Sony

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2014 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2015, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2019 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2020, except as described above in connection with the wind-down of its representative office in Iran. Nevertheless, Sony has continued to monitor developments in this area, especially in the light of the United States’ decision that was implemented in its entirety on November 5, 2018 to cease its participation in the Joint Comprehensive Plan of Action of July 14, 2015, among the United States, the United Kingdom, China, France, Russia, Germany, the European Union and Iran and re-impose certain secondary sanctions (i.e., laws and regulations that threaten to impose U.S. economic sanctions on non-U.S. companies engaging in specified transactions with Iran outside U.S. jurisdiction). Sony will determine whether and to what extent they affect Sony’s business with Iranian customers as currently conducted and may additionally be conducted. Such business activities may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such business activities in accordance with applicable laws and regulations.

According to its Annual Report filed with the SEC for fiscal year 2014: "Sony is aware that certain transactions during the fiscal year ended March 31, 2014, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act. (https://www.sec.gov/Archives/edgar/data/313838/000119312514249964/d709915d20f.htm)

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"Sony has been in Iran since at least 2000 and currently has an office in the country."  From 2000-2009, the company was the recipient of $103.3 million US federal funds.  The company's business in Iran is 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)

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2013 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that transactions that may be disclosable, as discussed above, will continue during the fiscal year ending March 31, 2014, except for the operation of its representative office and certain transactions through third-party-owned dealers that Sony believes to be intended for the Islamic Republic of Iran Broadcasting and the Iranian Ministry of Health. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law.

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

Sony believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

During the fiscal year ended March 31, 2017, a non-U.S. subsidiary of Sony sold medical instruments, including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from these sales was approximately 5.7 million U.S. dollars, and Sony has estimated that its net profit from such sales was 0.4 million U.S. dollars. (https://www.sec.gov/Archives/edgar/data/313838/000119312517203939/d358485d20f.htm)

Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates during the fiscal year ended March 31, 2015 that is disclosable in this report under Section 13(r) of the Exchange Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be disclosable will be conducted during the fiscal year ending March 31, 2016, except as described above in connection with the wind-down of its representative office or for certain transactions through third-party-owned dealers that Sony believes to be intended for hospitals and health organizations in Iran. Nevertheless, in the future, Sony may conduct additional sales activities in Iran through third-party-owned dealers/distributors, which may require disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such sales in accordance with applicable law."

Company website lists numerous outlet and retail shops in Iran. (Company Website) (http://www.sony-mea.com/section/retailshops)

According to its Annual Report filed with the SEC for fiscal year 2013: "Sony is aware that certain transactions during the fiscal year ended March 31, 2013, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act. (https://www.sec.gov/Archives/edgar/data/313838/000119312513273660/d519176d20f.htm)

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of Sony’s knowledge, and Sony in particular may not be aware of all potentially reportable sales by third-party-owned dealers and distributors.

"In the electronics and home appliances sections, sales of LG and Sony flat-screen televisions come with attractive service plans and free home installations. Local brands, such as Pars, go mostly ignored." (The Washington Post, "Iran hopes to resist sanctions by boosting production," 10/27/2012)  (http://www.washingtonpost.com/world/middle_east/iran-hopes-to-resist-sanctions-by-boosting-production/2012/10/27/a3531670-1f3e-11e2-8817-41b9a7aaabc7_print.html)

"But its population of about 75 million includes a sizeable urban middle class who have been avid consumers of foreign-made goods, including Samsung and Sony electronics and Peugeot cars." (Reuters, "Iran says it will cut imports of non-essential goods," 10/14/2012) (http://www.reuters.com/article/2012/10/14/iran-economy-idUSL5E8LE3AC20121014)

Sony’s small representative office in Tehran, Iran, may engage in certain incidental transactions (for example, permits, utilities, and other similar matters incidental to operating an office in Iran) with Iranian government-owned entities. No material revenues or profits are associated with these transactions with the Iranian government.

According to its Annual Report filed with the SEC for fiscal year 2019: "Sony is aware that certain transactions during the fiscal year ended March 31, 2019, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act. (https://www.sec.gov/Archives/edgar/data/313838/000119312519175182/d870848d20f.htm)

SonyIran has a website here.  (https://www.sonyiran.com/)

According to its Annual Report filed with the SEC for fiscal year 2016: "    (https://www.sec.gov/Archives/edgar/data/313838/000119312516624169/d168822d20f.htm)

Sony believes, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to impose penalties or sanctions against Sony, the impact of such sanctions could be material."

“Sony Corp. (6758) sold almost $13 million in video and medical equipment to dealers in Dubai that resold the gear in Iran, the company said. The recipients included groups under U.S. sanctions. In a U.S. filing yesterday, Sony said it sold broadcast equipment, security cameras and video-conferencing gear to dealers who planned to resell or resold the products to groups including the Information Technology Department of the Iranian Police and the Islamic Republic of Iran Broadcasting… Sony ‘believes that, and maintains policies and procedures designed to ensure that, its transactions with Iran and elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations,’ according to the filing. Penalties or sanctions taken against the company could be material if any government disagrees, Sony said... One dealer was a subsidiary of the Islamic Republic of Iran Broadcasting, Sony said in the filing. The company also reported sales of medical instruments -- including printers, paper and monitors -- it said were intended for the Ministry of Health.  Sony said it made the disclosure under the Iran Threat Reduction and Syria Human Rights Act of 2012 and related amendments to the Securities Exchange Act of 1934.  The company said it registered a profit of about $500,000 from the sale.” (Bloomberg, “Sony Reports Tech Sales to Iran that May Violate Sanctions,” 6/27/13) (http://www.bloomberg.com/news/2013-06-27/sony-reports-sale-of-communications-gear-to-iran.html)

According to its Annual Report filed with the SEC for fiscal year 2015: "Sony is aware that certain transactions during the fiscal year ended March 31, 2015, as described below, may be disclosable pursuant to Section 13(r) of the Exchange Act. (https://www.sec.gov/Archives/edgar/data/313838/000119312515231346/d895998d20f.htm)