Sanofi S.A.

Sanofi has determined that its activities are compliant with applicable law. In light of the nature of the activities concerned, Sanofi and its affiliates intend to continue their activities in Iran."

According to its form 20-F filed with the SEC in 2022, "Sanofi engages in limited business activities with Iran related to human health products – namely, sales of bulk and branded pharmaceuticals and vaccines. These activities, which are disclosed pursuant to Section 13(r) of the United States Exchange Act of 1934, as amended, are not financially material to Sanofi and contributed well under 1% of Sanofi’s consolidated net sales in 2022. Sanofi’s US affiliates and non-US affiliates owned or controlled by Sanofi’s US affiliates either do not engage in Iran-related activities or act under licenses issued by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC). Sanofi and certain non-US Sanofi affiliates engage in limited business activities that neither are expressly authorized by OFAC nor require such authorization. In 2016, Sanofi and the Iran Food and Drug Administration (IFDA), an entity affiliated with the Iranian Ministry of Health and Medical Education, signed a Memorandum of Cooperation (MOC) regarding: (i) potential future projects to reinforce current partnerships with reputable Iranian manufacturers (in particular, to enhance industrial quality standards); (ii) collaborating with the Ministry of Health and Medical Education on programs for the prevention and control of certain chronic and noncommunicable diseases (in particular, diabetes); and (iii) potential future collaboration on epidemiological studies. In 2022, activities conducted under the MOC did not generate any revenue or net profits. Certain non-US Sanofi affiliates engage in limited business with Iranian counterparties associated with the Iranian Ministry of Health, such as public hospitals or distributors. In 2022, those business activities generated approximately €28.2 million in gross revenue and contributed no more than €7.6 million in net profits." (https://www.sanofi.com/assets/dotcom/content-app/publications/annual-report-on-form-20-f/2022-01-01-form-20-f-2022-en.pdf)

“Temporary sanctions relief hasn’t yet translated into an economic turnaround in Iran. But at the Melal Hotel, business hasn’t been this good in years. Employees of French drug maker Sanofi Aventis SA and tire maker Cie. Générale des Etablissements Michelin mingle on a recent morning among the still lifes and faux-leather chairs of the hotel dining room...Businesses exploring the Iranian market ‘do so at their own peril right now,’ U.S. President Barack Obama said last month, ‘because we will come down on them like a ton of bricks.’ But that hasn’t stopped companies from boosting their presence or sending in advance teams—essentially making exploratory visits in the hopes that sanctions may be lifted further and permanently. Sanofi hosted a training seminar at the Melal this month. Part of the sanctions relief eases constraints on humanitarian goods, such as food and medicine...Sanofi and Michelin decline to comment.” (Wall Street Journal, “As Iran Sanctions Ease, Western Firms Seek a Way In,” 3/27/14) (http://www.unitedagainstnucleariran.com/company/michelin) (http://stream.wsj.com/story/latest-headlines/SS-2-63399/SS-2-493702/)

Sanofi S.A. has a U.S. Website (http://www.sanofi.us/l/us/en/index.jsp)

"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 representative for Sanofi couldn't be reached for comment." (Wall Street Journal, "Iran Deal Opens Door for Businesses," 12/1/13) (https://www.unitedagainstnucleariran.com/company/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 representative for Sanofi couldn't be reached for comment." (Wall Street Journal, "Iran Deal Opens Door for Businesses," 12/1/13)) (https://www.unitedagainstnucleariran.com/company/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 representative for Sanofi couldn't be reached for comment." (Wall Street Journal, "Iran Deal Opens Door for Businesses," 12/1/13)) (http://online.wsj.com/news/articles/SB10001424052702304579404579232131395661284)

"Dozens of European businesses have visited the country in recent months in anticipation of a thaw in relations over Iran’s nuclear programme that could rehabilitate the oil-rich country as a destination for business investment. Iranian and western businessmen say some tentative deals have been prepared, ready for signature once the interim nuclear agreement struck in Geneva last month is implemented…Sanofi of France, which already licenses production of several of its cancer drugs to a local Iranian manufacturer and employs 170 of its own staff in the country, said: 'We are planning additional product launches next year in Iran. It’s a good, solid business.' Medicines are among the humanitarian exemptions to the existing sanctions regime, but foreign companies’ sales and investment have been limited by difficulties in payment, insurance and shipping." (Financial Times, "Merck tests ground for Iran partnership to produce medicines," 12/26/13) (http://www.ft.com/intl/cms/s/0/428530ea-6997-11e3-aba3-00144feabdc0.html#axzz2ohCx0kOG)

Sanofi's website lists RP Iran as its affiliate in Iran. (https://www.sanofi.com/assets/dotcom/pages/docs/miscellaneous/list-of-sanofi-affiliates/list-of-sanofi-affiliates.pdf)

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Following the MOC, Sanofi and the Iranian company Barkat Pharmed Co. entered into a non-binding letter of intent on June 16, 2017 to evaluate the possibility of a transaction involving the creation of a joint venture, or other possible forms of transaction, the business purpose of which would be the manufacturing and distribution of pharmaceutical products in Iran. The MoC and the letter of intent did not generate any revenue, nor any net profit.

“Multiple companies currently exploring new business ventures in Iran are also cashing in on highly lucrative contracts with the U.S. Defense Department, raising questions about whether their dealings with Iran could run afoul of U.S. law. At least 13 major international companies have said in recent weeks that they aim to reenter the Iranian marketplace over the next several months. The companies have received Pentagon contracts totaling well over $107 billion, according to a Washington Free Beacon analysis that tracked DoD contracts awarded since fiscal year 2009. Many of the companies, which include carmaker Renault and oil giants such as BP, have already sent high-level trade delegations to Tehran to meet with Iranian officials about striking new business deals…These companies include Boeing and General Electric—which have DoD contracts worth $87 and $12 billion respectively—as well as the Italian oil company Eni, Merck, Safran, Vitol, Bosch Rexroth, Sanofi Pastuer, and AVL.” (Washington Free Beacon, “Pentagon Contractors Exploring Business with Iran,” 2/25/14) (http://www.unitedagainstnucleariran.com/company/renault) (http://www.unitedagainstnucleariran.com/company/bp) (http://www.unitedagainstnucleariran.com/company/eni) (http://www.unitedagainstnucleariran.com/company/merck-kgaa') (http://www.unitedagainstnucleariran.com/company/safran-sa) (http://www.unitedagainstnucleariran.com/company/vitol) (http://www.unitedagainstnucleariran.com/company/bosch-rexroth) (http://www.unitedagainstnucleariran.com/company/avl) (http://freebeacon.com/pentagon-contractors-exploring-business-with-iran/)

"Drugmaker Sanofi said it was premature to say if there will be any impact on its operations in Iran." (8/8/18) -- (https://www.reuters.com/article/us-iran-nuclear-companies-europe-factbox/factbox-european-companies-respond-to-latest-iran-sanctions-idUSKBN1KT1CR)

Sanofi Pasteur and Sanofi U.S. Services inc are subsidiaries of Saofi S.A. (http://www.sanofipasteur.com/)

"In January 2016, Sanofi and the Iran Food and Drug Administration, affiliated with the Ministry of Health and Medical Education of the Islamic Republic of Iran, signed a Memorandum of Cooperation (MoC) regarding (i) potential future projects to reinforce current partnerships with reputable Iranian manufacturers (in particular to enhance industrial quality standards), (ii) collaborating with the Ministry of Health on programs for the prevention and control of certain chronic and non-communicable diseases (in particular diabetes) and (iii) potential future collaboration on epidemiological studies. (https://www.sec.gov/Archives/edgar/data/1121404/000119312518073307/d466787d20f.htm)