Emerson Electric Co.

Conglomerate, Engineering, Technology

In response to an inquiry for the U.S. Securities and Exchange Commission's Office of Global Security Risk regarding potential Iran business ties, Emerson Electric wrote:

"Emerson’s U.S. subsidiaries have been prohibited from conducting business with Iran, directly or indirectly, under the Company’s trade compliance requirements since the initial imposition of U.S. sanctions against Iran in 1995.

"After 1995 and before July, 2010, some of Emerson’s foreign subsidiaries, primarily in Europe, continued to transact a limited amount of lawful business with Iran.  This involved the sale of process equipment such as valves, transmitters and controllers; climate control equipment such as compressors; and, electric motors, drives, and uninterruptible power supply equipment.  That business was primarily conducted indirectly through OEMs, engineering companies and distributors.
"In July, 2010, after the passage of the Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010, Emerson’s foreign subsidiaries implemented a prohibition on all new business with Iran, direct or indirect, even if such sales would have been legal.  When there was a legal basis for doing so, Emerson’s foreign subsidiaries terminated contracts that were entered prior to this ban.  Contracts for which there was no legal basis for termination remained in place, with a view to winding them down as soon as possible.  During the second quarter of fiscal 2012, the Company completed its remaining contracts." (SEC Correspondence, 3/16/2012)