China

According to its Annual Report filed with the SEC for fiscal year 2019: "CMCC, our parent company, is a party to international GSM roaming agreements with Telecommunication Kish Company and Mobile Company of Iran in Iran, which may be government-controlled entities. China Mobile International, one of our wholly-owned subsidiaries, is a party to international roaming agreements with Irancell Telecommunications Services Company and Mobile Company of Iran in Iran, which may be government-controlled entities. CMCC is also a party to international GSM roaming agreements with Syriatel Mobile Telecom S.A. and MTN Syria (formerly Spacetel Syria) in Syria. As part of our ordinary telecommunications services, these international roaming agreements allow our mobile customers to use their mobile devices on a network outside their home network. In 2019, our gross revenue generated by roaming traffic under these agreements was less than US$500,000.

China Mobile International intends to, and we understand that CMCC intends to, continue these activities in the future."

According to its Annual Report filed with the SEC for fiscal year 2016 and 2017: "China Telecom Global Limited, a wholly owned subsidiary of the Company, entered into a rate agreement for international voice services with Telecommunication Infrastructure Company of Iran (“TIC”), which is a government-controlled entity, in October 2016, which confirmed the preliminary charge rates for international voice services between the parties. The purpose for the agreement is to obtain the charge rates for the parties, which will serve the basis for future cooperation. The rate agreement is not binding on the parties to proceed with signing of the definitive agreement or implementation of the business arrangement, but only serves as the price references for future negotiation. The official business relationship between the parties should be based on a framework agreement or a definitive service agreement. The agreement was subsequently terminated in February 2017. Prior to the termination of the agreement, we did not commence any negotiation with TIC on any framework agreement or any definitive service agreement, and no business was conducted between the two parties. No revenue was generated, and no cost or expenditure was incurred in relation to the agreement. The Company does not currently have any plans to enter into any business arrangements with ITC or other telecommunications operators in Iran."

According to its Annual Report filed with the SEC for fiscal year 2019: "We or our affiliates, are a party to the international roaming agreements with Mobile Company of Iran, or MCI, and MTN Irancell, or MTN, respectively. In 2019, the estimated gross revenue generated from such inbound international roaming traffic with MCI and MTN was approximately RMB254,500 and RMB28,200, respectively, and the estimated total amount paid to MCI and MTN for the outbound international roaming traffic was approximately RMB45,200 and RMB127,700, respectively. We or our affiliates do not customarily allocate net profit on a country-by-country or activity-by-activity basis, and therefore it is not possible to determine accurately the precise net profits attributable to such transactions with MCI and MTN. We or our affiliate estimate that the net profits attributable to the transactions with MCI and MTN were negligible relevant to our overall net profits. We or our affiliate intend to continue these activities in the future."

In 2019 Zhejiang Shibao was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  

On September 19, 2007, Sinopec Shanghai was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Sinopec Shanghai remains on the SBA list of prohibited investments. 

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Sinopec Shanghai is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies.

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In 2020, the U.S. state of Mississippi listed Sinopec Shanghai on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting.

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According to its Annual Report filed with the SEC for fiscal year 2019: "We have sourced a small portion of our crude oil from Iran in the past through Sinopec Corp., our current controlling shareholder, and independent third parties, and Iran may continue to be the ultimate source of a small portion of our crude oil. In addition, Sinopec Corp. and Sinopec Group, the controlling shareholder of Sinopec Corp., have engaged in operations in or purchasing crude oil sourced from Iran and may continue to do so in the future. We have no control over the activities of Sinopec Group or Sinopec Corp. in connection with any activities that they may conduct in Iran."

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According to its 2018 Annual Report filed with the SEC in April 2019: "We have sourced a small portion of our crude oil from Iran in the past through Sinopec Corp., our current controlling shareholder, and independent third parties, and we may continue to purchase crude oil from Iran. In addition, Sinopec Corp. and Sinopec Group, the controlling shareholder of Sinopec Corp., have engaged in operations in or purchasing crude oil sourced from Iran and may continue to do so in the future. We have no control over the activities of Sinopec Group or Sinopec Corp. in connection with any activities that they may conduct in Iran...In addition, purchase of crude oil by Sinopec Corp. subsidiaries that supply us with raw materials may from time to time be sourced from National Iranian Oil Company. This entity has been identified by the U.S. government as an SDN and sanctioned under various laws, including for assisting the government of Iran to avoid sanction and for engaging in activities related to nuclear proliferation. Under Executive Order 13846, the U.S. President can sanction non-U.S. companies that engage in transactions with SDNs such as the National Iranian Oil Company.... It is possible that Sinopec Group or its affiliates engage in activities that are targeted for sanction purposes by the ISA or other U.S. laws. Based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group engaged in limited business activities in Iran such as providing engineering services and designs. We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2019."

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According to its Annual Report filed with the SEC for fiscal year 2013: "In 2013, we sourced a small amount of crude oil from Iran through a wholly-owned subsidiary of Sinopec Corp., our controlling shareholder, and such amount represented 7.04% of our total purchase volume of crude oil. Details of the purchase volume and purchase expenses are provided below. 

In addition, based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group, directly or indirectly, engaged in a small amount of business activities in Iran such as providing engineering support and designs. Sales revenue from these business activities accounted for 0.0015% of Sinopec Group’s total unaudited sales revenue in 2013. No profits were generated from these business activities in 2013.

We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2014."

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Sinopec Shanghai has filed Iran Notices with the SEC from 2013 - 2020. 

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According to its Annual Report filed with the SEC for fiscal year 2012: "In 2012, we sourced a small amount of crude oil from Iran through a wholly-owned subsidiary of Sinopec Corp., our controlling shareholder, and such amount represented 6.3% of our total purchase volume of crude oil in 2012. Details of our 2012 purchase volume and purchase expenses are provided below. In addition, based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group, directly or indirectly, engaged in a small amount of business activities in Iran such as providing engineering support and designs. Sales revenue from these business activities accounted for 0.08% of Sinopec Group’s total unaudited sales revenue in 2012. No profits were generated from these business activities in 2012. We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2013."

According to publicly available shipping information, Bulk Carrier vessel HONY FUTURE (IMO: 9583823), of which the Group Owner is Minsheng, has called at an Iranian port on seven occasions, most recently in July 2019.

On March 18, the U.S. Department of State imposed sanctions, pursuant to Executive Order (E.O.) 13846, on Dalian Golden Sun Import & Export Co., Ltd. for knowingly engaging in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petrochemical products from Iran. (U.S. Department of State, "Sanctions on Entities Trading in or Transporting Iranian Petrochemicals, "3/18/2020). 

Gaobeidian Kaituo Precise Instrument is sanctioned for supporting Iran’s missile program; The United States is sanctioning Gaobeidian Kaituo Precise Instrument pursuant to the Iran, North Korea, and Syria Nonproliferation Act (INKSNA) on February 25 2020 (Department of State, "New Sanctions under the Iran, North Korea, and Syria Nonproliferation Act," 2/25/2020).

Rushi signed a “Letter of Agency” signed by Rushi President Liu Zhi Gang on July 10, 2016 granting exclusive agency rights to the Iranian firm, Petro Farayand Sadid (“Petrosadid”) in Iran. (Petrosadid Website, “EXCLUSIVE AGENCY LETTER,” 3/2/2016).

According to publicly accessible ship-monitoring data, since January 1, 2016, vessels for which Jiangsu Steamship is the Operator and Group Owner have called at Iranian ports.