Eaton

Eaton has received over $2 billion in US government contracts over the past decade. (http://www.usaspending.gov/search?query=&searchtype=&formFields=eyJSZWNpcGllbnROYW1lTGNhc2UiOlsiRWF0b24gQ29ycG9yYXRpb24iXX0=)

Eaton Corporation plc (“Eaton”), particpiated in the Iran Trade and Investment Forum (the “Forum”) that took place at the Steigenberger Hotel in Berlin, Germany on January 23-24, 2018. (C5 Group, “Iran Trade and Investment Forum”). (https://www.c5-online.com/iran-trade-investment-forum/wp-content/uploads/sites/1464/2017/09/500L18_WEB.pdf)

According to its Annual report filed with the SEC for fiscal year 2017: "During the fourth quarter, we engaged in one transaction requiring disclosure under Section 13(r). On October 23, 2016, our wholly-owned non-U.S. subsidiary sold a plastic panel board to Pars Petrochemical Company, which is owned by the government of Iran. We received total net revenue of approximately 1,311 Euros and realized net profits of approximately 392 Euros from the sale (approximately $1,426 and $426, respectively, at the exchange rates for U.S. dollars at the date of the sale transactions). One or more of our non-U.S. subsidiaries intend to continue doing business in Iran under General License H in compliance with U.S. economic sanctions and export control laws, though the Company has no assets or employees in Iran." (https://www.sec.gov/Archives/edgar/data/1551182/000155118217000014/etn12312016form10-k.htm)

Eaton Corporation is a diversified power management company, specializing in hydraulics and industrial equipment for the manufacturing, aerospace, transportation, and energy industries. It had 2009 sales of $11.9 billion, with 70,000 employees spanning a market of 150 countries (Company Website).  (http://www.eaton.com/Eaton/OurCompany/AboutUs/CorporateInformation/index.htm)

According to its Annual Report filed with the SEC for fiscal year 2018: "During the fourth quarter 2018, certain of our wholly-owned non-U.S. subsidiaries sold various products to customers in Iran. We received total revenue of approximately 820,559 Euros and realized net profits of approximately 268,547 Euros from the sales (approximately $933,380 and $305,470 in whole U.S. dollars, respectively). Eaton has determined not to take any future orders for sales to Iran." (https://www.sec.gov/Archives/edgar/data/1551182/000155118219000045/etn12312018form10-k.htm)

Eaton acquired Vickers, a hydraulics manufacturer, in 1999. Vickers equipment is sold in Iran through distributor Hydraulic Karan. Hydraulic Karan features photographs of Vickers equipment taken as recently as 2007. (http://www.eaton.com/EatonCom/Markets/Hydraulics/ProductsbyName/Vickers-Hydraulics/index.htm) (http://www.hkaran.com/index-e.html) (http://www.hkaran.com/projects/4-f.html)

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In 2017 the U.S. state of Michigan listed Eaton on its Iran restricted investment list rendering Eaton ineligible for investment and/or state contracting.  (http://www.michigan.gov/documents/treasury/Divested_Securities_380236_7.pdf)