LyondellBasell

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)