Putrajaya Management Sdn Bhd

On June 1, 2020, the Ohio Police & Fire Pension Fund (“OP&F”) listed Putrajaya Management on its scrutinized companies Iran/Sudan list.   On September 24, 2008, OP&F adopted an Iran and Sudan Divestment Policy, which notes, “[t]he purpose of this Policy is to divest and restrict the purchase of stocks and bonds (“direct holdings”) issued by a publicly traded Company… with “scrutinized active business operations” in Iran and Sudan.”   (https://www.op-f.org/Files/Scrutinized Companies Iran Sudan.pdf)

Putrajaya is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list. (http://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB%20Iran%20Divestment%20List%203-31-19.pdf)

As of December 31, 2019, the Alaska Retirement Management Board lists Putrajaya Management as a company doing material business with Iran.   (https://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB Iran Divestment List 12-31-19.pdf)

On March 18, 2014, Putrajaya 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, Putrajaya 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)

In 2020, the U.S. state of Mississippi listed Putrajaya 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)

Putrajaya is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list. (http://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB%20Iran%20Divestment%20List%206-30-19.pdf)

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In 2014, 2015, 2016 and 2017 Putrajaya Managements was listed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code.   (https://comptroller.texas.gov/purchasing/publications/divestment.php)

In 2017 the U.S. state of Alaska, Florida, Mississippi, listed Putrajaya Management on its list of companies doing material business with Iran rendering Putrajaya Management ineligible for investment and/or state contracting. (http://treasury.dor.alaska.gov/Portals/3/docs/ARMB%20Iran%20Divestment%20List%2012-31-17.pdf) (https://www.sbafla.com/fsb/Portals/FSB/Content/GlobalGovernanceMandates/QuarterlyReports/2017/Global_Governance_Mandates_and_Florida%20Statutes_2017_12_13.pdf?ver=2017-12-13-145507-737) (http://www.dfa.ms.gov/media/4100/companies-posted.pdf)

On March 13, 2019, the Mississippi Department of Finance & Administration identified Putrajaya Management as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.”   (https://www.dfa.ms.gov/media/8124/businesses-doing-business-with-iran.pdf)

In 2018 the U.S. state of Iowa, Ohio listed Putrajaya Managements an Iran restricted company rendering Putrajaya Management ineligible for investment and/or state contracting. (https://www.ipers.org/sites/default/files/media/2017%2009%20Iran%20Prohibited%20Companies%20List%2009-30-17.pdf) (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf)

On June 8, 2017, the Protecting Florida’s Investments Act (“PFIA”) was signed into law. The PFIA requires the State Board of Administration (“SBA”), acting on behalf of the Florida Retirement System Trust Fund (“FRSTF”), to assemble and publish a list of “Scrutinized Companies” that have prohibited business operations in Sudan and Iran. Once placed on the list of Scrutinized Companies, the SBA and its investment managers are prohibited from acquiring those companies’ securities and are required to divest those securities if the companies do not cease the prohibited activities or take certain compensating actions. As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list Putrajaya Management on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector.”  (https://www.sbafla.com/fsb/Portals/FSB/Content/GlobalGovernanceMandates/QuarterlyReports/2020/Global_Governance_Mandates_and_Florida Statutes_2020_05_28.pdf?ver=2020-05-28-122524-540)

Putrajaya is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business. (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2019_06_04_Web_Update_PFIA_Prohibited_List.pdf?ver=2019-06-04-162911-617) (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2019_07_12_Web_Update_PFIA_Prohibited_List.pdf?ver=2019-07-12-114201-343)

On January 13, 2020, the South Dakota Investment Council submitted a report to the Executive Board of the Legislative Research Council regarding compliance with SDCL 4-5-48 to 4-5-60, Iran Divestiture. Included in this report is an Iran Scrutinized Companies list of all prohibited investments for which the internal managers and direct external managers are instructed not to purchase any company on the list. Putrajaya Management is included on this list.   (https://sdlegislature.gov/docs/referencematerials/requiredreports/RR901152020.pdf)