BRITISH AMERICAN TOBACCO P.L.C.

"B.A.T. [British American Tobacco] said it now makes cigarettes for export to Iran in Turkey. (USA Today, "From bull semen to bras, Iran still buys American," 7/9/08) (http://www.usatoday.com/news/washington/2008-07-08-350908565_x.htm)

Lists British American Tobacco Pars in Tehran, Iran on its company website. (http://www.bat.com/group/sites/UK__9D9KCY.nsf/vwPagesWebLive/DO9FCLZ4)

"GIANTS WITH A FOOT IN TEHRAN: Total, Shell, Statoil, BNP Paribas, Commerzbank, MTN, UPS, Linde, Technip, Nokia, Ericsson, Peugeot, Renault, OMV, Societe Generale, ENI, Mitsubishi, Sumitomo, Siemens, LG, Samsung, Bosch, Valeo, Nestle, Unilever, BAT, Japan Tobacco." (The London Times, "American pressure threatens UK firms," 5/27/06) (http://business.timesonline.co.uk/tol/business/economics/article727079.ece)

Concerning the business of BAT Pars, various elements such as income tax, payroll, social security, other taxes, excise, monopoly fees, duties and other fees, including for utilities, licences and judicial fees to commence litigation, are payable to the Government of Iran and affiliated entities regarding BAT Pars’ operation. BAT Pars maintains bank accounts in Iran with various banks to facilitate its operations in the country and to make any required payments, as described above, to the Government of Iran and affiliated entities regarding its operations.

Speaking at a press briefing on May 17, Afzali said that Japan Tobacco International (JTI) and British American Tobacco (BAT) control more than 61 percent of sales and some 70 percent of the value of the cigarette market in Iran. Afzali estimated that JTI and BAT supplied 46 billion cigarettes to Iranian consumers in the calendar year to late March." (Tobacco Reporter, "Foreign Firms Dominate Iranian Cigarette Market," 5/18/21) (https://tobaccoreporter.com/2021/05/18/itc-foreign-companies-dominate-iranian-cigarette-market/)

"Despite recent gains by Iranian Tobacco Co. (ITC), multinationals continue to dominate the Iranian cigarette market, according to a report by PressTV, citing ITC CEO Siavash Afzali.

As of August 27, 2019, British American Tobacco is listed on the Illinois Investment Policy Board list of Iran restricted companies. (https://www2.illinois.gov/sites/iipb/Pages/ProhibitedInvestmentList.aspx)

During the year ended 31 December 2019, BAT did not have any gross revenues or net profits derived from transactions with the Government of Iran or affiliated entities.

According to its Annual Report filed with the SEC for fiscal year 2019: "BAT has a local operation in Iran, established on 18 October 2003, through its wholly-owned non-US subsidiary, B.A.T. Pars Company (Private Joint Stock) (BAT Pars). BAT Pars produces its products, which include Kent, Pall Mall and Montana brands, in its own factory in Eshtehard, which is in the Alborz province of Iran. BAT Pars distributes its product via 75 sub-agents with national and provincial distribution licences, who sell products to wholesalers and retailers with the support of BAT Pars’ sales representatives. BAT Pars has 307 direct employees and an additional 1,159 contract workers supplied by a private company. (https://www.sec.gov/Archives/edgar/data/1303523/000119312520086441/d852737d20f.htm)

BAT believes, and maintains policies and procedures designed to ensure, that its activities in Iran and elsewhere comply in all material aspects with the applicable and relevant trade sanctions laws and regulations, including US and other international trade sanctions and/or embargoes. BAT’s sanctions policies and procedures have been designed to be as robust as possible. However, there can be no absolute assurance that these policies and procedures will be effective. Were they to be ineffective, penalties or sanctions could be imposed against BAT, which could be material. To the extent permitted under applicable law, and as long as it continues to meet BAT’s risk management and operational requirements, BAT Pars’ activities in Iran are expected to continue."

Dec 2016 Subsidiary filings with SEC lists B.A.T. Pars Company as its subsidiary. (https://www.sec.gov/Archives/edgar/data/1303523/000119312517168591/d352136dex211.htm)