Alcatel-Lucent

In 2018 and 2019, the U.S. state of Ohio,  listed Alcatel-Lucent on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering Alcatel-Lucent ineligible for investment and/or state contracting. (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf)

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Two non-U.S. subsidiaries of Alcatel Lucent have branches in Iran. The branch offices maintain bank accounts at Bank Tejarat for purposes of carrying out financial transactions in connection with their general business activities.” (Alcatel-Lucent, “Form 20-F,” 3/12/13) (http://www.sec.gov/Archives/edgar/data/886125/000119312513103311/d448194d20f.htm)

In its annual 20-F form to the U.S. Security Exchange Commission, Alcatel writes, “Under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which added Section 13 (r) to the Securities Exchange Act of 1934, as amended (the “Exchange Act”), we are required to disclose whether Alcatel Lucent or any of its affiliates knowingly engaged in certain activities, transactions or dealings relating to Iran or certain designated individuals or entities. Disclosure is required even when the activities were conducted outside the United States by non-U.S. entities and even when such activities were conducted in compliance with applicable law.

“Iran [welcomes] the most senior French trade delegation in years on Monday, telling more than 100 executives that the farsighted among them stood to win the race for business following an easing of some economic sanctions…’A new chapter has begun in relations between Iran and Europe,’ Mohammad Nahavandian, President Hassan Rouhani's chief of staff, was quoted as saying by the official IRNA news agency. ‘You should carry the message back that potential for cooperation with Iran is real and not to be overlooked,’ he told the delegation. ‘Those with longer foresight stand to win this race.’ The delegation of more than 100 executives from Medef, the French employers' association, on a Feb 2-5 trip, met Nahavandian and members of Iran's Chamber of Commerce, Industries, Mines and Agriculture, IRNA said. A source close to the delegation told Reuters it was the most senior group of entrepreneurs and financiers to visit Iran since the 1979 revolution, representing the defence, aviation, petrochemicals, automotive, shipping and cosmetics sectors. Among companies represented were Safran, Airbus, Total, GDF-Suez, Renault, Alcatel, Alstom, Amundi and L'Oréal, the source said. ‘Many of these firms have worked in Iran before and their goal now is to restore links,’ the source said. ‘The very makeup of the delegation shows these people are here to evaluate potential for cooperation.’ A French embassy source in Tehran said the visit was merely exploratory and ‘nothing is to be signed this time around.’” (Reuters, “Iran welcomes French business chiefs after sanctions eased,” 2/3/14) (http://www.unitedagainstnucleariran.com/company/safran-sa) (http://www.unitedagainstnucleariran.com/company/airbus-group) (http://www.unitedagainstnucleariran.com/company/total-sa) (http://www.unitedagainstnucleariran.com/company/gdf-suez-sa) (http://www.unitedagainstnucleariran.com/company/renault) (http://www.unitedagainstnucleariran.com/company/alstom) (http://www.unitedagainstnucleariran.com/company/amundi) (http://www.unitedagainstnucleariran.com/company/loreal) (http://uk.reuters.com/article/2014/02/03/iran-france-delegation-idUKL5N0L820K20140203)

(4) Alcatel Lucent has supplied telecommunications network equipment and related services to an Iranian customer called Elmatco, a privately-held engineering and consulting firm, for end-use by a group of state-owned regional electricity companies, including Esfahan Regional Electric Company (“EREC”), Iran Power Distribution Company (“IPDC”) and Gharb Regional Electric Company (“GHREC”). During 2012, Alcatel Lucent’s gross revenues received in connection with this contract were approximately €57,000, resulting in net profits of €2,000. We intend to fulfill our remaining obligations under our existing contracts with Elmatco, subject to compliance with applicable laws, but we do not plan to renew or extend these contracts.

(1) Alcatel Lucent and our subsidiary, Alcatel-Lucent Submarine Networks (“ASN”), each have separate arrangements pursuant to which they have provided hardware repair, maintenance and/or testing services directly and indirectly to or for the benefit of Telecom Infrastructure Company (“TIC”). These services were provided in support of telecommunications network equipment that was sold previously to customers in Iran for end-use by TIC. TIC is a government-owned telecommunications infrastructure provider in Iran that serves as Iran’s intercity, interprovincial and international telecom network operator. During 2012, Alcatel Lucent’s gross revenues received from these activities involving TIC were approximately €454,000 and net profits were approximately €14,000. ASN’s contract involving TIC has been completed and ASN does not intend to extend or renew that business. We intend to fulfill our remaining contractual service obligations related to the TIC network equipment, subject to compliance with applicable laws.

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"Saber Feyzi, managing director of TCI said sanctions havent stopped IT providers from selling to Iran as contracts for equipment such as switches and transmission and radio systems show. Companies including Siemens, Nokia , Eriksson, Alcatel-Lucent, Cisco Systems, Telaps, NEC, ZTE, Huawei Technologies Co and Wuhan Research Institute have all supplied the Islamic republic. Iranian officials have dismissed US sanctions as inefficient, saying that they are finding Asian partners instead. Several Asian firms are negotiating or signing up to deals with Iran." (Thai Press Reports, "IRAN TELECOM CO TO OFFER 50% STAKE BY MARCH," 1/14/09)

(3) Alcatel Lucent has supplied telecommunications network equipment and related services to a private company in Iran call PATSA for end-use by the Shiraz Urban Rail Organization (“SURO”) in support of operations of the Shiraz city metro rail system. We understand that SURO is owned by the government of the city of Shiraz. During 2012, Alcatel Lucent did not recognize any revenues or net profits attributable to SURO in connection with this contract. We have not completed deliveries under our contract with PATSA due to issues related to non-U.S. sanctions against Iran and have therefore suspended activities under this contract.

"While U.S. companies have long been barred from operating in Iran, more than 200 multinationals have investments there, from British-Dutch oil giant Royal Dutch Shell PLC and French telecommunications-equipment company Alcatel SA to Swedens electronics company Telefon AB L.M. Ericsson." (The Wall Street Journal, "Should states sell stocks to protest links to Iran," 6/14/07) (http://online.wsj.com/documents/print/WSJ_-A001-20070614.pdf)

As of June 1, 2020, Ohio Police & Fire Pension Fund lists Alcatel-Lucent on its Iran Scrutinized companies list.  (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf)

"Alcatel-Lucent, which over the years has completed major telecommunications projects in Iran, still has a small amount of business in that country, company spokeswoman Mary Ward said. The company also has received contracts to deliver communications services to the Departments of Defense and Energy. The company's federal contract totals do not include Lucent's contracts prior to 2006, when it merged with Alcatel, because Lucent did not have business interests in Iran prior to that time." The company has received $927.2 million in revenue and benefits from the US government, for their investments in Iran.  Their activities in Iran are currently active. (The New York Times, "Profiting from Iran, and the US," 3/6/2010) (http://www.nytimes.com/interactive/2010/03/06/world/iran-sanctions.html)

As of April 2022, Ohio Police & Fire Pension Fund lists Alcatel-Lucent on its Iran scrutinized companies list. (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf)

The following information is disclosed pursuant to Section 13(r). None of these activities involved U.S. affiliates of Alcatel Lucent.

(2) ASN also holds a contract for the supply of hardware repair and related services in support of the South East Asia Middle East Western Europe 3 (“SMW3”) submarine cable network, which is owned and operated by an international consortium of telecommunications companies. Although none of the SMW3 network equipment supported under the ASN contract is located in Iran, the Telecommunication Company of Iran (“TCI”) is a member of the consortium. ASN understands that TCI has ties to the Government of Iran. During 2012, we did not recognize any revenues or net profits attributable to TCI in connection with this contract.