Protecting Pennsylvania's Investments Act - Pennsylvania Treasury

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Annual Report of Activities Pursuant to Act 44 of 2010 September 30, 2011 COMPANY NAME IRAN SUDAN DATE RESPONDED STATUS CHANGE ACTIONS TAKEN Royal Dutch Shell Plc x 2/7/2011; 4/13/11 Past Involvement Removal from list Sasol Ltd. x 3/11/2011 No Change None Sojitz Corp. x 11/26/2010 Past Involvement Removal from list Technip x 11/30/2010 No Change None Total S.A. x x Toyo Engineering Corporation 11/30/2010; 3/29/2011 x 11/24/2010 Sudan: No Change; Iran: Plan to Cease Clarified Involvement Sudan: On list, Iran: Not Changed Removal from list Table 6: Correspondence from Companies Initially Determined as Not Directly Held by One or More of the Four Funds Table 6 lists companies that were initially determined to not be directly held by one of the Four Funds that have responded to the notification of scrutinized status, and what actions were taken (if any) due to their correspondence. COMPANY NAME IRAN SUDAN DATE RESPONDED STATUS CHANGE ACTIONS TAKEN Ao Tatneft x x 12/6/2010 Egyptians Abroad for Investment & Development Egyptians Housing Development & Reconstruction Ina-Industrija Nafte DD x Past Involvement Iran: Removal from list Sudan: Removal from list x 11/23/2010 No Change None x 11/23/2010 No Change None 4/14/2011; 7/15/2011 Clarified Involvement Removal from list Kencana Petroleum Bhd x 12/15/2010 No Change None Page 25 of 138
Annual Report of Activities Pursuant to Act 44 of 2010 September 30, 2011 Divestment Process and Activities The Act lays out a process and timeline for divestment from any directly-held scrutinized company that fails to take significant action with regard to its involvement. Timeline B: Scrutinized Company Divestment Timeline Notice is Sent If Four Funds receive notice of substantial action 180 Days If Four Funds do not receive notice of substantial action 1 Year 26 Months If substantial action is completed, company is removed from scrutinized company list If substantial action is not completed (or if new restricted activity is identified) The fund must divest securities 26 Months The fund must divest securities � When a scrutinized company is identified, a notice is sent advising the company as to its status. The notification provides an explanation of the reason for the company’s inclusion on a list of scrutinized companies and of the potential for any related securities held by the public fund to be divested. The notice also informs the company of the opportunity to clarify its scrutinized business activities and encourages the company to cease its scrutinized activities. � If within 180 days of the date of receipt of this notice the company announces by public disclosure substantial action (i.e., publicizing and implementing a formal plan to cease scrutinized business activities within one year and refrain from any such new business activities), the public fund may maintain its holdings in securities relating to the scrutinized company. The company, however, will remain on the scrutinized company list(s) until the actual cessation of scrutinized business activities. o If the company fails to follow through with disclosed substantial action within one year, or if the company engages in new scrutinized business activities within a country of concern, then the fund will divest securities related to the scrutinized company within 26 months after expiration of the one-year period. Page 26 of 138
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Protecting Pennsylvania's Investments Act - Pennsylvania Treasury

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