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

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AMETEK, according to its website, is a leading global manufacturer of electronic instruments and electromechanical devices, with 11,000 colleagues working at more than 80 manufacturing facilities and more than 80 sales and service centers in the US and across the world.

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Lloyd Instruments, an AMETEK subsidiary based in the United Kingdom, manufactures material testing machines, texture analyzers, and davenport polymer test equipment, and lists a regional contact in Iran.  (Company Website)

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Another subsidiary, Denmark-based AMETEK Calibration Instruments, also has an office in Iran. The company is a manufacturer of instruments that calibrate temperature, pressure and process signals as well as temperature sensors. (Company Website)

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The devices of AMETEK Calibration Instruments are used in the oil & gas industry, among others. (Company Website)

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

Merck KGaA spokesman Gangolf Schrimpf this week confirmed that a contractor has expanded capacity for making Merck drugs for the Iran market with the opening of a new facility. Merck was careful to point out that the facility was built without any investment from the German drugmaker and in “compliance with applicable local and international law and regulations.”

“Merck does not have a legal presence, nor does Merck own any assets or facilities in Iran,” Schrimpf said in an email. (FiercePharma, "New plant to make Merck KGaA drugs opens in Iran," 4/25/2019).

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“Multiple companies currently exploring new business ventures in Iran are also cashing in on highly lucrative contracts with the U.S. Defense Department, raising questions about whether their dealings with Iran could run afoul of U.S. law. At least 13 major international companies have said in recent weeks that they aim to reenter the Iranian marketplace over the next several months. The companies have received Pentagon contracts totaling well over $107 billion, according to a Washington Free Beacon analysis that tracked DoD contracts awarded since fiscal year 2009. Many of the companies, which include carmaker Renault and oil giants such as BP, have already sent high-level trade delegations to Tehran to meet with Iranian officials about striking new business deals…These companies include Boeing and General Electric—which have DoD contracts worth $87 and $12 billion respectively—as well as the Italian oil company Eni, Merck, Safran, Vitol, Bosch Rexroth, Sanofi Pastuer, and AVL.” (Washington Free Beacon, “Pentagon Contractors Exploring Business with Iran,” 2/25/14)

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"German pharmaceutical group Merck is seeking a partnership with an Iranian manufacturer to produce medicines in the country in a sign that western companies are putting their faith in President Hassan Rouhani’s reformist drive and an easing of international sanctions…Darmstadt-based Merck said it was in discussions with several specialist Iranian producers to assess production of two drugs, adding to its existing sales of medicines into the country…Medicines are among the humanitarian exemptions to the existing sanctions regime, but foreign companies’ sales and investment have been limited by difficulties in payment, insurance and shipping…Merck said it was seeking a local producer to make its products Glucophage for diabetes and Concor for high blood pressure to the necessary quality standards." (Financial Times, "Merck tests ground for Iran partnership to produce medicines," 12/26/13)

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"Germany’s multi-billion euro bilateral trade relationship with Iran continues unabated, even as evidence mounts that the Islamic Republic is determined to build a nuclear weapons capability. The Jerusalem Post has obtained an uncensored list from late 2011, showing hundreds of German and Iranian enterprises in a flourishing trade relationship . . . The list showed that Merck KGaA, the giant Hesse-based chemical and pharmaceutical company, has long been active in Iran. Merck spokesman Steffen Mueller remained largely tight-lipped about its work with Iran, writing in an email that the company adheres to all existing trade conditions." (Jerusalem Post, "German firms still ship dual-use goods to Iran Jerusalem," 7/9/12) 

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"In Iran, Merck has a representative office engaged in the marketing of engaged in the marketing of laboratory and specialty chemicals. Until the two divisions Merck Serono and Consumer Health Care as well as the business sector Chemicals have specific information on this site the offices are your point of contact for Merck products."

Listed are the Merck's chemicals distributors in Iran.  (Company Website)

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Over the last three presidential administrations, the United States government has granted Merck 10 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)

On February 16, 2021, Iowa Public Employees' Retirement System removed Danieli from its Iran Prohibited COmpanies List. 

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As of August 15, 2019, the state of Iowa listed Danieli on its Iran scrutinized companies list.

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According to its annual report filed on June 30, 2018, "With regard to the two Iranian contracts signed with Ghadir Energy Investment Company…The determination of the Italian Government and the European Union, together with other countries, to continue economic cooperation with Iran will hopefully lead to a solution that should allow the completion of the loan procedures for these two contracts and their subsequent start." (Danieli Website, “Annual Report,” 8/30/2018).

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"Italian steel manufacturer Danieli has halted work on finding financial coverage for orders it won in Iran worth 1.5 billion euros ($1.8 billion) following the U.S. withdrawal from the 2015 Iran nuclear deal. “With the withdrawal of the U.S. from the treaty the banks are no longer ready to fund Iranian projects for fear of secondary sanctions,” Danieli CEO Alessandro Trivillin said on Thursday. In 2016 Danieli signed a framework commercial agreement with Iran worth about $5.7 billion." (5/18/2018)

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In 2018 the U.S. state of  Iowa listed Danieli on its Iran scrutinized companies list rendering Danieli ineligible for investment and/or state contracting.

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Danieli group signed $6.2 billion with Iran during President Hassan Rouhani's visit to Italy in January 2016 for the cooperation in the steel and aluminum sectors.--

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"The Italian Danieli Groups steel machinery production plant was inaugurated on Tuesday by Industries, Mining and Trade Minister Mohammad Reza Nematzadeh and the head of Iranian Mines and Mining Industries Development and Renovation Organization, Mehdi Karbasian." (May 4, 2017).

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"Several steel giants, including Italy’s Danieli, Spain’s Sarralle Equipos Siderogicos, Germany’s SMS Group and Russia’s INTECO, have been actively participating in the Iranian industry though they seek to bolster ties with Iran. As such, Danieli Persia plant has been constructed in a joint venture between Iran and Italy and will begin production in April 2017. The plant will mark the biggest steel factory in the Middle East and will be operated only by Iranian engineers, as asserted by Danieli CEO Gianpietro Bendetti." (Mehr News Agency, "Iran's Steel Market in 'New Normal' Era," 2/18/2017).

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"The Italian Danieli group, which is one of the world’s largest suppliers of equipment and plants to the metal industry, is set to revamp Khorasan Steel Company’s electric arc furnace technology to boost the steel mill’s steel production capacity, Minews reported. The two companies’ representatives signed a memorandum of agreement in Khorasan Razavi Province on Wednesday. The company says the new EAF technology, which is expected to take one year to install, will also reduce the mill’s raw material and energy consumption." (August 20, 2016).

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Danieli 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”)

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“As economic sanctions eased last month under a temporary accord, Iran is shaping up as a hot, untapped opportunity for Western steel exporters, particularly high-grade varieties…About 45 producers sent representatives to a steel conference last month in Tehran to study export opportunities and investing in Iran’s domestic industry, Karbasian said. More than 10 steelmakers contacted by Bloomberg declined to comment or said they hadn’t attended the event…Danieli SpA of Italy and Germany’s SMS Siemag gave addresses at the steel event in Tehran, Karbasian said. A person familiar with Danieli’s situation said the company attended the conference, as the Iranian market is interesting and Danieli is evaluating possible opportunities there.” (Bloomberg, “Iran Thaw Seen Re-Stoking $6 Billion Market for Steel,” 3/12/14)

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"An Italian business delegation will visit Iran to explore investment opportunities in the Islamic Republic. The delegation, headed by Chairman of Iran-Italy Chamber of Commerce Rosario Alessandro, will start a four-day visit to Iran on Saturday, said the Press Office of the Iranian Embassy in Rome, Press TV reported…Meanwhile, Italy's Danieli company said it is ready to build a factory in Iran to design and produce mining equipment and machineries. Danieli Chief Executive Officer Gianpietro Benedetti, who is visiting Iran after four years, in a meeting with Mehdi Karbasian, director of Iranian Mines and Mining Industries Development and Renovation Organization (IMIDRO), on Friday referred to Danieli's years of presence in Iran and said the company is keen to expand relations in the mining industry. ‘The construction project of a factory for designing and production of equipment and machineries is currently underway in Shahreza, Isfahan province, and will come on stream within 15 months,’ Benedetti said. Benedetti said Danieli is ready to share its know-how and years of experience in steel industry with Iranian firms. The IMIDRO chief said his organization wants Danieli to cooperate in building a steel factory in Iran and will make every necessary preparation in this regard…Danieli ranks among the three largest suppliers of equipment and plants to the global metal industry. The company has seven factories in Italy, Germany, France, Sweden, Thailand, China and India. Its headquarters is in Buttrio in northeast Italy.” (Iran Daily, “Italian business delegation due,” 2/22/14)

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“Italian company, Danieli, has expressed its readiness to establish a factory in Iran for manufacturing mining machinery, ISNA reported on February 21. Danieli's CEO Gianpietro Benedetti made the remarks at a meeting with Iranian Deputy Industry Minister Mehdi Karbasian in Tehran. Currently, a steel plant is being built by Danieli in Iran's city of Shahreza, in Isfahan province, he said, adding that the project will be inaugurated by in the next 15 months.” (Trend, “Italian firm ready to build mining machinery factory in Iran,” 2/21/14)

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"Iranian special steel producer Iran Alloy Steel plans to construct a new seamless pipe mill, Steel Business Briefing is informed by the Iranian state metal and mining group Imidro. A consortium formed of Danieli and another company has signed a contract to construct the new facility named Yazd 1, says Iran Alloy Steel’s director of expansion projects Hokmolah Babaei. The capacity of the new mill, which is expected to be completed within 33 months, will be about 525,000 tonnes/year, a source informs SBB." (Steelmaker.ru, "Danieli will Build New Seamless Pipe Mill for Iranian Special Steel Producer," 4/21/11)

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"The list of about 1,000 Italian companies active in Iran includes such household names as Eni—the energy giant is Iran's biggest business partner in Europe according to the Italian-Iranian Chamber of Commerce—as well as Fiat, Ansaldo, Maire Tecnimont, Danieli and Duferco." (Wall Street Journal, The Rome-Tehran Axis, 1/14/2010)

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"Italy's Danieli & Company has been awarded the job of setting up a big facility in Khuzestan to build steel sheet for oil and gas pipelines. The $232 million contract signed on 25 October requires a separate financing deal being negotiated with Mediocredito Centrale." (MEED, "Iran: Danieli Steel Contract awaits Finance Line." 1999)

On March 9, 2021, Oil India was removed from the Florida State Board of Administration (SBA) Iran Continued Examination List. 

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On February 16, 2021, Iowa Public Employees' Retirement System removed Oil India from its Iran Prohibited Companies List. 

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In January 2021, the State of New Jersey Department of the Treasury listed Oil India as a company engaged in prohibited activities in Iran pursuant to P.L. 2012, c. 25 ("Chapter 25").

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As of December 2020, Rhode Island continues to list Oil India as having active investment in Iran's energy sector of at least greater than $20-50 million. 

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On October 14, 2020, Oil India remained on the Tennesse Department of General Services list of persons it determines engage in investment activities in Iran, as described in 12-12-105.

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Oil India is listed on the August 5, 2020 California Department of General Services, "Entities Prohibited from Contracting with Public Entities in California per the Iranian Contracting Act, 2010" list.

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As of July 2020, Oil India remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996. 

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In 2020, the U.S. state of Mississippi listed Oil India 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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In June 2020, Oil India was listed by the Connecticut Office of the Treasurer as a restricted company and therefore prohibits direct investment in the company due to its involvement in Iran. 

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"Oil India has been identified as having a participating interest in an offshore oil field in Iran. The U.S. Government Accountability Office (GAO) has identified Oil India as having commercial activity in Iran’s energy sector. Since 2012, CalSTRS has initiated the review process multiple times as the security was purchased by CalSTRS external managers but liquidated the security before completing the engagement. In 2015, CalSTRS designated the company as “Divested and Restricted” because it would be more efficient than continually initiating the review process. In 2020, prompted by potential manager interest in investing in the company, CalSTRS removed Oil Indian after further review of the company’s internal controls to prevent sanction violations."

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As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list Oil India on its list of “Continued Examination Companies with Petroleum Energy activities in Iran.

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On May 15, 2020, the IPERS identified Oil India on its Iran Prohibited Companies List.

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As of April 15, 2020, Oil India is included as an entity determined to be non-responsive bidders/offerers pursuant to The New York State Iran Divestment Act of 2012.

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As of April 15, 2020, Oil India is included on the Tennessee list of persons it determines engage in investment activities in Iran, as described in § 12-12-105.

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As of December 31, 2019, the Alaska Retirement Management Board lists Oil India as a company doing material business with Iran.

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Since 2012, the California State Teachers Retirement System (“CalSTRS”) initiated the review process of Oil India as the security was purchased by CalSTRS external managers. However, the security was always sold before the review process could be completed. In 2015, CalSTRS designated the company as “Divested and Restricted” for having a participating interest in an offshore block in Iran and because it would be more efficient than continually initiating the review process. CalSTRS maintained the “Divested and Restricted” designation in 2019.  In 2009 through 2010, the California State Public Employees Retirement System (“CalPERS”) identified Oil India as having oil exploration contracts and oilfield interests in Iran. In 2012 CalPERS approved divestment from the company.

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As of October 28, 2019, the Pennsylvania Treasury Department (“PA Treasury”) lists Oil India on its Iran list of scrutinized companies for “oil-related investment of at least US $20 million since 1996.

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As of August 15, 2019, the state of Iowa listed Oil India on its Iran scrutinized companies list.

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On June 30, 2019, New Jersey listed Oil India on its state list of entities determined, based on credible information, to be engaged in prohibited activities in Iran.

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Oil India is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

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Oil India is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list.

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On March 13, 2019, the Mississippi Department of Finance & Administration identified Oil India as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.

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Oil India is listed on the January 2019 Entities prohibited from Contracting with Public Entities in California list.

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Oil India has been identified as having a participating interest in an offshore block in Iran. The GAO has identified Oil India as having commercial activity in Iran’s energy sector.

Since 2012, CalSTRS has initiated the review process of Oil India as the company was purchased by CalSTRS external managers. However, the security was always sold before the review process could be completed. In 2015, CalSTRS designated the company as “Divested and Restricted” because it would be more efficient than continually initiating the review process. CalSTRS has maintained the “Divested and Restricted” designation in 2018.

Oil India is listed on the December 31, 2018 CalSTRs Portfolio of companies identified as possibly having ties to Iran and from which CalSTRs has divested from and restricted in 2018.

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Oil India is listed on the CalPERS November 2018 Iran Divested/Restricted companies list.

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In 2017 the U.S. state of California listed OilIndia on its list of companies doing material business with Iran rendering OilIndia for investment and/or state contracting.

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 In 2017 the U.S. state of Florida, Pennsylvania, Mississippi, Rhode Island, South Carolina, Tennessee listed Oil India on its continued examination list of companies with petroleum energy activities in Iran.

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In 2018 the U.S. states of Iowa, New Jersey, New York listed Oil India as an Iran restricted company rendering Oil India ineligible for investment and/or state contracting.

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"A U.S. Congress investigative arm has identified four companies that did business with Iran's energy sector over roughly the past year, despite global sanctions. Based on open-source information, the U.S. Government Accountability Office on Tuesday pinpointed two companies in China and another two in India dealing with Tehran's energy industry during a 13-month period ending in November. Any or all of the parties could come under new global pressure to cease their joint projects...Oil India and another Indian firm, Oil and Natural Gas, each told U.S. auditors they had divested from gas field development efforts noted in their annual reports. However, the investigators still labeled the firms as ‘active’ collaborators with Iran during the recently concluded reporting period." (Global Security Newswire, “Iran's Business Partners Face New Sanctions Scrutiny,” 1/9/14)

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"Iran has offered the first such pact globally since the 1979 revolution that overthrew the monarchy in Iran to an Indian consortium comprising ONGC Videsh Ltd (OVL), Indian Oil Corp. Ltd(IOC) and Oil India Ltd (OIL), which won a bid for the block in 2002 from National Iranian Oil Co." (The Wall Street Journal, "Indian firms to ink production-sharing contract with Iran," 6/16/2013)

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Firm/country: Oil India Ltd. (OIL)/India;

Firm activity: Development of Farzad-B natural gas field in the Farsi block;

Status: Part of a consortium that is exploring the Farsi block and

that submitted a 2009 plan to develop the gas field over a 7- to 8- year period;

Commercial activity: 20% stake in the project, with an estimated total investment of $5 billion;

Firm comment: Contacted on February 18, 2010; no response as of March 22, 2010.

(GAO Report 2010, "Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors")

"Indian companies including Oil India Ltd and ONGC plan to buy a part of ConcoPhillips' Canadian oil sands assets worth around $5 billion." (Reuters, "India ONGC says presence in Iran, Sudan may affect US plans," 9/4/2012)

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"The Indian government has asked its public sector oil firms to seek legal opinion on the impact of the latest round of US sanctions on Iran on their investment in the Persian Gulf nation, Oil Secretary S Sundareshan said here. The US administration had in May named Oil and Natural Gas Corporation, ONGC Videsh Ltd, Oil India Ltd, IndianOil, Hinduja Group and Petronet LNG among the 41 firms worldwide having energy ties with Iran, an act for which it may impose sanctions on them." (Economic Times, "Oil PSUs to seek legal opinion of impact of sanctions on Iran," July 22, 2010)

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"We had last year mentioned about commercial gas discovery in an Exploration Service Contract for Farsi Off shore Block, Iran, where your Company has 20% PI as a member of the consortium led by OVL. Th e consortium is now in discussion with National Iranian Oil Company (NIOC) and Iran Off shore Oil Company (IOOC) on its development plan." (Company Website - Chairman's Address, 2010) 

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"The Company has overseas presence in seven countries, Libya, Gabon, Nigeria, Yemen, East Timor, Iran and Sudan.  These blocks are part of one of the most prolific basins in Libya. In Iran , OIL has 20% PI in Farsi Block. Discovery of oil and gas in the block has been made, which is being evaluated for commercialization." (Company Website - Press Release, April 2009)

According to its Annual Report filed with the SEC in 2013: "We have not conducted, and do not intend to conduct, any further business activities in Iran or with Iranian counterparties."

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According to an Annual report filed by LyondellBasell affiliate Evertec, "Certain non-U.S. subsidiaries of our predecessor, LyondellBasell AF, licensed processes to construct and operate manufacturing plants in Iran that produce polyolefin plastic material, which is used in the packaging of household and consumer goods. The subsidiaries also provided engineering support and supplied catalyst products to be used in these manufacturing operations. In 2009, the Company made the decision to suspend the pursuit of any new business dealings in Iran.

As previously disclosed by the Company, in 2010, our management made the further decision to terminate all business by the Company and its direct and indirect subsidiaries with the government, entities and individuals in Iran. The termination was made in accordance with all applicable laws and with the knowledge of U.S. Government authorities. As part of the termination, we entered into negotiations with Iranian counterparties in order to exit our contractual obligations. As described below, two transactions occurred under settlement agreements in early 2012, although the agreements to cease our activities with these counterparties were entered into in 2011. In January 2012, one of our non-U.S. subsidiaries received a final payment of approximately €3.5 million for a shipment of catalyst from an entity that is 50% owned by the National Petrochemical Company of Iran.

Our shipment of the catalyst was in February 2012 as part of the agreement related to our termination and cessation of all business under agreements with the counterparty. In 2012, the gross revenue from this limited activity was approximately, €4.2 million and profit attributable to it was approximately, €2.4 million.

In January and February of 2012, one of the Company’s non-U.S. subsidiaries provided certain engineering documents relating to a polyolefin plastic process to a licensee comprising three Iranian companies, one of which is 20% owned by the National Oil Company of Iran. The provision of documents was the Company’s final act with respect to the termination and cessation of all business under agreements with the counterparties. No gross revenue or profit was attributable to this activity in 2012. The transactions disclosed in this report do not constitute violations of applicable anti-money laundering laws or sanctions laws administered by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), and are not the subject of any enforcement actions under the Iran sanction laws. We have not conducted, and do not intend to conduct, any further business activities in Iran or with Iranian counterparties.”"

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“LyondellBasell Industries NV, one of the world's biggest plastic and chemical producers, will end its business operations in Iran to shield itself against penalties the U.S. could soon impose on companies for violating trade sanctions.” (The Wall Street Journal, “LyondellBasell Will Quit Iran,” 8/5/10)

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Firm/country: LyondelBasell/The Netherlands;

Firm activity: Supplying technology for new HDPE petrochemical plant in Kermanshah, increasing capacity by 300,000 metric tons per year;

Status: Expected completion 2009 to 2010;

Commercial activity: Not reported;

Firm comment: Confirmed activities. Noted that profits from the two projects are small compared to its European operations.

(GAO report 2010 - "Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors")

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"Lyondell Basell Company had previously participated in Amirkabir and Jam petrochemical complexes’ development plans. National Petrochemical Company’s Project Manager Jalil Ebrahimpour said for his part that the abovementioned petrochemical complexes are parts of the Dena ethylene pipeline, each with the annual projected HDPE output of 300,000." (Tehran Times, "World praises Iran’s petrochemical achievements: LyondellBasell exec," 6/10/2009) 

In 2015 Costain was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran after the company confirmed that neither it nor any of its subsidiaries have business activities in Iran.
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In 2014, Costain was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.

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Firm/country[A]: Costain Oil, Gas & Process Ltd./United Kingdom;

Status: Gas refinery/processing plant at Bid Boland II;

Commercial activity: Expected completion 2009; Part of consortium whose contract is valued at $1.7 billion;

Firm comment: Contacted on January 14, 2010; no response as of March 22, 2010.

(GAO Report 2010 - "Firms Reported in Open Sources as Having Commercial Activity in Iran’s Oil, Gas, and Petrochemical Sectors")

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"In Iran, Costain led a consortium of four companies in the bidding and ultimate award by the National Iranian Gas Company of the Bid Boland II Gas Treatment Plant Project, valued at $1.67bn and financial negotiations are continuing." (Costain Company Press Release, June 2005)

The Iranian company HEPCO lists Terex products under license on its company website. (HEPCO Website, “Under License”)

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According to its Annual Report filed with the SEC for fiscal year 2012: "Effective April 30, 2010, we adopted an internal policy prohibiting any transactions where Terex knows or has reason to believe that such equipment or parts would be destined for Iran unless for humanitarian purposes. This policy applies to both U.S. and non-U.S. subsidiaries and joint ventures controlled by Terex even if the transaction otherwise would be permissible under U.S. law. In the very limited circumstances where existing contractual obligations of non-U.S. subsidiaries and controlled joint ventures required the supply of equipment, parts or aftermarket service to entities in Iran, obligations under these contracts were to be completed as quickly as possible provided that the transactions were compliant with U.S. law (“Winding Down Transactions”). Subsequently on March 26, 2011, we revised our policy and eliminated the ability to engage in any Winding Down Transactions.

We acquired a majority interest in Demag Cranes AG on August 16, 2011, but did not obtain management control over Demag Cranes AG and its subsidiaries until April 18, 2012. Once we obtained management control, Demag Cranes AG and its subsidiaries subsequently adopted the Company’s internal policy on sales into Iran effective June 4, 2012. However, between January 1, 2012 and June 4, 2012, certain subsidiaries of Demag Cranes AG exported certain products into Iran.

Pursuant to Section 13(r) of the Securities Exchange Act of 1934, we are required to provide disclosure if, during 2012, we or any of our affiliates have engaged in transactions or dealings with the government of Iran that have not been specifically authorized by a U.S. federal department or agency.

During the year ended December 31, 2012 (and prior to the June 4, 2012 implementation of the Terex policy at Demag Cranes AG and its subsidiaries), Demag Cranes and Component GmbH (“DCC”), a German subsidiary of Demag Cranes AG, exported from Germany overhead crane components and spare parts to three entities in Iran, National Iranian Copper Industries Co. (“NICIC”), Hormozgan Steel Complex (“HSC”) and Farabi Industrial & Agricultural Co. (“FIA”), which, based on information available to us, we believe are or may be owned or controlled by the Government of Iran.  All of the transactions occurred prior to the October 9, 2012 date of the Presidential Executive Order that made it a violation of U.S. law for owned or controlled foreign subsidiaries to knowingly engage in transactions with the Government of Iran or any person subject to the jurisdiction of the Government of Iran and prior to August 10, 2012, the date of enactment of the Iran Threat Reduction and Syria Human Rights Act of 2012.

The decision to provide the overhead crane components and spare parts was made and performed by a foreign entity and were permissible under applicable law when they were executed. The gross revenue values for DCC for the transactions with NICIC, HSC and FIA were €1,772, €5,932 and €18,174, respectively and the profit values for DCC for the transactions with NICIC, HSC and FIA were €755, €3,087 and €11,989, respectively. The last transaction generating revenue occurred on February 23, 2012, although DCC supplied warranty parts on April 18, 2012 for which they were not paid.

As a result of our policy against any sales into Iran unless for humanitarian purposes, neither Terex nor any of its foreign subsidiaries intend to conduct any future transactions into Iran."

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"A lobbying group that had targeted construction crane-maker Terex Corp. (TEX) over Iran's use of the company's cranes for public hangings said Thursday it is satisfied that Terex no longer does business in Iran. United Against Nuclear Iran said Terex demonstrated that it has received no revenue or profit from Iran since the third quarter of 2010, in keeping with the company's April 2010 policy prohibiting all new business transactions in Iran. 'We applaud Terex for ending its business in Iran,' said Mark Wallace, president of the group, in a written statement Thursday. 'Any socially responsible company should be appalled at the possibility of having its products used for gruesome public executions.' The New York-based group made Terex the first target of its 'Cranes Campaign' against companies whose machinery in Iran is used in executions where the condemned are hung from cranes and their bodies left to dangle for public display." (Dow Jones Newswires. "Terex Convinces Lobbying Group It Has Stopped Doing Business With Iran," 3/24/11)

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Terex is a Connecticut-based global manufacturer of industrial equipment, specifically for the construction, mining, utilities, forestry, and transportation industries  (Company Website). 

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Despite not listing Iran on its dealer locator, Terex sells cranes through the Iran-based Behrad Tehran Company, under its Terex Demag brand. The Behrad Tehran Company lists the mechanical specifications of over 30 Terex crane models, all of which are accompanied by photographs and made fully available for purchase (Behrad Tehran Company Website). 

Additionally, Terex's "Terex Atlas" brand is licensed for "Product Sales" in Iran (Company Website). 

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In 2009, the SEC questioned Terex's activites in Iran based on information from their 10-k form, noting the following:

"We note from disclosure in your Form 10-K that you currently operate in the Middle East, understood to include Iran, and that you intend to increase your operations in those regions. We note also that it appears from your website that nationals of Iran, Sudan and Syria can register as your suppliers, and that you sell products and provide service and support for your Terex Atlas brand in Iran. We are aware of a March 2006 news report that your joint venture, Inner Mongolia North Hauler Co. Ltd., sold products into Iran. We also are aware of a March 2007 news report that Terex Equipment Middle East LLC, the sales and marketing office for your Aerial Work Platforms segment, serves the market demand for your equipment in Iran and Syria, among other countries." (UPLOAD for TEREX CORP, 6/25/2009)

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In a correspondance with the SEC, Terex responded to their inquiries thusly:

"From time to time, various Terex foreign subsidiaries sell foreign-manufactured equipment for use in such industries in Iran, Sudan or Syria where permitted under U.S. and local law.  Terex foreign subsidiary sales into Iran  over each of the past three years are approximately as follows: Iran: $19.9 million in 2006, $11.8 million in 2007, and $11.1 million in 2008" (CORRESP for TEREX CORP, 7/17/2009)

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In 2004, O&K Mining, at that point owned by Terex, was listed as a supplier for Abad Rahan Pars Co. during its development of the South Pars Gas Field. O&K was sold in 2010, but was owned by Terex at the time of the project (Abad Rahan Pars Co. Resources).

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Terex has previously come under Congressional investigation for providing Scud missile launchers to Saddam Hussein's government in Iraq after eyewitness allegations were featured in the New York Times. 

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Terex's Corporate Citizenship policy states that "the ethical behavior of Terex and its employees takes precedence over profits, sales, or other standards of success" (Company Website). 

"While identified by CalPERS in 2015 as not meeting threshold criteria for consideration under the Act, in 2017 the company was reported as potentially having operational trade business in Iran helping coordinate various types of businesses between Japanese and Iranian companies. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."

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In 2020, the U.S. state of Mississippi listed Toyota Tsusho 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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On January 20, 2020, Minnesota SBI listed Toyota Tsusho as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list.

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On March 13, 2019, the Mississippi Department of Finance & Administration identified Toyota Tsusho as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran

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In 2018, the California State Public Employees Retirement System (“CalPERS”) designated Toyota Tsusho “Under Review.” In 2019, CalPERS designated Toyota Tsusho as “Being Monitored” because CalPERS “initial screening has not identified the company as having involvement in the [activities] targeted by the [2019 California Public Divest from Iran] Act.

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In 2017, CalSTRS designated Toyota Tsusho Corp. as “Under Review” for reportedly having an operational trade business in Iran which helps coordinate various types of businesses between Japanese and Iranian companies. CalSTRS maintained the “Under Review” designation in 2018.In 2019, CalSTRS removed Toyota Tsusho from its list.

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In 2017 the U.S. state of California listed Toyota Tusho Corp as a company under review for reportedly having an operational trade business in Iran which helps coordinate various types of businesses between Japanese and Iranian companies.

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In 2017 the U.S. state of Minnesota, Mississippi listed Toyota Tusho on its Iran restricted companies list rendering Toyota Tusho ineligible for investment and/or state contracting.

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Subsidiary of Toyota Group.

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In 2016 Tennessee used the South Carolina list of "Entities Ineligible to Contract with the State of South Carolina or any Political Subdivision of the State per the Iran Divestment Act of 2014, S.C. Code Ann." as its list of persons it determines engage in investment activities in Iran. Toyota Tusho was included on this list in 2016. "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

In 2018 Tennessee used the New York list of “Entities determined to be non-responsive bidders/offerers pursuant to the New York State Iran Divestment Act of 2012.” BPCL was included on this ist in 2018. Tennessee states "Inclusion on this list would make a person ineligible to contract with the state of Tennessee, if a person ceases its engagement in investment activities in Iran, it may be removed from the list."

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According to Reuters, Toyota Tsusho maintains its business relations with Iran. (Reuters, “Japan's JX renews Iran term crude contracts for 2016 – sources,” 1/5/2016).

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In 2015 Toyota Tsusho was removed from Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because the company's "involvement in purchases of crude oil falls under the waivers granted by the U.S. government that meet Section (a)(2) of Act 44's expiration clause."
 

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"Besides Mitsubishi, another trading house, Toyota Tsusho has been also lifting Iranian crude since April for the top two buyers, the sources added."a href="http://www.reuters.com/article/2012/06/22/japan-iran-mitsubishi-idUSL3E8HM3VC20120622">Japan's Mitsubishi renews Iran oil imports deal," 6/22/12)

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In 2011, Toyota Tsusho was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.

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" In 2009, Iran exported about 421,000 bpd of crude to Japan. It was overtaken by Qatar, however, as Japan's third-largest crude supplier.  Many of Japan's top refiners buy Iranian crude, including Showa Shell Sekiyu (5002.T), Nippon Oil (5001.T), Japan Energy, Cosmo Oil (5007.T). Trading house Toyota Tsusho (8105.T) also has a deal to buy crude from the Islamic republic." (Reuters, "Iran's crude export and fuel import customers," 4/13/2010)

As of May 2018, has terminated business in Iran that was previously conducted via a subsidiary, Detecon. ("German rail operator, Deutsche Telekom end Iran projects," Reuters, August 16, 2018.)

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According to its 2017 SEC 10-K filing: DT, through certain of its non-U.S. subsidiaries, is party to roaming and interconnect agreements with the following mobile and fixed line telecommunication providers in Iran, some of which are or may be government-controlled entities: Gostaresh Ertebatat Taliya, Irancell Telecommunications Services Company (“MTN Irancell”), Telecommunication Kish Company, Mobile Telecommunication Company of Iran, and Telecommunication Infrastructure Company of Iran. For the year ended December 31, 2017, gross revenues of all DT affiliates generated by roaming and interconnection traffic with Iran were less than $4 million and estimated net profits were less than $4 million.

In addition, DT, through certain of its non-U.S. subsidiaries, operating a fixed line network in their respective European home countries (in particular Germany), provides telecommunications services in the ordinary course of business to the Embassy of Iran in those European countries. Gross revenues and net profits recorded from these activities for the year ended December 31, 2017 were less than $0.4 million. We understand that DT intends to continue these activities.

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In a correspondance with the SEC in 2009, Deutsche Telekom disclosed few details regarding their investments in Iran.  

"We have bilateral agreements with operators in Iran that provide for termination of traffic into the country and traffic originating from the country.  We have roaming agreements with network operators in Iran.  Roaming agreements allow our mobile customers to make and receive voice calls, send and receive data, or access other services when traveling outside the geographical coverage area of the home network, by means of using another operator’s network." (CORRESP for DEUTSCHE TELEKOM AG, 11/27/2009)