Mining

Polymet Mining Corp

Industry
Mining
Country
Canada
Sources

According to its 2019 Annual Report filed with the SEC: "During January 1, 2019 until December 31, 2019, a non-U.S. affiliate of the largest shareholder of the Company (“the non-U.S. Shareholder Affiliate”) entered into sales contracts for agricultural products with, or for delivery to or from Iranian entities wholly or majority owned by the GOI.  The non-U.S. Shareholder Affiliate performed its obligations under the contracts in compliance with applicable sanctions laws and, where required, with the necessary prior approvals by the relevant governmental authorities. The non-U.S. Stockholder Affiliates expect to continue to engage in similar activities in the future in compliance with applicable economic sanctions and in conformity with U.S. secondary sanctions."

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According to its Annual Report filed with the SEC for fiscal year 2018: "During January 1, 2018 until December 31, 2018, a non-U.S. affiliate of the largest shareholder of the Company (“the non-U.S. Shareholder Affiliate”) entered into sales and purchase contracts for agricultural products, metals, minerals and energy products with, or for delivery to or from Iranian entities wholly or majority owned by the GOI.  The non-U.S. Shareholder Affiliate performed its obligations under the contracts in compliance with applicable sanctions laws and, where required, with the necessary prior approvals by the relevant governmental authorities.
  
The gross revenue of the non-U.S Shareholder Affiliate related to these contracts did not exceed the value of USD $1.049 billion for the twelve months ended December 31, 2018.

The non-U.S. Shareholder Affiliate does not allocate net profit on a country-by-country or activity-by-activity basis, but estimates that the net profit attributable to the contracts would not exceed a small fraction of the gross revenue from such contracts. It is not possible to determine accurately the precise net profit attributable to such contracts.

The contracts disclosed above do not violate applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement action under Iran sanction laws.

In response to the re-imposition of certain US secondary sanctions, the non-U.S. Shareholder Affiliate wound down such activities to the extent necessary to avoid any sanctionable activity after such sanctions took effect."

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According to its Annual Report filed with the SEC for fiscal year 2015: "Because the SEC defines the term “affiliate” broadly, our largest shareholder may be considered an affiliate of the Company despite the fact that the Company has no control over our largest shareholder’s actions or the actions of its affiliates. As such, pursuant to Section 13(r)(1)(D)(iii) of the Exchange Act, the Company hereby discloses the following information provided by our largest shareholder regarding transactions or dealings with entities controlled by the Government of Iran (the “GOI”):

During the period from February 1, 2014 until January 31, 2015, a non-U.S. affiliate of the largest shareholder of the Company (the “non-U.S. Shareholder Affiliate”) entered into sales contracts for agricultural products for delivery to Iranian entities wholly or majority owned by the GOI. The non-U.S. Shareholder Affiliate performed its obligations under the contracts in compliance with applicable sanction laws and, where required, with the necessary prior approvals by the relevant governmental authorities.

The gross revenue of the non-U.S Shareholder Affiliate related to these contracts did not exceed the value of $119 million for the twelve months ended January 31, 2015. The non-U.S. Shareholder Affiliate does not allocate net profit on a country-by-country or activity-by-activity basis, but estimates that the net profit attributable to the contracts would not exceed a small fraction of the gross revenue from such contracts. It is not possible to determine accurately the precise net profit attributable to such contracts.

The contracts disclosed above do not violate applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement action under Iran sanction laws.

In compliance with applicable economic sanctions and in conformity with U.S. secondary sanctions, the non-U.S. Shareholder Affiliate expects to continue to engage in similar activities in the future.

Neither the Company nor any of its subsidiaries (i) engaged in any transactions or activities requiring disclosure under ITRA nor (ii) were involved in the transactions described in this section. As of the date of this report, the Company is not aware of any other activity, transaction or dealing by us or any of its affiliates during the fiscal year ended January 31, 2015 that requires disclosure in this report under Section 13(r) of the Exchange Act."

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According to its Annual Report filed with the SEC for fiscal year 2014: "Because the SEC defines the term “affiliate” broadly, our largest shareholder may be considered an affiliate of the Company despite the fact that the Company has no control over our largest shareholder’s actions or the actions of its affiliates. As such, pursuant to Section 13(r)(1)(D)(iii) of the Exchange Act, the Company hereby discloses the following information provided by our largest shareholder regarding transactions or dealings with entities controlled by the Government of Iran (“GOI”):

During the period from February 1, 2013 until January 31, 2014, non-U.S. affiliates of the largest shareholder of the Company (“non-U.S. Shareholder Affiliates”) entered into sales contracts for agricultural products as well as sale and purchase contracts for metal oxides and metals with Iranian entities, wholly or majority owned by the GOI. All contracts were conducted in compliance with applicable sanction laws and, where required, with the necessary prior approvals by the relevant governmental authorities.

The gross revenue of the non-U.S Shareholder Affiliates related to these contracts did not exceed the value of $206 million for the twelve months ended January 31, 2014. This figure includes the gross revenue of goods sold in the period but purchased in previous periods. The non-U.S. Shareholder Affiliates do not allocate net profit on a country-by-country or activity-by-activity basis, but estimate the net profit attributable to the contracts with the GOI would not exceed a small fraction of the gross revenue from such contracts. It is not possible to determine accurately the precise net profit attributable to these contracts.

These contracts disclosed above do not violate applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement action under Iran sanction laws.

In compliance with applicable economic sanctions and in conformity with U.S. secondary sanctions, the non-U.S. Shareholder Affiliates expect to continue to engage in similar activities in the future relating to agricultural products.

Neither the Company nor any of its subsidiaries (i) engaged in any transactions or activities requiring disclosure under ITRA nor (ii) were involved in the transactions described in this section. As of the date of this report, the Company is not aware of any other activity, transaction or dealing by us or any of its affiliates during the fiscal year ended January 31, 2014 that requires disclosure in this report under Section 13(r) of the Exchange Act."

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According to its Annual Report filed with the SEC for fiscal year 2013: "Because the SEC defines the term “affiliate” broadly, our largest shareholder may be considered an affiliate of the Company despite the fact that the Company has no control over its actions or the actions of its affiliates. As such, pursuant to Section 13(r)(1)(D)(iii) of the Exchange Act, the Company hereby discloses the following information provided by our largest shareholder regarding transactions or dealings with entities controlled by the Government of Iran (“GOI”):

"During the year ended January 31, 2013, non-U.S. affiliates of the largest shareholder of the Company ("Shareholder Affiliates") entered into sales contracts for wheat and coal as well as sale and purchase contracts for metal oxides and metals with Iranian entities, which are either fully or majority owned by the GOI. The GOI is in the process of privatizing some of these entities. All transactions were conducted in compliance with applicable sanction laws and, where required, with the necessary prior approvals by the relevant governmental authorities.

The gross revenue of the non-U.S Shareholder Affiliates related to these transactions did not exceed the value of $645 million for the twelve months ended January 31, 2013. This figure includes the gross revenue of goods sold in the period but purchased in previous periods. The non-U.S. Shareholder Affiliates do not allocate net profit on a country-by-country or activity-by-activity basis, but estimate that the net profit attributable to the transactions with the GOI would not exceed a small fraction of the gross revenue from such transactions. It is not possible to determine accurately the precise net profit attributable to these transactions.

The non-U.S. Shareholder Affiliates believe that these transactions disclosed above do not constitute violations of applicable sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control, and are not the subject of any enforcement actions under Iran sanction laws.

In accordance with applicable U.S. and foreign sanctions laws, the non-U.S. Shareholder Affiliates expect to continue to engage in similar activities in the future."

Neither the Company nor any of its subsidiaries (i) engaged in any transactions or activities requiring disclosure under ITRA nor (ii) were involved in the transactions described in this section. As of the date of this report, the Company is not aware of any other activity, transaction or dealing by us or any of its affiliates during the fiscal year ended January 31, 2013 that requires disclosure in this report under Section 13(r) of the Exchange Act."

Aurubis AG

Industry
Mining
Symbol
ETR: NAD
Country
Germany
Sources

“The Islamic Republic of Iran and Germany’s Aurubis AG are set to look into ways of cooperating in the area of copper industry. Mehdi Karbassian, director of Iran’s Mines and Mining Industries Development and Renovation (IMIDRO), a major state-owned holding company active in the mining sector, has announced a plan by a team of Germany’s Aurubis AG to visit Iran for economic cooperation in the near future. The official pointed to his recent trip to Germany and his visit to Aurubis HQ in Hamburg, where he said German company officials pointed to their readiness to cooperate with Iran and invest in its copper industry, Tasnim news agency reported. Karbassian said Aurubis, which is the largest copper producer in Europe and the biggest copper recycler in the world, declared its intention to send a team to Tehran in the near future when the two sides will discuss cooperation further.” (Press TV, “‘Iran’s IMIDRO, German Aurubis to tap joint potentials’,” 6/5/2016)

Austmin

Industry
Mining
Country
Australia
Sources

John Burgess, the Director of Austmin Pty Ltd is speaking at Iran's Mines and Mining Industries Summit which takes place on December 10-11, 2016 in Tehran, I.R. of Iran. (Iran's Mines and Mining Industries Summit 2016 Brochure)

ATC Williams

Industry
Mining
Country
Australia
Sources

"The delegates from IMIDRO were in the country to attend the annual International Mining and Resources Conference (IMARC) in Melbourne. ATC Williams in partnership with the French Australia chamber of commerce (FACCI) held a meet and greet during their stay. The event was attended by ATC Williams and FACCI staff members along with the delegation and other mining industry representatives. TC Williams has a long history of working on Projects in Iran and we commenced business 18 years ago with NICICO (National Iranian Copper Industry Co). ATC Williams has since provided innovative tailings management solutions to mine operations and projects that have a water shortage."

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Behrooz Ghahreman Nejad, Principal/Manager Technical and Innovation for ATC Williams, is speaking at the Iran's Mines and Mining Industries Summit which takes place on December 10-11, 2016 in Tehran, I.R. of Iran. (Iran's Mines and Mining Industries Summit 2016 Brochure)

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"We’re delighted to announce the agreement between ATC Williams and the Iranian Babak Copper Company (IBCCo) that was recently signed. IBCCo is the subsidiary of the private Middle East Mineral Industries and Mines Development Holding Company (MIDHCO) . This agreement is related to the development of a filtered tailings deposition for a new bio leach copper extraction operation located in Kerman province, Iran. ATC Williams can now build on its extensive water and tailings management experience developed over our 15 year history working within the Middle East." (Company Website, 5/31/2016)

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"The sanctions on Iran are progressively being lifted which has major positive implications for how the rest of the world can work with this country. ATC Williams has been working in Iran for over 15 years under a licence from the Australian Department of Foreign Affairs and Trade. We have been assisting the National Iranian Copper Industry (NICICO), the largest Iranian Copper Producer with design services associated with management of water and tailings for these projects using innovative methods such as down valley thickened tailings. Our presence is still active and engineers from our Melbourne office are regularly in Iran to review works that have been completed." (Company Website, 2/5/2016)

CSA Global

Industry
Mining
Country
Australia
Sources

Dr. Neal Reynolds, Director of CSA Global is speaking at the Iran Mines and Mining Industries Summit taking place on December 10-11, 2016. (Iran Mine's and Mining Industries Summit 2016 Brochure)

Jindal Saw Limited

Industry
Mining
Symbol
NSE: JINDALSAW
Country
India
Sources

JSL attended the Iranian Steel Pipe & Tube Conference (the “Conference”) held in Tehran on May 24-25, 2016. (MetalBulletin Events, “Iranian Steel Pipe & Tube Conference”). The Conference purported to offer “a unique opportunity to gain crucial insight into the Iranian market and the networking with leading Iranian companies is not to be missed.”

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JSL has maintained a constant presence in Iran since at least 2009. Between 2004 and 2011, Iran, the UAE, Qatar, Syria and “other gulf countries” comprised 15% of JSL’s total sales. (JSL website, “Milestones,”).

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Vishal Steel and Hi-Tech Metal and Tubes identify themselves as distributers of JSL stainless steel pipes in Iran. (Vishal Steel website, “Jindal Steel,”; Hi-Tech Metal and Tubes website, “Hitech Pipes & Tubes is Leading Exporters of Jindal Saw Pipes Tubes,”).

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In 2011, a company spokesman explained that “its [overseas] business is mainly spread in Iran, Iraq and Saudi Arabia.” (Reuters, “Jindal Saw to buy logistic firm to ramp up scale,” 3/22/2011). 

KGHM Polska Miedź

Industry
Mining
Symbol
WSE: KGH
Country
Poland
Sources

"Ten senior managers of the largest Polish mineral holding are in Tehran to talks with Iranian mineral and industrial officials. The holding dubbed KGHM is one of the largest producers of copper and silver in the world. The mining & metallurgy company is based in Poland in Lubin. KGHM Polska Miedz S.A. owns shares in 33 entities, operating in various production and service-related areas... The holding senior managers have been invited by Iranian Minister of Industry, Mine and Trade Mohammad-Reza Nemat-Zadeh and will stay in Tehran until Tuesday." (ISNA, "Senior managers of European mineral holding in Iran," 10/18/15)

Tiefenbach Control Systems GmbH

Industry
Mining Products
States
WV
Country
Germany
Sources

"An early market voyage organized by Volker Klosowski through his local business partners showed the potential that exists in Iran through many direct discussions in the market (with market participants, commercial agents and customers, as well as visits to production facilities). "Volker Klosowski has brought us together quickly and competently with the top decision makers relevant to our industry. As part of the excellently organized market exploration trip, I had a deep insight into the typical Iranian business culture and gained a solid overview of the local technology standard ", says Dipl. Ing. Christian Piel, Commercial Director Tiefenbach Control Systems." 

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Tiefenbach Control Systems GmbH reportedly participating in the Iran Mines & Mining Industries Summit, being held in Tehran May 31-June 1, 2015. (IMIS Website, “List of companies participating in IMIS”)