Ingram Micro

According to its Annual Report filed with the SEC for fiscal year 2015: "During the year ended January 3, 2015, we learned that Ingram Micro Germany, one of our wholly-owned non-U.S. subsidiaries, made one sale during the year ended January 3, 2015, to an individual who received delivery of the sale at a German subsidiary of an Iranian company. The individual is not included on the Specially Designated Nationals and Blocked Persons List maintained by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) with the identifier “[IRAN]”, however, the German company is included on that list. This sale consisted of a single graphics card resulting in revenue to us of approximately $.045, with net profits of substantially less than that. The sale appears to be the result of human error and was not made with any intent to violate our policies and procedures or any applicable laws. However, the sale was conducted in contravention of Ingram Micro’s export control and sanctions policies, which prohibit Ingram Micro and its affiliates from conducting any activities, transactions or dealings with Iran or Iranian counterparties, including the Government of Iran. In connection with our discovery of the above-described sale, we have increased compliance resources and training intended to prevent such activity from recurring. We have voluntarily notified OFAC of the sale and intend to cooperate fully with OFAC."