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BP » Topics » Overview of the group, page 11

This excerpt taken from the BP CORRESP filed Nov 4, 2008.

Overview of the group, page 11

1.     

We note the disclosure on page 11 and 12 in your Form 20-F regarding your contacts with certain countries that the United States Department of State has identified as state sponsors of terrorism. We also have reviewed prior correspondence between BP and the staff pertaining to your contacts with those countries. Please tell us whether you have entered into any additional business arrangements relating to Iran, Sudan or Syria since December 31, 2006, and, if so, describe the arrangements. Please also tell us whether the percentages of sales and other operating revenues, purchases and assets attributable to your contacts with those countries in fiscal 2007 approximate the percentages set forth in the earlier correspondence as attributable to contacts with those countries in prior fiscal periods.

BP p.l.c., 1 St James's Square, LONDON, SW1Y 4PD
Registered in England & Wales - No: 102498

Response: BP has not entered into any additional types of business activity relating to Iran, Sudan or Syria since December 31, 2006.

As indicated in our prior correspondence with the Staff and in our Form 20-F, BP believes that its activities in these countries are immaterial to the group.

Purchases and sales attributable to BP’s contacts with Syria represented 0.14% and less than 0.01% of the group’s total purchases and total sales and other operating revenues respectively, for the year ended December 31, 2007. BP has no assets in Syria.

BP’s sales relating to interests in two fields (Shah Deniz in the Azerbaijan sector of the Caspian Sea and Rhum in the North Sea) and the South Caucasus Pipeline (from Azerbaijan through Georgia to Turkey) in which the National Iranian Oil Company (NIOC) and an affiliated entity have interests, represented 0.14% of total sales and other operating revenues and the associated assets represented 0.71% of BP’s total assets. Purchases of crude oil in Iran represented 0.29% of the group’s total purchases for the year ended December 31, 2007. Purchases and sales by BP’s joint venture in Iran represented less than 0.01% of the group’s total purchases and total sales and other operating revenues respectively for the year ended December 31, 2007. BP’s share of the net assets of its joint venture in Iran represents less than 0.01% of total group assets.

BP has no purchases, sales and other operating revenues or assets in Sudan.

Our jet fuel and marine businesses, which operate at airports and maritime ports around the world (but not in Syria, Iran or Sudan) sell small quantities of fuel and lubricants to airlines and shipping companies from these countries which re-fuel at such airports and ports.

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