China Oilfield Services (COSL)

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. COSL is included on this list. (https://sdlegislature.gov/docs/referencematerials/requiredreports/RR901152020.pdf)

On May 15, 2020, the IPERS identified COSL on its Iran Prohibited Companies List. (https://www.ipers.org/sites/default/files/IPERS%27 Iran Prohibited Companies 2Q20.pdf)

China Oilfield Services is listed on the CalPERS November 2018 Iran Divested/Restricted companies list. (https://www.calpers.ca.gov/docs/forms-publications/iran-sudan-divestment-2018.pdf)

As of December 31, 2019, the Alaska Retirement Management Board lists COSL 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)

In 2014, CalSTRS designated China Oilfield Services Limited as "Divested and Restricted" and maintained the "Divested and Restricted" status in 2020." (https://www.calstrs.com/sites/main/files/file-attachments/calstrs-investment-reports-2020.pdf?1609284307)

In 2013, 2014, 2015, 2016 and 2017, China Oilfield Services 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)

As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list COSL 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)

"The oil rigs currently operating in Iranian waters mostly work for Iranian state-owned companies. The rigs are owned by a variety of foreign firms, including Norway's Sinvest, London-based Foresight Group, China Oilfield Service, Japan Drilling and Saipem, a subsidiary of Italian oil giant ENI. Industry sources said they would probably be certified by either Lloyd's or Bureau Veritas. BV did not respond to inquiries." (The Washington Post, "Congress sees shipping-certification firms as tool to tighten Iran noose," 12/5/2011) (http://www.washingtonpost.com/business/economy/congress-sees-shipping-certification-firms-as-tool-to-tighten-iran-noose/2011/12/02/gIQAjCxvXO_story_1.html)

In 2017, the states of Alaska, California, Connecticut, Florida, Georgia, Iowa, Mississippi, North Carolina, Ohio, Pennsylvania       South Dakota and Texas  listed China Oilfield Services on its Iran scrutinized companies list rendering China Oilfield Service ineligible for investment and/or state contracting. (http://treasury.dor.alaska.gov/Portals/3/docs/ARMB%20Iran%20Divestment%20List%203-31-17.pdf) (https://www.calpers.ca.gov/docs/forms-publications/iran-sudan-divestment-2017.pdf) (http://www.ott.ct.gov/PDFs/IACAnnualReportonStatutoryInvestmentRestrictions062917.pdf) (https://www.sbafla.com/fsb/Portals/FSB/Content/GlobalGovernanceMandates/QuarterlyReports/2017/Global_Governance_Mandates_and_Florida%20Statutes_2017_03_14.pdf?ver=2017-03-14-132558-093) (https://ost.georgia.gov/sites/ost.georgia.gov/files/related_files/document/20140814_IRAN_DIVESTMENTS_FINAL.pdf) (https://www.legis.iowa.gov/docs/publications/DF/861736.pdf) (http://www.dfa.ms.gov/media/4100/companies-posted.pdf) (https://www.nctreasurer.com/inside-the-department/OpenGovernment/Reports/Divestment%20-%202017-08-30%20-%20Iran.pdf) (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf) (http://sdlegislature.gov/docs/referencematerials/requiredreports/RR901132017.pdf) (http://www.prb.state.tx.us/txpen/wp-content/uploads/2017/03/2017.03.01_Iran_List.pdf)

CNPC is listed on the January 2019 Entities prohibited from Contracting with Public Entities in California list. (http://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB%20Iran%20Divestment%20List%203-31-19.pdf) (https://www.dgs.ca.gov/-/media/Divisions/PD/PTCS/OPPL/Iran-Contracting-Act-List.ashx?la=en&hash=95E15BE0E8841A4AC8C2CD823C7D8EC0F1F58981)

On June 1, 2020, the Ohio Police & Fire Pension Fund (“OP&F”) listed COSL 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.

COSL is listed on the August 5, 2020 California Department of General Services, "Entities Prohibited from Contracting with Public Entities in California per the Iranian Contracting Act, 2010" list. (https://www.dgs.ca.gov/-/media/Divisions/PD/PTCS/OPPL/Iran-Contracting-Act-List.pdf?la=en&hash=71776438AADF114D952082668B1D6A0AEED31C2B)

"In 2014, CalSTRS designated China Oilfield Services Limited as "Under Review" for potentially having ties to Iran. The company's activities in Iran were confirmed in CNOOC's 20-F Filing, which stated, "China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran in relation to subcontracting agreements entered into in 2009, as it did in 2012."

In 2014, CalSTRS designated China Oilfield Services Limited as “Under Review” for potentially having ties to Iran. The company’s activities in Iran were confirmed in CNOOC’s 20-F Filing, which stated, “China Oilfield Services Limited (COSL), one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran in relation to subcontracting agreements entered into in 2009, as it did in 2012.” In 2014, CalSTRS designated China Oilfield Services Limited as “Divested and Restricted” and has maintained the “Divested and Restricted” designation in 2018.

August 2017 - COSL Singapore Ltd (“COSL Singapore”), an oilfield services company located in Singapore and a subsidiary of China Oilfield Service Limited, has agreed to pay $415,350 to settle its potential civil liability for 55 apparent violations of the Iranian Transactions and Sanctions Regulations. (https://www.treasury.gov/resource-center/sanctions/CivPen/Documents/20170824_cosl.pdf)

China Oilfield 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)

China Oilfield Services 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)

In January 2021, the State of New Jersey Department of the Treasury listed COSL as a company engaged in prohibited activities in Iran pursuant to P.L. 2012, c. 25 ("Chapter 25").  (https://www.nj.gov/treasury/purchase/pdf/Chapter25List.pdf)

As of May 17, 2021, Iowa's Public Employee's Retirement System lists COSL on its Iran Scrutinized Companies List. (http://www.mfprsi.org/site_media/uploads/divestments/iran_list.pdf) (https://www.ipers.org/sites/default/files/IPERS%27%20Iran%20Prohibited%20Companies%203Q19.pdf)

As of June 2020, China Oilfield remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996.  (https://www.patreasury.gov/pdf/divestment/2020-Annual-Divestment-Report.pdf)

China Oilfield Services 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)

In 2014, China Oilfield Services Limited was identified as being involved in the development of oilfields in Iran. (https://www.calstrs.com/sites/main/files/file-attachments/calstrs_investment_reports_2018.pdf)

On June 16, 2011, COSL 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, COSL 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)

"To our knowledge, in 2018, China Oilfield Services Limited (COSL), one of our non-controlled affiliates, provided certain drilling services in Iran." (CNOOC, Annual Report 2018). (https://www.cnoocltd.com/attach/0/91ce9f2285834a7fa5d7e070a01640ec.pdf)

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As of October 2019, China Oilfield remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996.  (https://www.patreasury.gov/pdf/divestment/2019-Annual-Divestment-Report.pdf)

In June 2020, COSL was listed by the Connecticut Office of the Treasurer as a restricted company and therefore prohibits direct investment in the company due to its involvement in Iran.  (https://portal.ct.gov/-/media/OTT/Doing-Business/080420SudanStatutoryInvestmentRestrictionsJun2020.pdf)

On March 13, 2019, the Mississippi Department of Finance & Administration identified COSL 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)

<!--td {border: 1px solid #ccc;}br {mso-data-placement:same-cell;}--> China Oilfield Services Ltd is listed on the December 31, 2018 CalSTRs Portfolio of companies identified as possibly having ties to Iran and from which CalSTRs has divested from and restricted in 2018. (https://www.calstrs.com/sites/main/files/file-attachments/calstrs_investment_reports_2018.pdf)

In 2014, the California State Teachers’ Retirement System (“CalSTRS”), designated COSL as “Under Review” for involvement in the development of oilfields in Iran. The company’s activities in Iran were confirmed in CNOOC’s 20-F filing, which stated, “China Oilfield Services Limited (COSL) one of our non-controlled affiliates, continued to provide certain drilling and other related services in Iran in relation to subcontracting agreements entered into in 2009, as it did in 2012.” In 2014, CalSTRS designated COSL as “Divested and Restricted” and maintained that designation in 2019.   In 2015, the California State Public Employees Retirement System (“CalPERs”) approved divestment from COSL.  (https://www.calstrs.com/sites/main/files/file-attachments/calstrs-investment-reports-2019.pdf?1577750493) (https://www.calpers.ca.gov/docs/board-agendas/201912/invest/item06g-01_a.pdf)

<!--td {border: 1px solid #ccc;}br {mso-data-placement:same-cell;}--> As of August 15, 2019, the state of Iowa listed China Oilfield Services on its Iran scrutinized companies list. (https://www.ipers.org/sites/default/files/media/2017%2009%20Iran%20Prohibited%20Companies%20List%2009-30-17.pdf)

On June 30, 2019, New Jersey listed China Oilfield Services on its state list of entities determined, based on credible information, to be engaged in prohibited activities in Iran. (https://www.state.nj.us/treasury/purchase/pdf/Chapter25List.pdf)

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

In 2014, China Oilfield was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996. (https://www.patreasury.gov/pdf/divestment/2015-Annual-Divestment-Report-print.pdf)