Sony 2015 Annual Report Download - page 38

Sony does not customarily allocate net profit on a country-by-country or activity-by-activity basis, other
than as set forth in Sony’s consolidated financial statements prepared in accordance with U.S. GAAP; thus, the
net profit and loss described below are non-U.S. GAAP figures and are estimated solely for the purpose of
preparing this disclosure pursuant to Section 13(r) of the Exchange Act. The information below is to the best of
Sony’s knowledge, and in particular Sony may not be aware of all potentially reportable sales by
third-party-owned dealers and distributors.
• During the fiscal year ended March 31, 2016, a non-U.S. subsidiary of Sony sold medical instruments,
including medical printers, print media and monitors, to a third-party-owned dealer in Dubai, which, to
the best of Sony’s knowledge, planned to resell those products to hospitals and health organizations in
Iran, some of which are under the control of the Iranian Ministry of Health. Sony’s gross revenue from
these sales was approximately 4.8 million U.S. dollars, and Sony has estimated that its net profit from
such sales was 0.3 million U.S. dollars.
• Sony’s representative office in Tehran, Iran, which was established in 1992, has been closed and has
been under liquidation processes since before the beginning of the fiscal year ended March 31, 2014. In
the course of liquidation, Sony engages in certain incidental transactions (for example, permits, taxes,
and similar matters incidental to the wind-down of the office in Iran) with Iranian government-owned
entities. No material revenues or profits are associated with these transactions with the Iranian
government-owned entities.
Sony is not aware of any other activity, transaction or dealing by Sony Corporation or any of its affiliates
during the fiscal year ended March 31, 2016 that is disclosable in this report under Section 13(r) of the Exchange
Act. As of the date of this report, Sony does not anticipate that any activity, transaction or dealing that may be
disclosable will be conducted during the fiscal year ending March 31, 2017, except as described above in
connection with the wind-down of its representative office or for certain transactions through third-party-owned
dealers that Sony believes to be intended for hospitals and health organizations in Iran. Nevertheless, Sony
continues to monitor developments in this area, especially in the light of the Joint Comprehensive Plan of Action
of July 14, 2015, among the United States, the United Kingdom, China, France, Russia, Germany, the European
Union and Iran, and will determine whether and to what extent they affect Sony’s business with Iranian
customers as currently conducted and may additionally be conducted. Such business activities may require
disclosure pursuant to Section 13(r) of the Exchange Act. Sony intends to conduct any such business activities in
accordance with applicable law.
Sony believes, and maintains policies and procedures designed to ensure that, its transactions with Iran and
elsewhere have been conducted in accordance with applicable economic sanctions laws and regulations and do
not involve transactions likely to result in the imposition of sanctions or other penalties on Sony. However, there
can be no assurance that Sony’s policies and procedures will be effective, and if the relevant authorities were to
impose penalties or sanctions against Sony, the impact of such sanctions could be material.
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