Automotive

According to its Annual Report filed with the SEC for fiscal year 2014: "In connection with certain activities that could not be finalized on or before March 8, 2013, ITT received a Special License from OFAC in June 2014 in order to conclude a settlement with an agent associated with Bornemann’s Iranian activities. The settlement agreement has been finalized and payments totaling Euro 770 thousand were made to the agent in 2014."
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According to its Annual Report filed with the SEC for fiscal year 2012: "On November 28, 2012, ITT acquired all the shares of Bornemann, a manufacturer of pumps and systems utilized in the oil & gas, marine, food and pharmaceutical industries, headquartered in Germany. In accordance with U.S. regulations prohibiting business with Iran by U.S. persons and their owned or controlled non-U.S. affiliates, Bornemann agreed in connection with its acquisition by ITT to terminate all contracts with companies in Iran, which agreement was memorialized in the Share Purchase Agreement. Bornemann sent contract termination notices having immediate effect to those companies on November 28, 2012.

Following issuance of the termination notices, Bornemann received from Oil & Energy Industries Development Q. Co. (OEID), a prepayment of approximately €670,000 for future services under one of the terminated contracts. The terminated contract involved an adaption and start-up of pump systems that Bornemann had shipped prior to its acquisition by ITT.

On December 26, 2012, the Office of Foreign Assets Control of the U.S. Department of the Treasury (OFAC) issued a General License authorizing foreign subsidiaries of U.S. companies through March 8, 2013, to wind down any ongoing transactions or dealings involving Iran that would otherwise be unlawful under ITRA Section 218, which extended the U.S. sanctions against Iran to non-U.S. entities owned or controlled by U.S. companies. Pursuant to the General License, and in an effort to resolve and mitigate the issues surrounding termination of the contract, Bornemann will be performing certain wind-down services under the terminated OEID contract. Profit from these activities will not be known until the end of the first quarter of 2013. Upon expiration of the permissible wind-down period on March 8, 2013, Bornemann will not provide any goods or services in Iran or related to the terminated contract."

According to its Annual Report filed with the SEC for fiscal year 2012: "Prior to the enactment of ITRSHRA, we had a longstanding policy of reviewing and determining that any matter relating to possible transactions involving Iran did not violate applicable U.S. export controls and sanctions laws, and we do not believe that we have conducted any transactions that violated applicable laws. During 2012, certain of our non-U.S. affiliates engaged in transactions involving Iran in accordance with applicable law. Our non-U.S. affiliates have ceased transactions involving Iran as of October 9, 2012, as required by ITRSHRA.

Prior to October 9, 2012, some of our non-U.S. affiliates sold items out of general inventory to non-U.S. distributors outside of Iran, who sold those items to retail or automotive assembly, service, or repair establishments in Iran. The sales made to these non-U.S. distributors of items that were subsequently resold into Iran totaled approximately $3.7 million and generated operating income of approximately $0.7 million. In 2012, our non-U.S. affiliates received payments of approximately $2.7 million related to these sales. The items were all non-U.S. origin automotive components which, if exported from the United States, would not have required a U.S. export license (except for direct export to Iran and certain other very limited destinations or entities).

Our non-U.S. affiliates received payments from the distributors through banks outside of Iran. However, some of those transactions may have involved transfers of funds to the distributors through Iranian Government-owned banks, and we are not certain of the exact path of such transfers, and whether those transactions are therefore required to be disclosed under Section 13(r)(1)(D)(iii) or otherwise of the Securities Exchange Act of 1934. The transactions disclosed herein were not prohibited under any U.S. export controls and sanctions laws at the time the transactions were undertaken because they were not conducted by U.S. persons or entities, did not involve ten percent (10%) or more U.S.-origin content, and were not otherwise prohibited."

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

Dowin International Corp (“Dowin”), was listed as a participant at the 16th International Exhibition of Transportation Urban Services & Related Industries (“ITUF”), which took place at the Tehran International Permanent Fairground from January 2-5, 2019. (ITUF 2019, “Exhibition Profile”).

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Dowin lists a distribution channel in Iran on its company website. 

Endress+Hauser is featured on the website of the Iranian firm, DIBAGARAN FARAYAND (DIFACO).

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Iranian oil, gas, petrochemical and power industries services company Petrokalooj cites Endress+Hauser as a supplier on its website.

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Endress+Hauser lists Iranian company Arya Instrument in Tehran, Iran on the Endress+Hauser website.

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Endress+Hauser logo appears on the webpage of the Iranian firm, Pars Akam Energy (“Pars Akam”).  (Pars Akam Website, “Home”).  

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The Iranian firm, Raya Tosee Tajhiz Paya (“Raya Tosee”), claims to be an authorized agent of Endress & Hauser in Iran.  (Raya Tosee Website, “Home.”).

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Iranian company Hirbodan Sanat Paj (“Hirbodan”), according to its website, appears to have commercial ties with Endress+Hauser (http://hirbodanco.com/en/products/). 

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According to its website, Amitis is an authorized representative for Endress+Hauser in Iran. (http://amitistech.com/endress-hauser/).

DENA teccon GmbH (“DENA teccon”) is listed as a participant in the 12th Auto Parts International Fair 2017 (“IAP Fair”), which took place in Tehran, Iran on November 13-16, 2017. (IDRO Fairs Website, “IAPEX 2017 – List of International Participants”).

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DENA teccon helps bring poromembrane filtration technology to China, Turkey, and Iran. (8/12/2016).

Iranian company Pasargad Machine Persia Jonoubsells Bomag products on its company website. 

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Bomag GmbH (“Bomag”), was listed as a participant at the 16th International Exhibition of Transportation Urban Services & Related Industries (“ITUF”), which took place at the Tehran International Permanent Fairground from January 2-5, 2019. (ITUF 2019, “Exhibition Profile”).

References to Rockwell Automation brand Allen-Bradley appear on the website of the Iranian energy and gas services provider, Fars Scout.

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According to their official website, Nirou Taban is working in the Oil, Gas, Petrochemical and Energy Industries, an industry controlled by Iran’s Islamic Revolutionary Guards (“IRGC”) (Nirou Taban Website, “Home”), and has business ties with Allen Bradley Rockwell.

Lagermax Lagerhaus und Speditions AG (“Lagermax”) was included among the list of “Partners, Sponsors & Participants” of the 4th Iran Automotive Industry International Conference in Iran (“IAIIC”), which took place at the International Conference Center in Tehran’s Milad Tower on February 12-13, 2017. (IAIIC, “4th Iran Automotive Industry International Conference”).

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The Austrian forwarding company Lagermax has resumed its service to Iran and now offers weekly departures from Salzburg to that country in collaboration with its Teheran-based partner Teen International Transport. (7/31/2015)

According to its website, Kishan has a global reach to Iran. 

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Kishan Auto attended IAPEX in 2018, according to the exhibitors list. (IAPEX 2018 Website, “Exhibitors List”).