KLCC Property Holdings

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

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

As of December 31, 2019, the Alaska Retirement Management Board lists KLCC 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 2017 the U.S. state of Alaska, Florida, and Mississippi, listed KLCC on its list of companies doing material business with Iran rendering KLCC ineligible for investment and/or state contracting. (http://treasury.dor.alaska.gov/Portals/3/docs/ARMB%20Iran%20Divestment%20List%2012-31-17.pdf /) (https://www.sbafla.com/fsb/Portals/FSB/Content/GlobalGovernanceMandates/QuarterlyReports/2017/Global_Governance_Mandates_and_Florida%20Statutes_2017_12_13.pdf?ver=2017-12-13-145507-737) (http://www.dfa.ms.gov/media/4100/companies-posted.pdf)

KLCC 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)

On April 14, 2009, Bank of KLCC 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, KLCC 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)

In 2013, 2014, 2015, 2016 and 2017 KLCC 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)

KLCC 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)

KLCC 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)

In 2020, the U.S. state of Mississippi listed KLCC 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 2018 the U.S. state of Ohio listed KLCC on its list of entities determined to be engaged in prohibited activities in Iran rendering KLCC ineligible for investment and/or state contracting. / Subsidiary of PETRONAS  (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf)

--

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