LARSEN & TOUBRO LIMITED

In 2014, the California State Teachers’ Retirement System (“CalSTRS”), designated Larsen & Toubro as “Under Review” for providing products to Iran and holding a stake in an Iran-based joint venture, IndIran Engineering Projects and Systems. In 2015, CalSTRs designated Larsen & Toubro as “Being Monitored” and maintained that designation in 2019. In 2018, the California State Public Employees Retirement System (“CalPERs”) designated Larsen & Toubro as under review for potentially having a stake in an Iran-based joint venture. In 2019, CalPERs changed the designation to “Being Monitored” because CalPERS’ “initial screening has not identified the company as having involvement in the [activities] targeted by the [2019 California Public Divest from Iran] Act (https://www.calpers.ca.gov/docs/legislative-regulatory-letters/investments-ca-divest-iran-sudan.pdf) (https://www.calstrs.com/sites/main/files/file-attachments/calstrs-investment-reports-2019.pdf?1577750493)

"In 2014, Larsen & Toubro Ltd. was identified by CalSTRS service providers as providing products to Iran. Additionally, Larsen & Toubro Ltd. holds a stake in an Iran-based joint venture, IndIran Engineering Projects and Systems. In 2014, CalSTRS designated Larsen & Toubro Ltd. as “Under Review” for potentially having ties to Iran. In 2015, CalSTRS designated Larsen & Toubro Ltd. as “Being Monitored.” CalSTRS has maintained the “Being Monitored” status in 2020." (https://www.calstrs.com/sites/main/files/file-attachments/calstrs-investment-reports-2020.pdf?1609284307)

"The company was reported as potentially having a stake in an Iranbased joint venture. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act." (https://www.calpers.ca.gov/docs/forms-publications/iran-sudan-divestment-2020.pdf)