OJSC GAZPROM NEFT

www.gazprom-neft.com

Disqualified

Transport sanctions: where transport sanctions apply, a ship owned, controlled, chartered or operated by a designated person is prohibited from entering a port in the UK, may be given a movement or a port entry direction, can be detained, and will be refused permission to register on the UK Ship Register or have its existing registration terminated. Similarly, an aircraft owned, chartered or operated by a designated person is prohibited from overflying or landing in the UK, may be given a movement direction, can be detained or moved to a specified airport, and will be refused permission to register on the CAA Aircraft Register or have its existing registration terminated. This also includes a prohibition of technical assistance relating to aircraft and ships: a prohibition on the provision of technical assistance relating to aircraft or ships will prevent a person from directly or indirectly providing technical assistance to, or for the benefit of, the designated person, where that technical assistance relates to an aircraft or ship. The Director Disqualification Sanction was imposed on 09/04/2025.

Listed under Schedule 2 of the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855).

On September 16, 2008, Gazprom Neft 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, Gazprom Neft 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)

Gazprom Neft 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_07_12_Web_Update_PFIA_Prohibited_List.pdf?ver=2019-07-12-114201-343)

As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list Gazprom Neft on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector (https://www.unitedagainstnucleariran.com/company/china-nonferrous-metal-mining-group)

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

Gazprom Neft, the oil division of Russian gas major Gazprom, presented its development plan for Iran's Azar and Changuleh oilfields on Monday. The presentation took place in a meeting in Tehran between Gazprom Neft executives and National Iranian Oil Company officials led by deputy chief Gholamreza Manouchehri, the NIOC news portal reported. (December 20, 2017). (https://financialtribune.com/articles/energy/78290/gazprom-neft-presents-iran-oilfield-proposals)

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

"Gazprom Neft, the oil division of Russian gas major Gazprom, presented its development plan for Iran's Azar and Changuleh oilfields on Monday....The two companies signed a memorandum of understanding in July in the Russian city of St. Petersburg to join forces for conducting the assessment of geological potentials of Changuleh and Azar in Ilam Province." (December 2017) (https://financialtribune.com/articles/energy/78290/gazprom-neft-presents-iran-oilfield-proposals)

Gazprom Neft 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 2018 the U.S. state of  Ohio listed Gazprom Neft on its Iran prohibited companies list rendering Gazprom neft ineligible for investment and/or state contracting. (https://www.op-f.org/Files/Scrutinized%20Companies%20Iran%20Sudan.pdf)

In 2017 the U.S. states of Alaska, Florida, Mississippi lists Gazprom Neft on its list of companies doing material business with Iran rendering Gazprom Neft 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)

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

On June 1, 2020, the Ohio Police & Fire Pension Fund (“OP&F”) listed Gazprom Neft 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.” (https://www.op-f.org/Files/Scrutinized Companies Iran Sudan.pdf)

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

Gazprom Neft is listed on the 4Q 2020 Minnesota State Board of Investment List of Unauthorized (Scrutinized) Iran Companies. (https://www.lrl.mn.gov/docs/2021/mandated/210295.pdf)

On January 20, 2020, Minnesota SBI listed Gazprom Neft as a scrutinized investment. The managers are explicitly instructed to refrain from purchasing securities on this list. (https://www.leg.state.mn.us/docs/2020/mandated/200121.pdf)

"Gazprom Neft has signed a Memorandum of Understanding with Iran’s Oil Industries’ Engineering & Construction (OIEC) confirming both companies’ mutual interest in combining forces in the preliminary assessment and investigation of the geological potential of oil fields located in the Islamic Republic of Iran. The document was signed by First Deputy CEO, Gazprom Neft, Vadim Yakovlev and OIEC CEO Behzad Mohammadi." (July 2017) (https://www.unitedagainstnucleariran.com/http://www.gazprom-neft.com/press-center/news/1120310)

Gazprom Neft 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)

For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.

For more information on directives, please visit the following link: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/ukraine.aspx#directives.

(also OJSC GAZPROM NEFT)

(also OJSC GAZPROM NEFT)

(also OJSC GAZPROM NEFT)

(also SIBIRSKAYA NEFTYANAYA KOMPANIYA OAO, OPEN JOINT-STOCK COMPANY GAZPROM NEFT, JSC GAZPROM NEFT, GAZPROM NEFT OAO)

(also GAZPROM NEFT JOINT STOCK COMPANY)

(also OJSC GAZPROM NEFT)

(also OJSC GAZPROM NEFT)