PC components, cellular phones, server and datacenter solutions, and more” (Company website).

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Avajang, an Iranian IT distributor, features the Gigabyte logo on its homepage, and lists several news articles on Gigabyte motherboards throughout the page. (Avajang website)

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Gigabyte lists Avajang as one of its Middle East distributors. (Company website)

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ITP.net describes Gigabyte market activities in Iran and the Middle East: “Golden Systems acts as Gigabyte’s sole distributor for the UAE and Iran, while the vendor has multiple partnerships for other Middle East markets. Gigabyte enjoys high market share in Iran and is looking to replicate that success in both Saudi Arabia and Egypt” (ITP.net, "Gigabyte plans regional base", 10/19/04).

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Gigabyte has its own page through Iran ICT news, featuring news on its products and Gigabyte’s place in the Iranian market. (Gigabyte Iran ICT News website)

According to its website, “NVIDIA awakened the world to the power of computer graphics when it invented the GPU in 1999. Since then, it has consistently set new standards in visual computing with breathtaking, interactive graphics available on devices ranging from tablets and portable media players to notebooks and workstations. NVIDIA's expertise in programmable GPUs has led to breakthroughs in parallel processing which make supercomputing inexpensive and widely accessible. The company holds more than 1,100 U.S. patents, including ones covering designs and insights which are fundamental to modern computing” (Company website)

“…NVIDIA was founded in 1993, by Jen-Hsun Huang, who had previously served at LSI Logic and AMD, and Chris Malachowsky and Curtis Priem, whocame from Sun Microsystems…It has some 5,700 employees in more than 20 countries.” (Company Website)

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Avajang ICT Group, an IT and semiconductor distributor in Tehran, features Nvidia in its list of products and in product news on its homepage. (Avajang Company website)

Avajang claims to be "one of the most prolific group of IT companies in the country...the distributor of personal computer components such as motherboards, graphic cards, memory, CPU’s and accessories in Tehran and other major cities. Avajang company is a respected member of the “IT Counsel” of Iran. They have over 250 direct channels throughout their covered region" (Avajang Company website).

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Nvidia is featured in several news articles on Shahrsakhtafzar.com ("City Hardware"), an Iranian hardware website. Nvidia is also discussed in the product reviews page that focuses on Iranian markets. (Iranian Hardware website)

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A graphic board product powered by NVIDIA® GeForce 8800GTS Graphics Processing Unit is listed on the mainpage of Tehran computer component distributor, Darya Computer. (Iranian distributor website)

Environmental Systems & Services (ES&S) is an "advanced technology company, specialising in solutions in environmental and allied fields such as meteorology, hydrology, seismology, oceanography, air quality, and geotechnical engineering" (Company Website). It describes itself as the "largest Australian company" to specialize in these fields, and is an instrument supplier to the Australian Bureau of Meteorology as well as several other government bureaus throughout South Asia and Oceania (Company Website).

ES&S lists Iran as a country in which it has representatives, and lists three separate Iranian companies that act as distributors for its products to be sold in Iran (Company Website). 

ES&S describes itself as possessing "extensive representation arrangements with manufacturers from USA" and maintains a San Diego office (Company Website). 

In 2009, Intel was issued a "show cause notice" by the United States Securities and Exchange Commission (SEC) for trading with countries such as Iran, Syria, Cuba and Sudan.  The SEC's letter was marked confidential, and asked the company to provide "any and all business transaction records for the business conducted with the banned countries." 

The letter states: “We are aware of a May 2008   news report that PCs in Cuba contain your Celeron Processors.   Cuba, Iran, Sudan, and Syria are identified by the State Department as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. We note that your Form 10-K does not include disclosure regarding contacts with Cuba, Iran, Sudan, and Syria. Please describe to us the nature and extent of any past, current, and anticipated contacts with the referenced countries, whether through distributors, resellers, licensees, or other direct or indirect arrangements.”

Wincor Nixdorf, according to its website, is one of the world’s leading providers of IT solutions and services to retailers and retail banks.  Their IT solutions "help boost process efficiency in banking and retail industries High levels of availability and quality Solutions for cost-efficient operation of IT systems Banking."

The company has subsidiaries in over 41 countries and has an overall market presence in over 100 countries. (Company Website)

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Wincor Nixdorf is listed on the website of Iranian company Informatics Services Corporation (ICS) as a business partner (ICS Company Website).  Likewise, WN lists ICS as one of its banking partners on its own website.  (Company Website) 

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The company's policy on "Social Corporate Responsibiliy" is as follows:

“Success …depends on…achieving a balance between economic, environmental and social objectives – one that is indispensable if we wish to enjoy the confidence of the public over the long term.”  The policy also cites three key values: Caring for the environment, Focus on people, and Social responsibility.  (Company Website)

"IBM Italia Servizi Finanziari S.p.A., a 100 percent owned subsidiary of IBM Italy, currently has an equipment financing lease with an Italian company called Irasco.  IBM’s original inspection of Irasco indicated it to be an Italian subsidiary of Ascotec Gmbh, a German company holding 51 percent of Irasco’s equity.  Upon further inspection of Ascotec (the German company), it was discovered to be wholly owned by Iranian Mines and Mining Industries Development and Renovation Organization (IMIDRO)." (CORRESP for INTERNATIONAL BUSINESS MACHINES CORP, 4/16/2009)

"IBM does not believe that the financing agreement between IBM Italy and Irasco constitutes a material risk to our investors, whether analyzed on a quantitative or qualitative basis.  From the perspective of quantitative materiality, at inception, the financing lease provided for total revenue to IBM of $106,652." (CORRESP for INTERNATIONAL BUSINESS MACHINES CORP, 6/8/2009)

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IRASCO's main clients are in Iran, including the National Iranian Oil Company (controlled by the IRGC) (IRASCO client list)

Iranian suppliers of Mettler-Toledo products, according to the company website. (Company Website)