Syngenta AG

"Syngenta conducts business in most countries of the world, and thus it has minor operations in high risk territories, including Cuba, Iran, Syria and the Sudan, some of which have been identified by the US government as state sponsors of terrorism.  Syngenta’s operations in these countries are quantitatively immaterial, and it is Syngenta’s belief that supporting agriculture in these countries is beneficial to their wider population, for whom food is often in short supply.  However, certain investors may choose not to hold investments in companies that have operations of any size in these countries and several US states have enacted, and others may in the future enact, legislation requiring public entities with investments in companies with operations in these countries to disclose this fact or in some cases to divest these investments.  Any such divestment is not currently expected to have a material impact on the value of Syngenta shares." (SEC, "Form 20-F," 2/18/09) (http://www.sec.gov/Archives/edgar/data/1123661/000095010309000334/dp12532_20f.htm)

As part of Syngenta's SEC filings, the company's 2008 Annual Report on Form 20-F states:

Listed by U.S. Government as doing business in Iran. (U.S. Securities and Exchange Commission, “List of Companies Doing Business With State Sponsors Of Terror,” Removed from the Internet in July 2007)

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"Last year, Obama said in a statement that he sold about $180,000 in his holdings in a different Vanguard fund, the Wellington Fund, because the fund owned shares in Schlumberger a French oil-services company that does business in Sudan. Wellington also owns shares in companies that do business in Iran, including Schlumberger, Royal Dutch Shell and Syngenta, a Switzerland-based agribusiness company." (USA Today, "McCain, Obama funds invest in firms working in Iran," 6/3/08) (http://www.usatoday.com/news/politics/election2008/2008-06-02-investments_N.htm)

Syngenta officially lists that it runs an Iran office in Tehran. (Company Website) (http://www.syngenta.com/en/country/ir.html)

"The Swiss agrochemical company, Syngenta, said on Sunday that it was disappointed with the U.S. Securities and Exchange Commission (SEC) which suspected it of sponsoring terrorist states.... The blacklist is based on latest annual reports of the companies. They are mostly non-U.S. and include Unilever, Cadbury,HSBC, Nokia, Siemens and Total, as well as the second biggest Swiss bank, Credit Suisse, the agrochemical firm, Syngenta, and the engineering group, ABB. Syngenta said it was disappointed with the U.S. blacklist, while ABB and Credit Suisse played down their business links with the five named countries - Cuba, Iran, the Democratic People's Republic of Korea, Sudan and Syria, Swissinfo said. According to Basel-based Syngenta, the company should not be punished for its transparency. It is currently active in four of the five countries designated by the U.S. State Department as 'sponsors of terrorism.' 'But we see no reason to change our policy,' said Syngenta spokesman Medard Schoenmaeckers. He added that the company's business activities in Sudan's agriculture sector were 'minimal.'"(Xinhua, "Swiss Company Irritated Over U.S. Blacklist," 7/2/07) (http://news.xinhuanet.com/english/2007-07/02/content_6315860.htm)