GlaxoSmithKline PLC

The Group does not regularly receive information regarding the identity of its distributors’ downstream customers and intermediaries in Iran, and it is possible that these parties include entities, such as government-owned hospitals and pharmacies, that are owned directly or indirectly by the Iranian government or by persons or entities sanctioned in connection with terrorism or proliferation activities. The Group understands that a sub-distributor to which the Group’s privately held distributor in Iran previously sold Group medicines may be an entity whose property is blocked pursuant to Executive Order 13224 as a consequence of its indirect ownership structure. Upon learning of the sub-distributor’s potential ownership structure, the Group required its distributor in Iran to terminate the relevant sub-distributor."

According to its Annual Report filed with the SEC in 2013: "Following a review of its business with Iran, the Group has ceased sales of products from its Consumer Healthcare business and intends to supply only products of high medical/public health need (as determined using criteria set by the World Health Organization) from its Pharmaceuticals and Vaccines businesses." (https://www.sec.gov/Archives/edgar/data/1131399/000119312513098802/d470564d20f.htm)

GlaxoSmithKline PLC (a U.K. company) disclosed that, while it “does not have a legal entity based in Iran . . . it does export certain pharmaceutical and vaccine products to Iran, via sales by non-U.S. entities, to two privately held Iranian distributors.” GSK stated that it has “no direct knowledge of the identity of its distributors’ downstream customers in Iran, and it is possible that these customers include entities, such as government-owned hospitals and pharmacies that are owned or controlled directly or indirectly by the Iranian government.” Jahan Behbood lists itself as an agent for GlaxoSmithKline. (January 2018) (https://www.shearman.com/Perspectives/2018/01/Dynamics-in-the-Era-Iran-Sanctions / http://www.jahanbehbood.com/aboutus.html)

"While Western powers have identified a small group of sectors for Iranian sanction relief, a much wider set of European and U.S. companies—from pharmaceutical firms and medical-equipment makers to food companies and traders—also stands to regain lost Iranian trade as soon as relief measures are formally adopted next month. Western governments singled out Iran's automotive and aviation sectors for temporary sanction relief, while allowing petrochemical exports and trade in gold and other precious metals. But the fine print of the deal also clears the way for GlaxoSmithKline PLC and Sanofi SA, for example, to restart selling many of the drugs they had been forced to cut back on because of increasingly stiff financial sanctions…Pharmaceutical companies Glaxo and AstraZeneca PLC of the U.K. and Sanofi of France reported annual Iranian sales of roughly $32.2 million, $14 million and $13.9 million, respectively, according to their annual SEC reports. A spokeswoman for Glaxo said 'things are moving at the moment' with the proposed sanctions relief and that the company is 'monitoring the situation, but it's early days.'" (Wall Street Journal, "Iran Deal Opens Door for Businesses," 12/1/13)  (http://www.unitedagainstnucleariran.com/company/sanofi-sa) (http://www.unitedagainstnucleariran.com/company/astrazeneca-plc) (http://online.wsj.com/news/articles/SB10001424052702304579404579232131395661284)

GlaxoSmithKline LLC and GlaxoSmithKline (Holdings) are subsidaries of GlaxoSmithKline PLC

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"The Group exports certain pharmaceutical, vaccine and consumer products to Iran, via sales by non-US entities, to two privately held Iranian distributors." (2018 Annual Report) (https://www.gsk.com/media/5345/investor-information.pdf)

GlaxoSmithKline PLC has a U.S. Website (http://us.gsk.com/)

According to its Annual Report filed with the SEC for fiscal year 2019: "The Group exports certain pharmaceutical, vaccine and consumer products to Iran, via sales by non-US entities that are not subsidiaries of a US entity, to two privately held Iranian distributors. (https://www.sec.gov/Archives/edgar/data/1131399/000119312520065064/d769953dex153.htm)