Sinopec Shanghai Petrochemical Co Ltd

According to its Annual Report filed with the SEC for fiscal year 2019: "We have sourced a small portion of our crude oil from Iran in the past through Sinopec Corp., our current controlling shareholder, and independent third parties, and Iran may continue to be the ultimate source of a small portion of our crude oil. In addition, Sinopec Corp. and Sinopec Group, the controlling shareholder of Sinopec Corp., have engaged in operations in or purchasing crude oil sourced from Iran and may continue to do so in the future. We have no control over the activities of Sinopec Group or Sinopec Corp. in connection with any activities that they may conduct in Iran." (https://www.sec.gov/Archives/edgar/data/908732/000119312520122219/d868834d20f.htm)

According to its Annual Report filed with the SEC for fiscal year 2012: "In 2012, we sourced a small amount of crude oil from Iran through a wholly-owned subsidiary of Sinopec Corp., our controlling shareholder, and such amount represented 6.3% of our total purchase volume of crude oil in 2012. Details of our 2012 purchase volume and purchase expenses are provided below. In addition, based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group, directly or indirectly, engaged in a small amount of business activities in Iran such as providing engineering support and designs. Sales revenue from these business activities accounted for 0.08% of Sinopec Group’s total unaudited sales revenue in 2012. No profits were generated from these business activities in 2012. We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2013." (https://www.sec.gov/Archives/edgar/data/908732/000119312513184178/d522439d20f.htm)

On September 19, 2007, Sinopec Shanghai was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Sinopec Shanghai remains on the SBA list of prohibited investments.  (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2021_03_09_Web_Update_PFIA_Prohibited_List.pdf?ver=2021-03-09-134849-587)

According to its Annual Report filed with the SEC for fiscal year 2013: "In 2013, we sourced a small amount of crude oil from Iran through a wholly-owned subsidiary of Sinopec Corp., our controlling shareholder, and such amount represented 7.04% of our total purchase volume of crude oil. Details of the purchase volume and purchase expenses are provided below.  (https://www.sec.gov/Archives/edgar/data/908732/000119312514168868/d717414d20f.htm)

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We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2014."

In addition, based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group, directly or indirectly, engaged in a small amount of business activities in Iran such as providing engineering support and designs. Sales revenue from these business activities accounted for 0.0015% of Sinopec Group’s total unaudited sales revenue in 2013. No profits were generated from these business activities in 2013.

According to its 2018 Annual Report filed with the SEC in April 2019: "We have sourced a small portion of our crude oil from Iran in the past through Sinopec Corp., our current controlling shareholder, and independent third parties, and we may continue to purchase crude oil from Iran. In addition, Sinopec Corp. and Sinopec Group, the controlling shareholder of Sinopec Corp., have engaged in operations in or purchasing crude oil sourced from Iran and may continue to do so in the future. We have no control over the activities of Sinopec Group or Sinopec Corp. in connection with any activities that they may conduct in Iran...In addition, purchase of crude oil by Sinopec Corp. subsidiaries that supply us with raw materials may from time to time be sourced from National Iranian Oil Company. This entity has been identified by the U.S. government as an SDN and sanctioned under various laws, including for assisting the government of Iran to avoid sanction and for engaging in activities related to nuclear proliferation. Under Executive Order 13846, the U.S. President can sanction non-U.S. companies that engage in transactions with SDNs such as the National Iranian Oil Company.... It is possible that Sinopec Group or its affiliates engage in activities that are targeted for sanction purposes by the ISA or other U.S. laws. Based on feedback to our inquiries to Sinopec Group, the controlling shareholder of Sinopec Corp., Sinopec Group engaged in limited business activities in Iran such as providing engineering services and designs. We have no performance obligations under any contract to continue to purchase crude oil sourced from Iran in 2019." (https://sec.report/Document/0001193125-19-124886/d695706d20f.htm)

In 2020, the U.S. state of Mississippi listed Sinopec Shanghai on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting. (https://www.dfa.ms.gov/media/sd1ccddh/businesses-doing-business-with-iran-12-4.docx)

Sinopec Shanghai is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies. (https://www.lrl.mn.gov/docs/2021/mandated/210295.pdf)

Sinopec Shanghai has filed Iran Notices with the SEC from 2013 - 2020.  (https://www.sec.gov/cgi-bin/browse-edgar?action=getcompany&CIK=0000908732&type=iran&dateb=&owner=include&count=40)