Orange

According to its Annual Report filed with the SEC for fiscal year 2019: "Orange conducts limited business in Iran, all of which relates to telecommunications. The total revenue from these activities constitutes much less than 1% of the Group's consolidated revenue in 2019. Section 13 (r) of the United States Exchange Securities Act of 1934 requires an issuer to disclose in its annual or quarterly reports, as applicable, certain activities, including certain transactions or dealings relating to the “Government of Iran” as defined under § 560.304 of the Iranian Transactions and Sanctions Regulations (31 C.F.R. Part 560). Disclosure may be required even where the activities, transactions or dealings are conducted outside the United States by non-U.S. affiliates in compliance with applicable law and regardless of whether the activities are sanctionable under U.S. law.

In compliance with the Section 13(r), Orange is disclosing that Orange’s Enterprise operating segment provided (through indirect, wholly-owned subsidiaries of Orange SA) telecommunication services to certain international public organizations and multinationals in Iran. These telecommunication services represented in 2019 gross revenues of approximately 3.3 million euros and a net profit of approximately 0.3 million euros. Orange intends to continue carrying out these activities."

--

In 2017, CalSTRS designated Orange SA as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Orange after confirming the company had curtailed its ties to Iran and reviewing the company’s internal controls.

--

In 2017 the U.S. state of California listed Orange as a company under review for reportedly providing consulting services to Iranian government owned companies.

--

"Sofrecom, an indirect wholly-owned subsidiary of Orange S.A. that is incorporated in France provides consulting services in the telecom field, including with respect to networks and marketing. In 2016, Sofrecom provided certain services to and/or engaged in transactions with ZAIEM, MCCI, TCI, NAK and MobinNet which fall or may fall within the definition of the government of Iran. Globecast, an indirectly, wholly-owned subsidiary of Orange SA that is incorporated in France, operates a global satellite and fiber network to manage and transport video and other media of its customers for delivery to direct-to-home satellite platforms:  cable, IPTV, mobile and broadband head-ends. Following the waiver of certain sanctions against the Islamic Republic of Iran Broadcasting (IRIB) in February 2014, and while IRIB remains a specially designated national (SDN), Globecast entered into two satellite broadcast agreements with the IRIB ending respectively on June 9, 2017 and July 31, 2018 (agreements subject to renewal).Telecommunication services are provided by the Enterprise operating segment (through indirect wholly owned subsidiaries of Orange SA) to certain international public organizations and multinationals in Iran solely to carry out telecommunications services that are otherwise authorized." (2017) 

--

"French telecoms network operator Orange will continue to see slow growth in revenues in the Middle East and Africa this year, its regional business chief said. The company sees the region as key to its future, especially since it sold its mobile operations in Britain and Switzerland, but is struggling to turn it into a strong growth driver as talks with a potential partner in Iran drag on and economic conditions in some African markets remain challenging... Talks with Iran's largest mobile operator, Mobile Telecommunication Company of Iran (MCI), meanwhile are 'very far' from reaching a final agreement, Mettling said. The discussions, which were revealed last year, first aim at a commercial agreement. 'It's very long, it's very slow, it's very complicated,' Mettling said." (Reuters, "Orange Sees More Slow Growth in Middle East," 2/28/2017).

--

"Paris Ambassador to Tehran François Sénémaud announced that the French-based satellite provider, Eutelsat, plans to win [a] contract with Iran to build a satellite for the country. "The Eutelsat company seeks cooperation with the Iranian Space Agency and is preparing a draft of its proposals to participate in the tender for build a satellite," Sénémaud said in a meeting with Iranian Communications and Information Technology Minister Mahmoud Vaezi in Tehran on Saturday. He said that Eutelsat and the French telecommunications operator, Orange, are also in talks with the Iranian firms to increase mutual cooperation." (Fars News, "French Envoy: Eutelsat Eager to Send Offer to Iran Satellite Tender," 10/26/2016).

--

Sources: 

Orange is listed as a speaker at the 2016 Iran Connect Conference that took place from September 6-7 in Tehran, Iran. The conference brought together international telecom companies looking to access the Iranian market. (Iran Connect Brochure, 2016).

--

"France’s Orange SA has entered preliminary talks to buy a piece of Iran’s largest cellular operator in what would mark the first acquisition of a stake in a major Iranian firm by a Western company since nuclear sanctions were lifted in January. Orange, France’s largest telecom company, is one of several European companies that have held discussions about taking a stake in Mobile Telecommunication Co. of Iran, according to people familiar with the matter. The names of the others couldn’t immediately be learned... The Paris-based company is discussing a commercial and technical agreement as well as a share purchase, the people said. Orange, which is 23%-owned by the French government, is navigating difficult straits as Iran strains to open its markets up to the West. It needs to squeeze financing for a potential deal out of Western banks that are fearful of being hit by remaining U.S. sanctions. In addition, MCI’s parent company, Telecommunication Co. of Iran, or TCI, is owned by a group of companies that in some cases lead back to Iran’s Revolutionary Guards Corps, a paramilitary force that runs large swaths of the Iranian economy and remains under U.S. sanctions for its alleged involvement in terrorism, an accusation it denies... Orange has been planning its move into Iran for years. Its consultancy unit, Sofrecom SA, has provided technical assistance to TCI and advised its management since at least 2014, according to invoices reviewed by The Wall Street Journal." (Wall Street Journal, "French Carrier Pursues Stake in Iranian Wireless Firm," 08/31/2016).

--

“Temporary sanctions relief hasn’t yet translated into an economic turnaround in Iran. But at the Melal Hotel, business hasn’t been this good in years...two managers from French telecommunications company Orange SA stayed at the Melal, which is nestled on a quiet street of the Valiasr business district and offers suites appointed with engraved copper fireplaces and embroidered Persian sofas…Businesses exploring the Iranian market ‘do so at their own peril right now,’ U.S. President Barack Obama said last month, ‘because we will come down on them like a ton of bricks.’ But that hasn’t stopped companies from boosting their presence or sending in advance teams—essentially making exploratory visits in the hopes that sanctions may be lifted further and permanently...An Orange representative said its executives visited Tehran recently with an eye toward offering consulting services to Iranian phone companies.” (Wall Street Journal, “As Iran Sanctions Ease, Western Firms Seek a Way In,” 3/27/14)

--

“A delegation of more than 100 French companies is set to visit Tehran on Monday in the biggest demonstration of western business interest in Iran for more than a decade. The three-day visit, which includes top French companies such as oil major Total, engineer Alstom, telecoms group Orange and carmaker Renault, has raised hopes in Iran that an interim deal on its nuclear programme could lead to a return of foreign investment. This was sharply curtailed after sanctions were imposed in retaliation for Tehran’s perceived bid to acquire nuclear weapons. Although France has adopted a tough stance against Iran’s nuclear programme, it is also moving quickly to position French business to take advantage of last month’s potential opening up of a big new market for its companies.” (Financial Times, “French business delegation aims for early bird advantage in Iran,” 2/2/14)

--

In its January 24, 2014 20-F/A form submitted to the USA Securities Exchange Commission, Orange disclosed that “Orange conducts limited business in Iran, all of which relates to telecommunications.  The total revenue from these activities constitutes much less than 1% of the Group's consolidated revenue in 2012.  Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 requires an issuer to disclose in its annual or quarterly reports, as applicable, certain activities, including transactions or dealings relating to the government of Iran. Disclosure is required even where the activities, transactions or dealings are conducted outside the United States by non-U.S. affiliates in compliance with applicable law, and whether or not the activities are sanctionable under U.S. law.  In compliance with the Iran Threat Reduction, Orange is disclosing the following matters:

•Sofrecom, an indirect wholly-owned subsidiary of Orange S.A. that is incorporated in France provides consulting services in the telecom field, including with respect to networks and marketing.  In 2012, Sofrecom provided certain services to MCCI and TCI, which fall within the definition of the government of Iran.  The gross revenue in connection with these activities in 2012 was approximately €4.9 million and the estimated net profit was approximately €1.2 million.  Sofrecom intends to continue to provide its services.

•Globecast, an indirectly, wholly-owned subsidiary of Orange S.A. that is incorporated in France, operates a global satellite and fiber network to manage and transport video and other rich media of its customers for delivery to direct-to-home satellite platforms:  cable, IPTV, mobile and broadband headends.  In 2012, Globecast provided certain services to the Islamic Republic of Iran Broadcasting (IRIB).  Globecast promptly took steps to terminate the contracts and services after the IRIB was placed on a list of “specially designated nationals” in early 2013.  Globecast has since terminated all contracts with the IRIB.  The gross revenue attributable to Globecast’s activity with the IRIB was €5,566,698 in 2012, with an estimated net profit of approximately €1.03 million.

•Equant S.A., a French company that is an indirectly wholly-owned subsidiary of Orange S.A.  procures certain network capacity from the Telecommunications Company of Iran solely to carry out telecommunications services that are otherwise authorized.  Equant S.A. intends to continue procuring network capacity in order to carry out these activities; the procurement of network capacity represents no revenue and no net profits.” (USA Security Exchange Commission, "FORM 20-F/A-Orange" 1/24/14)