Manufacturing

"Iran imposed sanctions on 15 American companies, saying that they were involved in human rights violations and had cooperated with Israel, the state news agency IRNA reported on Sunday, in a tit-for-tat reaction to a move by Washington...The affected companies, many of them military contractors, also included ITT Corporation, United Technologies and the specialty-vehicle maker Oshkosh Corporation. The affected companies, many of them military contractors, also included ITT Corporation, United Technologies and the specialty-vehicle maker Oshkosh Corporation." (March 26, 2017).

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According to its Annual Report filed with the SEC in 2014:

• "As part of UTC's on-going efforts to identify and terminate transactions with the Government of Iran, we recently determined that three non-U.S. subsidiaries operating through the UTC Climate, Controls & Security segment, sold fire safety products and related installation, maintenance and inspection services to certain Iranian parties located in France, Switzerland and the United Kingdom in 2012, 2013, and 2014. Each of the Iranian parties to the transactions described below has been designated by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) as an entity owned or controlled by the Government of Iran. With respect to Bank Melli Iran, Melli Bank PLC, Bank Sepah, Bank Sepah International PLC, and IranAir, these parties have also been designated by OFAC as blocked pursuant to Executive Order No. 13382. With respect to Bank Saderat Iran, this party has also been designated by OFAC as blocked pursuant to Executive Order No. 13224. A portion of the 2012 transactions and all of the 2013 and 2014 transactions took place after the President issued Executive Order 13628 on October 9, 2012, which implemented Section 218 of the Iran Threat Reduction and Syria Human Rights Act by prohibiting any entity owned or controlled by a U.S. person and established or maintained outside the U.S. from knowingly engaging in any transaction, directly or indirectly, with the Government of Iran. Accordingly, UTC has filed appropriate disclosures with OFAC.
• In 2012, 2013, and 2014, Chubb France SCS (Chubb France), a company organized under the laws of France, sold fire safety equipment and services to the Paris offices of Bank Sepah, Bank Saderat Iran, Bank Melli Iran, and IranAir. In 2012, Chubb France sold approximately $4,324.75 in the aggregate in fire safety equipment and services to these parties, with a net profit of $164.35. Approximately $1,175.18 of the 2012 payments were received before October 9, 2012 and were not prohibited by applicable law when received. In 2013, Chubb France sold approximately $2,402.99 in the aggregate in fire safety equipment and services to these parties, with a net profit of $91.32. In 2014, Chubb France sold approximately $22,070.81 in the aggregate in fire safety equipment and services to these parties, with a net profit of $1,378.48. Chubb France has informed each of these parties that it has terminated the relationships and will not provide further fire safety equipment or maintenance inspection services.
• In 2012, 2013, and 2014, Chubb Fire & Security Limited (Chubb UK), a company organized under the laws of the United Kingdom, sold fire safety products and provided related maintenance inspection services to Petrochemical Commercial Company (U.K.) Limited (Petrochemical). In 2012, Chubb UK sold approximately $7,422.75 in the aggregate in fire safety equipment and services to Petrochemical, with a net profit of $442.83. Approximately $7,834.23 of the 2012 payments were received before October 9, 2012 and were not prohibited by applicable law when received. In 2013, Chubb UK sold approximately $10,078.17 in the aggregate in fire safety equipment and services to Petrochemical, with a net profit of $1,224.64. In 2014, Chubb UK sold approximately $2,243.10 in the aggregate in fire safety equipment and services to Petrochemical, with a net profit of $404.18. Chubb UK has informed Petrochemical that it has terminated the relationship and will not provide further fire safety equipment or maintenance inspection services.
• In 2012, 2013, and 2014, Security Monitoring Centres Limited (SMC), a sister company of Chubb UK organized under the laws of the United Kingdom, provided security alarm monitoring services to the London office of Melli Bank PLC. SMC provided security alarm monitoring services to the London office of Bank Sepah International PLC in 2014. SMC provided the monitoring services to the Iranian banks pursuant to a contract between SMC and Total Security Systems Ltd. (Total Security), a third-party company organized under the laws of the United Kingdom. Total Security had contracts with the two Iranian banks to maintain and monitor their security alarm systems, and Total Security subcontracted the monitoring work to SMC. The contract between Total Security and SMC provides that Total Security will pay SMC a lump sum of $17,526 per year, in exchange for SMC providing monitoring services to 120 of Total Security’s customers. In 2012, SMC received total payments and net profit of approximately $868.90 and $230.28, respectively, for services provided to Melli Bank PLC. In 2013, SMC received total payments and net profit of approximately $857.14 and $229.69, respectively, for monitoring services provided to Melli Bank PLC. In 2014, SMC received total payment and net profit of approximately $961.74 and $381.01, respectively, for monitoring services provided to Melli Bank PLC and Bank Sepah International PLC. SMC has informed Total Security that it has terminated the monitoring services to both Iranian banks and will not provide further services.
• In 2012 and 2013, Sicli Materiel-Incendie S.A. (Sicli Switzerland), a company organized under the laws of Switzerland, sold fire safety products and provided related maintenance inspection services to the Delegation and Permanent Representative of the Islamic Republic of Iran to the United Nations Office in Geneva, Switzerland. In 2012, Sicli Switzerland sold approximately $657.17 in the aggregate in fire safety equipment and services to the Permanent Representative of Iran, with a net profit of approximately $115.12. The 2012 payments took place before October 9, 2012 and were not prohibited by applicable law when received. In 2013, Sicli Switzerland sold approximately $159.13 in fire safety equipment and services to the Delegation of Iran, with a net profit of approximately $32.16. Sicli Switzerland has discontinued the services to the Delegation and Permanent Representative and will not provide further fire safety equipment or maintenance inspection services."

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"United Technologies Corp. disclosed in regulatory filings Friday that one of its foreign businesses worked on the security system for the Paris branch of Iran's national bank, an entity singled out under U.S. economic sanctions against the Middle East country. Delta Security Solution's business with the Bank Melli Iran's Paris branch amounted to $7,582 in 2012 and 2013, a portion of which occurred after President Barack Obama signed an executive order last October limiting U.S. companies and their foreign subsidiaries from 'engaging in any transaction, directly or indirectly, with the Government of Iran.' According to securities filings, UTC reported sales of about $3.59 million over the past two years to banks, insurance companies, oil companies and embassies controlled or owned by the Iranian government. All of the sales were through foreign subsidiaries of the Hartford-based company, which declined to comment further on the sales. Though the sales amount to a sliver of UTC's annual revenue, they underline just how difficult a task U.S. companies and their overseas affiliates have complying with the expanded sanctions against Iran. In the past two months, a group of about two dozen companies — including Costco, Toyota, Oracle, Vodafone, Sony and FedEx — have filed similar notices... Jonathan M. Epstein, a partner at Holland & Knight in Washington D.C. who practices international trade law, said that the fact that UTC has ended the contracts should help it avoid sanctions. 'The winding down of something that was previously lawful and is suddenly unlawful would be a major mitigating factor,' he said, adding that the company's actions 'may very well just result in a warning letter.' The Paris-based subsidiary that did the security work, Delta Security Solutions, is owned by UTC Climate, Controls & Security. This year and last, it 'provided remote monitoring of the Paris branch's electronic alarm system as well as related maintenance services to verify the proper functioning of the branch's intrusion detection equipment,' the filings said. When the work contracts were signed in August 2010, neither the business agreements nor the services were prohibited by law, UTC said in its filings. In addition to reporting the business to the U.S. Securities and Exchange Commission, UTC Climate, Controls & Security filed this information with the Treasury's Office of Foreign Assets Control, as it has in all of these cases. Delta Security has terminated the contracts with the bank and 'does not intend to do any further business with Bank Melli Iran,' UTC said in filings. UTC also reported in April that another subsidiary sold fire safety equipment, including fire blankets, extinguishers, stands and spare parts, to the London office of the Bimeh Iran Insurance Company, another Iranian-controlled business. In February, UTC reported that two other subsidiaries, Simtronics and Water Mist Engineering AS, sold $3.51 million in fire detection and suppression equipment to the Pars Oil & Gas Company, a firm controlled by Iran. Also that month, the company reported that a foreign affiliate of Otis conducted service and maintenance at a number of Iranian 'diplomatic premises' in France, Kuwait and Hungary. That work amounted to $74,500." (The Courant, "UTC Reporting Business With Iran Despite Sanctions," 7/26/2013)

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"United Technologies Corp. says two overseas affiliates earned $630,000 as the company ended business with Iran. The aerospace and building systems conglomerate based in Hartford, Conn., disclosed in its annual report Thursday that its non-U.S. affiliates generated $3.5 million in revenue 'related to the orderly winding down of legacy business related to sale of fire safety equipment' United Technologies said it stopped new business with Iran in 2009. It also said non-U.S. affiliates of its Otis subsidiary serviced, maintained and modernized elevators at Iranian diplomatic premises in France, Hungary and Kuwait last year. The Otis affiliates earned $6,000." (Washington Post, "United Technologies discloses $3.5M in revenue for 2 overseas affiliates ending Iran business," 2/7/13)

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Carrier Corporation, a wholly-owned subsidiary of United Technologies Corporation, states it does business with Iran: "Delivering innovative solutions and trusted products for our customers in: Bahrain, Iran, Iraq, Oman, Qatar, Syria, Yemen." (Company Website)

United Technologies Corporation is also the parent company of three key defense contractors for the United States Military: Sikorsky Aircraft Corporation, Pratt & Whitney and Hamilton Sundstrand.

According to the Sikorsky website, "Sikorsky helicopters are used by all five branches of the United States armed forces, along with military services and commercial operators in 40 nations. Core U.S. military production programs are based on the Sikorsky H-60 aircraft: the BLACK HAWK helicopter for the U.S. Army and SEAHAWK® helicopter for the U.S. Navy. H-60 aircraft derivative aircraft perform multiple missions with other branches of the U.S. military. The CH-53E helicopter and MH-53E helicopter heavy-lift aircraft are flown by the U.S. Navy and Marine Corps to transport personnel and equipment, and in anti-mine warfare missions. Sikorsky is currently developing the next-generation CH-53K helicopter for the U.S. Marines. Sikorsky is the prime contractor in the U.S. Army's UH-60M aircraft program, which the Pentagon authorized for full rate production on June 26, 2007. The program calls for more than 1,200 of the newest BLACK HAWK aircraft during the next 25 years. In 2002, the U.S. Navy inducted the first MH-60S aircraft, the first all-new rotary wing aircraft to enter the service in a decade. The U.S. Navy's helicopter fleet will become all-Sikorsky by 2010, with the MH-60S helicopter and the MH-60R helicopter the only air platforms used." (Company Website)

Sikorsky is the manufacturer of the long-time presidential helicopter, "Marine One." (Sikorsky, "Sikorsky Submits VH-92 Proposal for Presidential Helicopter Mission," 1/26/04)

Pratt & Whitney From the P & W website: "Today, nearly 11,000 Pratt & Whitney military engines are in service with 27 armed forces worldwide, setting new standards for performance and dependability. With the best engine technology, world-renowned manufacturing techniques and a global service organization, Pratt & Whitney is completely focused on meeting the new demands of the 21st century. Pratt & Whitney currently produces the F135 engine for the F-35 Lightning II. This proven fifth-generation engine was selected by the Department of Defense as the best engine for the F-35 and is more reliable and cost-effective than adding an unwanted alternate engine. Learn why the F135 is the best engine for the F-35 at f135engine.com. Pratt & Whitney’s other military engines include the F119 for the F-22 Raptor, the F100 family that powers the F-15 and F-16, the F117 for the C-17 Globemaster III, the J52 for the EA-6B Prowler, TF30 for the F-111, and the TF33 powering AWACS, Joint STARS, B-52, and KC-135 aircraft. In addition, Pratt & Whitney offers a global network of MRO and MAS focused on maintaining engine readiness for our customers." (Company Website)

Hamilton Sundstrand Aerospace: "Hamilton Sundstrand's Aerospace business units provide technologically advanced systems, components and services for commercial and military aircraft and vehicles." (Company Website) Energy, Space & Defense: "Hamilton Sundstrand’s Energy, Space & Defense (ESD) business unit provides highly reliable, advanced technology solutions to a broad range of government and industry customers. ESD continues to bring innovative and integrated solutions to our traditional Space, Missile, Launch Vehicle, and Undersea markets, while seeking new applications for our advanced technologies in support of Army and Joint Services land-based forces, surface Navies, Renewable Energy Production, and the Nation’s Homeland Security needs." (Company Website)

Caterpillar Iran has its own website.

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"Solar Turbines, a division of Caterpillar, requested this license because it wanted to bid on a project to build a natural mixing station needed by the Turkish government-owned pipeline company, Botas. In its application, Solar Turbines acknowledged that the mixing station in Sivas, Turkey, would serve a pipeline that carried Iranian gas through Turkey and into Western Europe.

The United States has a clear-cut policy that it does not support pipelines that deliver Iranian gas to customers outside that country’s borders, for the simple reason that Iran’s huge natural gas resources prop up its economy and help finance pursuits like its nuclear program. But in this case, the company argued, the station would primarily serve a different, United States-supported pipeline called the Shah Deniz, which pipes gas from Azerbaijan to Turkey, and thus would reduce reliance on Iranian gas. In fact, according to Botas and Turkish Embassy officials, the opposite was true. A Turkish diplomat, Tuncay Babali, said that back in 2005, when this license was issued, 'the Sivas station was primarily for Iran gas, actually.' And that is still the case today, according to Oguz Zimamoglu, the head of Botas's central gas control unit. 'Primarily the gas flowing from Sivas is Iranian gas,' he said. A Caterpillar spokesman, Jim Dugan, said the company relied on the best information it had in making its application, while OFAC said in a statement that its decision was the product of an interagency review that found that 'notwithstanding an Iranian nexus,' granting the license was in America’s foreign policy interest. In the end, another company won the right to build the station. But Elliott Abrams, who at the time served as the deputy national security adviser and should have been involved in any interagency review, said the fact that Solar Turbines was allowed to bid raises questions about the government’s vetting process. He did not recall any debate on the issue, which he called 'surprising' because 'the issues are significant.'" (New York Times, "Licenses Granted to U.S. Companies Run the Gamut," 12/24/10)

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"Caterpillar, through foreign subsidiaries, sold heavy machinery to independent dealers that resold to users in Iran, where the company's equipment can be found at work in Iran’s oil and gas sectors. In addition, a Canadian subsidiary that Caterpillar acquired in 2008, Lovat, sold tunnel-boring equipment to Iran in the late 1990s for municipal projects, said a spokesman, Jim Dugan. Iran has since constructed tunnel complexes to shelter its uranium enrichment complexes, a fact noted in a letter sent last month to the company by United Against Nuclear Iran (UANI), a group that mounts public pressure campaigns against corporations doing business there. Caterpillar also sells products like armored bulldozers to the United States military. On Feb. 26, the company announced that while its sales to Iran amounted to less than 1 percent of worldwide revenue and complied with American law, it would now go “a step further” by prohibiting its foreign subsidiaries from accepting orders for machines, engines or parts that they know it will end up in Iran."  The company has received $2 billion in benefits and revenue from the US government to pursue business in Iran.  They have since withdrawn their investments in Iran.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

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Caterpillar has performed business in Iran through its wholly-owned subsidiary Lovat, (a Canadian tunnel-boring machine company), and Arya Machinery, which states it is the “exclusive dealer of Caterpillar in Iran.”

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“Caterpillar Inc., of Peoria, Ill., says that under current U.S. sanctions its foreign subsidiaries may, under some circumstances, sell its heavy machinery to independent dealers that resell to users in Iran.

Closely held Arya Machinery, with offices in Tehran, markets itself on its Web site as Iran's exclusive dealer of Caterpillar equipment. A senior sales executive at the company said Arya buys equipment from a Caterpillar subsidiary in Europe.

A Caterpillar spokesman declined to comment about Arya, but said in a statement that Caterpillar has no assets, operations or employees in Iran and is in "full compliance with all applicable laws.” (The Wall Street Journal, "U.S. Enforces Existing Sanctions on Iran," 10/2/09)

Lovat

Lovat, a manufacturer of tunnel boring machines (TBMs) is a wholly-owned subsidiary of Caterpillar acquired in April 2008. (AP, “Caterpillar acquires tunnel boring company,” 4/2/08) Iran has been constructed tunnels to obscure and shield its nuclear program. (The New York Times, “Iran Shielding Its Nuclear Efforts in Maze of Tunnels,” 1/6/10)

Lovat’s business in Iran:

• On its full worldwide contacts list, Lovat lists Mr. Amir Kheradmand of the Tehran-based “Tunnel Boresh Machine” as its main Iran contact. (Company Website)   
• Lovat’s website lists a completed drainage project in Tehran in its “Project section.” The project used a Lovat tunnel-boring machine. (Company Website)
• The December 2009 article World Tunnelling magazine lists two recently completed Lovat tunneling projects for surface water collection in Khayyam and Bahmanyar. Lovat used the same tunnel-boring machine for both projects. (World Tunnelling, “Iranian TBMs continue steady march,” 12/23/09)
  
  

Arya

 “Arya Heavy Machinery (Exclusive dealer of Caterpillar in Iran) has been the Sole authorized representative for the supply of Caterpillar machines, engines, parts and services in Iran since August 18, 2005.” (Company Website) 

The Arya website lists four offices in Iran with its head office in Tehran. (Company Website) 

Arya sells a wide array of Caterpillar power generation equipment and machines in Iran. (Company Website)

Billboard

Listed as an approved vendor in Iran by NIOEC, NPC, NIGCENG, NISOC and SADAF.

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The Toshiba website lists Badr Electric Company as the distributor in Iran. (Company Website)

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"A spokesperson for Toshiba said the company did sell its products in Iran, but decided in 2009 to stop doing business there except for existing contracts and some sales of medical products."  

From 2000-2009, the company was the recipient of $285.2 million US federal funds.  Their business in Iran is currently active but there are no further plans for new investments.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

SonyIran has a website here. 

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According to its Annual Report filed with the SEC for fiscal year 2019: "Sony is aware that certain transactions during the fiscal year ended March 31, 2019, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2019, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 1.4 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.2 million U.S. dollars.
• Sony’s representative office in Tehran, Iran, which was established in 1992, has been closed and has been under liquidation processes since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, Sony engages in certain incidental transactions (for example, permits, taxes, and similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government-owned entities.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2019 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2020, except as described above in connection with the wind-down of its representative office in Iran. Nevertheless, Sony has continued to monitor developments in this area, especially in the light of the United States’ decision that was implemented in its entirety on November 5, 2018 to cease its participation in the Joint Comprehensive Plan of Action of July 14, 2015, among the United States, the United Kingdom, China, France, Russia, Germany, the European Union and Iran and re-impose certain secondary sanctions (i.e., laws and regulations that threaten to impose U.S. economic sanctions on non-U.S. companies engaging in specified transactions with Iran outside U.S. jurisdiction). Sony will determine whether and to what extent they affect Sony’s business with Iranian customers as currently conducted and may additionally be conducted. Such business activities may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such business activities in accordance with applicable laws and regulations.

Sony believes, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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During the fiscal year ended March 31, 2017, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 5.7 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.4 million U.S. dollars.

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According to its Annual Report filed with the SEC for fiscal year 2016: "   

• During the fiscal year ended March 31, 2016, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 4.8 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.3 million U.S. dollars.
• Sony’s representative office in Tehran, Iran, which was established in 1992, has been closed and has been under liquidation processes since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, Sony engages in certain incidental transactions (for example, permits, taxes, and similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government-owned entities."

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According to its Annual Report filed with the SEC for fiscal year 2015: "Sony is aware that certain transactions during the fiscal year ended March 31, 2015, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2015, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers and paper, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 2.9 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.1 million U.S. dollars.       
• Sony’s representative office in Tehran, Iran, has been under liquidation processes and no longer engaged in any operation or activities other than the matters necessary for liquidation since before the beginning of the fiscal year ended March 31, 2014. In the course of liquidation, the office would engage in certain incidental transactions (for example, permits, taxes, and other similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2015 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2016, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for hospitals and health organizations in Iran. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law."

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According to its Annual Report filed with the SEC for fiscal year 2014: "Sony is aware that certain transactions during the fiscal year ended March 31, 2014, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and Sony in particular may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• Before the beginning of the fiscal year ended March 31, 2014, Sony ceased its sales of professional equipment for use in television broadcasting to a third-party-owned dealer in Dubai, except for selling after-sales service parts and providing after-sales service training for such equipment, which were also ceased by the end of May 2013. The third-party-owned dealer in Dubai, to the best of Sony’s knowledge, may have resold such after-sales service parts and provided relevant after-sales services to the Islamic Republic of Iran Broadcasting, which we believe is a parent company of such dealer. During the fiscal year ended March 31, 2014, Sony’s gross revenue from these sales and training was approximately 14,000 U.S. dollars, and Sony has estimated that its net profit from such sales and training was approximately 11,000 U.S. dollars.
• During the fiscal year ended March 31, 2014, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, paper and monitors to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 2.5 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.5 million U.S. dollars.
• During the fiscal year ended March 31, 2014, a non-U.S. subsidiary of Sony closed a dormant bank account at Future Bank B.S.C. in Bahrain. Sony’s non-U.S. subsidiary closed the account in March 2014 and withdrew the remaining balance of the equivalent of 26,000 U.S. dollars, less de minimis fees.
• Sony’s representative office in Tehran, Iran, has been under liquidation processes and no longer engaged in any operation or activities other than the matters necessary for liquidation during the fiscal year ended March 31, 2014. In the course of liquidation, the office may engage in certain incidental transactions (for example, permits, taxes, and other similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2014 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2015, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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Company website lists numerous outlet and retail shops in Iran. (Company Website)

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“Sony Corp. (6758) sold almost $13 million in video and medical equipment to dealers in Dubai that resold the gear in Iran, the company said. The recipients included groups under U.S. sanctions. In a U.S. filing yesterday, Sony said it sold broadcast equipment, security cameras and video-conferencing gear to dealers who planned to resell or resold the products to groups including the Information Technology Department of the Iranian Police and the Islamic Republic of Iran Broadcasting… Sony ‘believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations,’ according to the filing. Penalties or sanctions taken against the company could be material if any government disagrees, Sony said... One dealer was a subsidiary of the Islamic Republic of Iran Broadcasting, Sony said in the filing. The company also reported sales of medical instruments -- including printers, paper and monitors -- it said were intended for the Ministry of Health.  Sony said it made the disclosure under the Iran Threat Reduction and Syria Human Rights Act of 2012 and related amendments to the Securities Exchange Act of 1934.  The company said it registered a profit of about $500,000 from the sale.” (Bloomberg, “Sony Reports Tech Sales to Iran that May Violate Sanctions,” 6/27/13)

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According to its Annual Report filed with the SEC for fiscal year 2013: "Sony is aware that certain transactions during the fiscal year ended March 31, 2013, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and Sony in particular may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

• During the fiscal year ended March 31, 2013, Sony sold professional broadcast equipment, including cameras, switchers, VTRs, monitors and other associated broadcast equipment and media products for use in television broadcasting, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, resold that equipment to the Islamic Republic of Iran Broadcasting, which we believe is a parent company of such dealer. Sony’s gross revenue from these sales was approximately 5.2 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.3 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold medical instruments, including medical printers, paper and monitors to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 4.9 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.1 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold video security cameras and hard disk products to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to the judiciary, Ferdowsi University, Iran Railway, Bank Sepah and Bank Melli in Iran. Such equipment is generally used by purchasers for the purposes of standard building/premises security in fixed locations. During the fiscal year ended March 31, 2013, Sony’s gross revenue from these sales was approximately 2.2 million U.S. dollars, and Sony has estimated that its net profit from such sales was less than 0.1 million U.S. dollars.
• During the fiscal year ended March 31, 2013, Sony sold video conference equipment to third-party-owned dealers in Dubai, which, to the best of Sony’s knowledge, planned to resell that equipment to the Information Technology Department of the Iranian Police. Sony’s gross revenue from these sales was approximately 0.5 million U.S. dollars, and Sony estimates that it recorded a net loss from such sales.

Sony’s small representative office in Tehran, Iran, may engage in certain incidental transactions (for example, permits, utilities, and other similar matters incidental to operating an office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2013 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2014, except for the operation of its representative office and certain transactions through third-party-owned dealers that Sony believes to be intended for the Islamic Republic of Iran Broadcasting and the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

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"In the electronics and home appliances sections, sales of LG and Sony flat-screen televisions come with attractive service plans and free home installations. Local brands, such as Pars, go mostly ignored." (The Washington Post, "Iran hopes to resist sanctions by boosting production," 10/27/2012) 

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"But its population of about 75 million includes a sizeable urban middle class who have been avid consumers of foreign-made goods, including Samsung and Sony electronics and Peugeot cars." (Reuters, "Iran says it will cut imports of non-essential goods," 10/14/2012)

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"Sony has been in Iran since at least 2000 and currently has an office in the country."  From 2000-2009, the company was the recipient of $103.3 million US federal funds.  The company's business in Iran is currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

"ABAN didnt respond to requests for comment. Dan Hong, a lawyer for AT&M, said in an email that AT&M received warnings several months ago of allegations that we have business dealings with Iran. But he said the firm has never heard of ABAN. 'AT&M never signed any contracts with and exported to Iran the specialized metal,' he added. We checked our business records carefully. Records show AT&M supplied the tungsten copper to an intermediary firm called Liaoning Industry & Trade Co. Ltd. That firm couldnt be reached for comment." (The Wall Street Journal, "Fresh Clues of Iranian Nuclear Intrigue," 1/16/09)

• the website, iran-bosch.com, features the sanction-designated Iranian financial institution, Bank Mellat.

• BOSCH is advertised as a Partner of the Iranian firm, Ezam Automotive Parts Group (“EZAM”), “The Largest Auto Parts Manufacturer in Iran.” According to the EZAM website, “Obtaining reliable licenses and establishing technical cooperation with the latest technologies from world’s recognized brands such as MANDO, MAHLE, BOSCH… are some of the Ezam Group’s achievements…”

• One of the senior officials of Germany`s Bosch Auto Spare parts company announced that the company sought to expand its business in Iran and its priority was to domestic production in the country. (February 13, 2018).

• On March 5, 2017, the Tehran Times conducted an exclusive interview with CEO Robert Bosch, who said, “[r]esources of Iran and Germany are amazing, so we are looking for partners for cooperation….  [W]e see huge potential and after the trip we will try to make plan for the further cooperation.”  (Tehran Times, “Robert Bosch Foundation Seeking Partners in Iran – CEO,” 3/5/2017). 

• Bosch Group opened an office in Tehran in 2016 as the group’s automotive division “sees growing potential in Iran’s car market following the lifting of international sanctions.”
• Bosch is listed as a company participating as part of the German delegation visiting Iran September 27-28,2016. (Participating Companies).
• "'Companies are already trying to sign letters of intent with Iranian trading partners to get a foot in the market,' said Juliane Emami, project manager at conference organizer Management Circle AG... Some industrial giants such as automotive parts producer Bosch GmbH, which signed its first contract, are already venturing back. ‘We've already signed our first contracts,’ said spokeswoman Trix Böhne. 'But this is all at very early stages and we will have to see how things develop.'" (The Wall Street Journal, "German Business Looks to Renew Iran Contracts," 8/3/14)
• According to Bosch's Turkey website, the Bosch representative in that country provides services to Bosch units and divisions both “in Turkey and Iran.” (Bosch Turkey Website, “Our Company: Representative of Turkey”)
• The Bosch Packing Technology division lists a local Iran agent on its website. (Bosch Packing Technology Website, “Your Bosch Packaging Technology Contact: Iran”) 
• Bosch's subsidiary, Bosch Power Tools, lists Abzarsara Co. as its Iran dealer while the Abzarsara Co. website advertises Bosch products and lists Bosch as a supplier. (Bosch Power Tools Website, “Bosch dealer”; Abzarsara Co. Website, “Home”; Abzarsara Co. Website, “Suppliers”)
• Bosch's subsdiary, Bosch Rexroth, maintains a relationship with Iran through the Iranian company Narvan Arra Ltd. (Bosch Rexroth Website, “Contact Service Hydraulics: Iran”).  On its Company Website, Narvan Arra states that “as the Sole Distributor and Service Partner for the entire Bosch Rexroth Group, [it] provides high quality components, modules or complete system solutions for Bosch Rexroth in Hydraulics, Pneumatics, Service Automation, Electric Drives and Controls, Linear Motion and Assembly Technology.” (Narvan Arra Website, “Homepage”) Rexroth AG manager Wolfgang Paul Rexroth is listed as a member of the German-Iran Chamber of Commerce election committee. (AHK Website, “AHK Iran: Board Elections”)
• "Dozens of European businesses have visited the country in recent months in anticipation of a thaw in relations over Iran’s nuclear programme that could rehabilitate the oil-rich country as a destination for business investment. Iranian and western businessmen say some tentative deals have been prepared, ready for signature once the interim nuclear agreement struck in Geneva last month is implemented…Bosch, the German technology and services conglomerate, said it was 'carefully monitoring current developments' in Iran. 'In general, we see good potential opportunities for our business, provided that the future political and legal framework will make this possible without restrictions,' it added." (Financial Times, "Merck tests ground for Iran partnership to produce medicines," 12/26/13)
• "Bosch, a supplier of building and industrial technology and consumer goods, markets its products in Iran through contract partners, according to its website, but does not have an office in Iran. 'We're doing very little business and this is handled through Turkey,' said Christian Fromek, a company spokesman. 'Our businesses have a civil purpose in providing auto components as well as consumer goods, such power tools and spark plugs. All of our activities respect current regulations in place.'"  The company has received $90.3 million in revenue and benefits from the US government for their investments in Iran during 2000-2009.  The company's activities in Iran are currently active.  (The New York Times, "Profiting from Iran, and the US," 3/6/2010)
• "GIANTS WITH A FOOT IN TEHRAN: Total, Shell, Statoil, BNP Paribas, Commerzbank, MTN, UPS, Linde, Technip, Nokia, Ericsson, Peugeot, Renault, OMV, Societe Generale, ENI, Mitsubishi, Sumitomo, Siemens, LG, Samsung, Bosch, Valeo, Nestle, Unilever, BAT, Japan Tobacco." (The London Times, "American pressure threatens UK firms," 5/27/06)

"We have banned sales to and have no operational sites or employees in Iran. Previous to May 2018, certain limited sales were made in accordance with international agreements and sanctions." (Atlas Copco website)

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Atlas Copco is listed on the March 1, 2022 report to the New Jersey Legislature Iran Divestment as a prohibited company.

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Atlas Copco, headquartered in Nacka, interrupts its business with Iran. 
This, according to President Trump's message that the United States imposes sanctions on the country. "We have been following developments continuously and have made this decision," said Sara Liljedal, Press Manager at Atlas Copco. (Nackajätte bryter med Iran (Trump Effect – Nacka giant breaks with Iran),” Mitti (Sweden), August 7, 2018.) 

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In 2017, the U.S. state of Iowa listed Atlas Copco on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Atlas Copco ineligible for investment and/or state contracting.

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According to the Atlas Copco website, “Atlas Copco has appointed a distributor and will use this company as a vehicle for expansion on the Iranian market.”  Atlas Copco Website, “Complex markets: Iran”

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"Atlas Copco has had a branch in Iran for the past 30 years, according to Senior Vice President Hans Sandberg. The company primarily sells compressors, mining and construction equipment and services there, with sales of about $15 million to $20 million a year, he said. The company has received contracts from several United States federal agencies, including the Fish and Wildlife Service to the Department of Defense."  The company received $9.2 million in benefits and revenue from the US government for their investments in Iran, during 2000-2009.  Their business in Iran is currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010)

The Iranian Tamkar Gas Equipment Company states on its website that it and a consortium of foreign companies, including Swiss GreenField and German MAN group, signed a contract in 2003 to provide equipment for 57 compressed natural gas refueling stations. According to Tamkar's website, the company is manufacturing the CNG refueling stations under GreenField's license. GreenField notes on its website that it was purchased by Atlas Copco in March 2007 and continues to operate within the Atlas Copco family.

In 2005, another company, Intermech Ltd. was acquired by Atlas Copco South Pacific Holdings Pty Limited of Australia. Through its relationship with Atlas Copco, the company lists an office in Tehran on its website.

According to the government of New Zealand, Intermech Ltd. and Iranian Pars Compressor Co. won a $20 million joint contract in August 2003 from the Iran Fuel Consumption Optimization Organization to build CNG refueling stations throughout Iran. According to a company press release, Intermech shipped 25 packages of equipment to Iran in April 2009; the "order was a follow up after the first successful shipment of 50 packages in 2008."

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Atlas Copco has an Iran portal and lists that it has an office in Tehran, Iran on its company website.