Deferred Prosecution Agreement Between Us and Tenaris, S.A.

UNITED STATES OF AMERICA
 
SECURITIES AND EXCHANGE COMMISSION
 
DEFERRED PROSECUTION AGREEMENT 
1. In connection with an investigation, the Division ofEnforcement ("Division") of 
the United States Securities and Exchange Commission ("Commission") alleges that 
Tenaris, S.A. ("Respondent" or "Tenaris"), in or about 2006 through 2008, violated 
Sections 13(b)(2)(A), 13(b)(2)(B) and 30A 
of the Securities Exchange Act of 1934 
("Exchange Act") by making payments to certain Uzbekistani government officials in 
order to secure an improper advantage in the bidding process for Uzbekistani government 
contracts and 
by failing to keep accurate books and records relating to those transactions, 
and 
by failing to maintain internal controls to ensure that the transactions in Uzbekistan 
were properly authorized by management and that the financial statements were prepared 
in conformity with generally accepted accounting principles ("Investigation"). Prior to a 
public enforcement action being brought by the Commission against it, without admitting 
or denying these allegations, Respondent has offered to accept responsibility for its 
conduct and to not contest or contradict the factual statements contained in Paragraph 6 in 
any future Commission enforcement action in the event it breaches this Agreement. 
Accordingly, the Commission and the Respondent enter into a deferred prosecution 
agreement ("Agreement") with the following terms and conditions: 
TERM 
2. The Respondent understands and agrees that the provisions of this Agreement are 
in full force and effect from May 17, 
2011 to May 17, 2013 ("Deferred Period"), unless 
expressly stated otherWise. 
COOPERA
nON 
3. The Respondent, a corporation organized and operating under the laws of 
Luxembourg and its subsidiaries ("Related Entities") agree to cooperate fully and 
truthfully in the Investigation and any other related enforcement litigation or proceeding 
to which the Commission is a party (the "Proceedings"), regardless ofthe time period in 
which the cooperation is required. In addition, the Respondent agrees to cooperate fully 
and truthfully, when directed by the Division's staff, in any other related official 
investigation or proceeding by any 
U.s. federal, state, or self-regulatory organization 
("Other Proceedings"). The full, truthful, and continuing cooperation 
ofthe Respondent 
and Related Entities shall include, but not be limited to: 
a. producing, in a responsive and prompt manner, all non-privileged 
documents, information, and other materials to the Commission as requested by the 
Division's staff, wherever located, in the possession, custody, or control 
of the 
Respondent or any 
of its Related Entities; and 

b. using its best efforts to secure the full, truthful, and continuing· 
cooperation, as defined in Paragraph 4, 
ofcurrent and former directors, officers, 
employees and agents, including making these persons available, when requested to do so 
by the Division's staff, at its expense, for interviews and the provision 
oftestimony in the 
investigation, trial and other judicial proceedings in connection with the Proceedings or 
Other Proceedings. 
4. The full, truthful, and continuing cooperation 
of each person described in 
Paragraph 3 above will be subject to the procedures and protections 
ofthis paragraph, 
and shall include, but not be limited to: 
a. producing all non-privileged documents and other materials as requested 
by the Division's staff;· 
b. appearing for interviews, at such times and places, as requested by the 
Division's staff; 
c. responding to all inquiries, when requested to do so by the Division's 
staff, in connection with the Proceedings 
or Other Proceedings; and 
d. testifying at trial and other judicial proceedings, when requested to do so 
by the Division's staff, in connection with the Proceedings or Other Proceedings. 
STATUTE OF LIMITATIONS 
5. The Respondent agrees that the running ofany statute oflimitations applicable to 
any action or proceeding against it authorized, instituted, or brought by or on behalf of 
the Commission arising out ofthe Investigation ("Proceeding"), including any sanctions 
or reliefthat may be
imposed therein, is tolled and suspended during the Deferred Period. 
a. The Respondent and any of its attorneys or agents shall not include the 
Deferred Period in the calculation 
ofthe running ofany statute of limitations or for any 
other time-related defense applicable to the Proceeding, including any sanctions or relief 
that may be imposed therein, in asserting or relying upon any such time-related defense. 
b. This agreement shall not affect any applicable statute 
of limitations 
defense or any other time-related defense that may be available to Respondent before the 
commencement 
ofthe Deferred Period or be construed to revive a Proceeding that may 
be barred by any applicable statute oflimitations or any other time-related defense before 
the commencement 
ofthe Deferred Period. 
c. The running 
of any statute of limitations applicable to the Proceeding shall 
commence again after the end 
ofthe Deferred Period, unless there is an extension ofthe 
Deferred Period executed in writing by or 
on behalf of the parties hereto. 
2 

d. This agreement shall not be construed as an admission by the Commission 
relating to the applicability 
of any statute of limitations to the Proceeding, including any 
sanctions or relief that may be imposed therein, or to the length 
of any limitations period 
that may apply, or to the applicability of any other time-related defense. 
STATEMENT OF FACTS
l 
6. If this case had gone to trial, the Commission would have presented evidence 
sufficient to prove the following facts: 
Tenaris, SA. 
a. Tenaris, S.A. was a corporation organized under the laws of Luxembourg. 
Tenaris was a global manufacturer and supplier 
of steel pipe products and related 
services. Tenaris's 
ADS's were listed on the New York Stock exchange and Tenaris's 
stock was listed on the exchanges 
of Argentina, Italy, and Mexico. Tenaris had annual 
revenues of $9.9 billion in 2007 and $12 billion in 2008, and had more than 24,000 
employees worldwide. Tenaris, and through its 
17 subsidiaries, operated in 12 countries 
and its customers included the world's leading oil and gas companies, as well as 
engineering companies engaged in constructing oil and gas gathering, transportation, and 
processing facilities. 
b. Tenaris's operations included steel pipe sales in the Caspian Sea region, 
including Uzbekistan. The Caspian Sea region accounted for an average 
of 
approximately 5% of Tenaris's global oilfield services sales and approximately 1% of 
Tenaris's total global sales and services from 2003 to 2008. Tenaris did not have an 
office in Uzbekistan. Its Caspian Sea business was run from offices in Azerbaijan and 
Kazakhstan. 
c. Tenaris obtained steel pipe sales in the Caspian Sea region in part by 
bidding on contracts solicited by government-owned companies, private companies or 
quasi-governmental entities to provide pipeline used in the development and production 
of oil and natural gas. Tenaris often used agents to assist in bidding on contracts in the 
Caspian Sea region. Among other services, those agents provided Tenaris with access to 
information and people that helped it tender bids that had a greater likelihood 
of being 
awarded by the governmental entities soliciting them. 
DAD Contracts 2006-2007 
d. Between in or around April 2006 through May 2007, Tenaris bid on a 
series of contracts with OJSC O'ztashqineftgaz ("OAO"), to supply OAO with pipeline 
for use in the development and production 
of oil and natural gas in Uzbekistan. OAO 
1 The facts set forth in this section are made pursuant to settlement negotiations associated with the 
violations alleged by the Division in Paragraph 1 of this Agreement and are not binding against Tenaris in 
any other legal proceeding or on any other person or entity. 
3 

was a subsidiary ofUzbekneftegaz, the state-owned holding company ofUzbekistan's oil 
and gas industry. 
e. OAO was an agency and instrumentality ofthe government ofUzbekistan 
and its employees were "foreign officials" within the meaning 
of Section 30A(f)(1)(A) of 
the Exchange Act. 
f. In or around December 2006, Tenaris was introduced to a potential agent 
("Agent") to help Tenaris bid on certain contracts with OAO. As an incentive to retain 
the Agent, the Agent offered Tenaris's then-regional sales personnel access to the 
confidential bid information 
of competitors obtained from officials in OAO's tender 
department, who also would allow Tenaris to submit revised bids. Tenaris's then­
regional sales personnel would use the confidential competitor bid information to submit 
revised bids in order to increase the likelihood 
of Tenaris being awarded the underlying 
contract. 
g. 
In or around January 2007, Tenaris entered into an agreement with the 
Agent to use its services in bidding on OAO contract M-07-53. Tenaris agreed to pay the 
Agent a commission 
of3.5% for its services related to that contract. 
h. 
In or around February 2007, Tenaris bid on contract M-07-53, utilizing the 
Agent's services, which included obtaining confidential bid information 
of Tenaris's 
competitors through OAO officials and thereafter submitting a revised bid to OAO 
through its officials who were cooperating with the Agent. 
. 
i. On or about April 30, 2007, Tenaris was awarded contract M-07-53 based 
on its revised bid. Pursuant to the terms 
of contract M-07-53, OAO agreed to pay Tenaris 
$2,719,720 for pipe used in oil and gas development in Uzbekistan. 
j. Between in or around April and May 2007, Tenaris bid 
on 3 additional 
contracts with OAO utilizing the Agent. 
In bidding on those contracts, Tenaris's then­
regional sales personnel again obtained the confidential bid information 
of its competitors 
from OAO officials and submitted revised bids to those officials utilizing that 
confidential bid information. 
k. As a result 
of Tenaris's then-regional sales personnel's use ofthe bid 
information 
ofits competitors, Tenaris was awarded contracts M-07-70, M-07-71 and M­
07-72 on 
or around May 22, 2007. Tenaris agreed to pay the Agent a 3% commission for 
its services related to contracts M-07-70, M-07-71, and M-07-72. 
1. OAO agreed to pay Tenaris $1,499,367 under contract M-07-70, 
$6,378,657 under contract M-07-71 and $8,797,980 under contract M-07-72, for pipe and 
related services. 
m. Tenaris paid the Agent commissions for its services related to contracts 
M-07-53, M-07-70, M-07-71 and M-07-72. In making such payments, Tenaris made use 
4
 

ofthe means and instrumentalities ofinterstate commerce in furtherance of such 
payments, including a payment to the Agent on or about July 2, 2007, via same day 
transfer 
of approximately $32,140.67 through an intermediary bank:, Wachovia Bank: NY 
International, utilizing routing number xxx9 and account number 3xxxxxx1. 
n. Tenaris's then-regional sales personnel understood that a portion of the 
commission Tenaris paid to the Agent for services related to contracts M-07-53, M-07­
70, M-07-71 and M-07-72 would be used to pay OAO officials for opening competitors' 
bids, providing confidential bid information to Tenaris, and replacing Tenaris's original 
bids with its revised bids. 
o. The conduct of the OAO officials in providing Tenaris with confidential 
bid information and allowing Tenaris's then-regional sales personnel to resubmit revised 
bids was in violation 
of the OAO officials' lawful duty and was done in order to assist 
Tenaris in obtaining or retaining business in Uzbekistan. 
p. According to e-mails written by Tenaris's then-regional sales personnel, in 
or around November 2007, the Agent informed Tenaris's then-regional sales personnel 
that Tenaris's competitors in Uzbekistan had complained to an Uzbekistani government 
agency, Uzbekexpertiza JSC ("Uzbekexpertiza"), that Tenaris had obtained access to 
competitor bid information for contracts M-07-70, M-07-71, and M-07-72. 
q. Uzbekexpertiza was an agency and instrumentality of the government of 
Uzbekistan and its employees were "foreign officials" within the meaning of Section 
30A(f)(1)(A) 
of the Exchange Act. 
r. Uzbekexpertiza had the authority to cause an investigation ofthe bidding 
process in which Tenaris bid for contracts M-07-70, M-07-71, and M-07-72. 
s. According to e-mails written by Tenaris's then-regional sales personnel, in 
an effort to avert the potential investigation 
of the bidding process, the Agent 
recommended that Tenaris and the Agent pay Uzbekexpertiza officials to refrain from 
recommending an investigation against Tenaris or re-opening the bidding process to 
Tenaris's competitors. 
t. Certain e-mails suggest that Tenaris's then-regional sales personnel agreed 
to pay the recommended payment to Uzbekexpertiza officials by the end 
of December 
2007 in order to avert an investigation into the bidding process 
of contracts M-07-70, M­
07-71, and M-07-72. 
It is unknown whether Tenaris ever made any such payment, and 
Tenaris has found no records evidencing any payment. 
u. The agreement among Tenaris's then-regional sales personnel to pay the 
payment to the Uzbekexpertiza officials as recommended by the Agent was described by 
Tenaris's then-regional sales personnel as having been made to assist Tenaris in obtaining 
or retaining business in Uzbekistan. 
5
 

v. In the summer of2008, the M-07-70 contract and all outstanding portions 
of the M-07-72 contract were cancelled. In total, OAO paid Tenaris approximately 
$2,697,598 on the 07-53 contract, $4,585,312 on the 07-71 contract, and $1,651,663 on 
the 07-72 contract. Tenaris's combined profits on OAO contracts M-07-53, M-07-71, and 
M-07-72 were approximately $4,786,438. 
w. In or around 2007, the books, records and accounts reflecting Tenaris's 
transactions related to the OAO contracts, which involved payments to OAO foreign 
officials, were incorporated into Tenaris's consolidated year-end financial statements for 
the respective year. 
x. In or around 2007, Tenaris failed to make and keep books, records, and
 
accounts which accurately and fairly reflected Tenaris's transactions with the agent
 
described above, and which failed to accurately record the payments to OAO officials.
 
y. In or around 2007, Tenaris's system of internal controls failed to detect or 
prevent payments to OAO officials in an effort to obtain and retain business in 
Uzbekistan, including a failure to ensure that proper and effective due diligence was 
conducted on the Agent for the OAO contracts, and that the review process for 
authorization or approval 
ofpayments to the Agent failed to detect or prevent the illegal 
payments to OAO officials. Tenaris's policies, procedures and training related to 
anticorruption and the Foreign Corrupt Practices Act ("FCPA") compliance in place at 
that time warranted further strengthening to ensure effective compliance with the related 
laws. 
Tenaris's Disclosure 
z. In or about March 2009, a third party disclosed to Tenaris that it had 
become aware that certain sales agency payments made by Tenaris may have improperly 
benefited employees 
of the third party. In response to that information the Audit 
Committee ofTenaris's Board 
ofDirectors retained Sullivan & Cromwell LLP to 
investigate the allegations. Thereafter, in a Form 20-F filed with the Commission on or 
about June 30, 2009, Tenaris disclosed the customer's allegations, Tenaris's internal 
investigation, andthatit hadinformedstaff
ofthe DivisionandDepartment ofJustice 
("DOl") about the allegations by the third party. 
aa. InoraboutJuly2009,counselforTenarismetwiththestaff 
ofthe 
DivisionandDepartment 
ofJustice ("DOJ"),anddisclosedpreliminaryfindings ofthe 
internal investigation. Such disclosure was not related to the facts concerning 
transactions in Uzbekistan. Tenaris counsel informed staff 
of the Division and DOJ that 
it would conduct a more detailed internal investigation, and would report its findings to 
the staff. 
bb. Tenaris's internal investigation included a world-wide investigation 
of its 
business operations and controls. Beginning in or about July 2010, Tenaris counsel met 
with the staff 
of the Division and DOJ to disclose facts related to its internal 
6
 

investigation. Tenaris provided extensive, thorough, real-time cooperation with the staff 
ofthe Division and DOl which included timely, voluntary and complete disclosure of 
certain conduct, including the facts described above. As a result of its internal 
investigation, Tenaris discovered facts and transactions in Uzbekistan which Tenaris 
included in the report provided to the staff. Tenaris also thoroughly reviewed its 
pre-existing compliance program and undertook steps to update and improve its 
compliance program, and to continue to implement enhanced compliance measures. 
These steps included, in part, adoption 
ofa strengthened Code ofConduct, Business 
Conduct Policy, and Agent Retention Procedure that address anticorruption and 
compliance with the FCPA, and provide for enhanced due diligence procedures related to 
the retention 
ofthird party agents and review ofpayments to third party agents. Tenaris 
has agreed to provide real and meaningful cooperation with the Commission, 
DOl and 
any law enforcement agency in connection with this matter. 
PROHIBITIONS 
7. During the Deferred Period, the Respondent understands and agrees to comply 
with the following prohibitions: 
a. to refrain from violating the U.S. federal and state securities laws; 
b. to refrain from seeking 
or accepting a U.S. federal or state tax credit or 
deduction for any monies paid pursuant to this Agreement; and 
c. to refrain from seeking or accepting reimbursement or indemnification 
from any source, including, but not limited to, payment made pursuant to 
an insurance 
policy 
or employment contract, with regard to any monies paid pursuant to this 
Agreement. 
UNDERTAKINGS 
8. During the Deferred Period, the Respondent understands and agrees to perform 
the following undertakings: 
a. to provide written notification to the Division, within fourteen days, if it 
(1) has been charged or convicted ofan offense by any U.S. federal, state, or local law 
enforcement organization 
or regulatory agency, or (2) has been charged or convicted of 
an offense by any foreign law enforcement organization or regulatory agency relating to 
any anti-bribery or securities law, regulation or rule; 
b. to provide written notification to the Division, within fourteen days, 
if a 
formal or informal complaint has been made against it, or disciplinary action has been 
taken against it by any 
self regulatory organization relating to any anti-bribery or 
securities law, regulation or rule; 
7 

c. to pay disgorgement obtained or retained as a result ofthe violations 
alleged in Paragraph 1 in the amount 
of $4,786,438 plus prejudgment interest of an 
estimated $641,900 for a total of$5,428,338 within 30 days by delivering or mailing by 
next-day mail a certified check, bank cashier's check, or United States postal money 
order, payable to the Securities and Exchange Commission, to the Office 
of Financial 
Management, Securities and Exchange Commission, Operations Center, 6432 General 
Green Way, Mail Stop 0-3, Alexandria, Virginia 22312 along with a letter identifying the 
Respondent and specifying that the payment is made pursuant to a deferred prosecution 
agreement entered into with the Commission on May 17, 2011 and send an additional 
copy
oftheletterandcheckinaccordancewiththe servicerequirements ofParagraph 11; 
d. to provide the Division with a written certification of compliance with the 
prohibitions and undertakings in this Agreement between forty-five and sixty days before 
the end 
of the Deferred Period; 
e. to review annually and update, as appropriate, the Code of Conduct 
beginning on February 1,2012; 
f. to require that each director, officer, and management-level employee 
certify compliance with the Code 
of Conduct on an annual basis beginning on February 
1,2011; and 
g. to conduct effective training regarding anticorruption and compliance with 
the FCPA for (1) all current officers and managers, (2) all employees working in Finance, 
Accounting, Internal Audit, Sales, and Government Relations, (3) all other employees 
working in positions Tenaris deems to involve activities implicated by Tenaris's policies 
regarding anticorruption and compliance with the FCPA, on or before December 31, 
2011, and (4) all such future employees within 90 days 
oftheir affiliation with Tenaris. 
PUBLIC STATEMENTS 
9. After the Deferred Period begins, on May 17,2011, the Respondent agrees not to 
take any action or to make or permit any public statement through present or future 
attorneys, employees, Agents, or other persons authorized to speak for it, except in legal 
proceedings in which the Commission is not a party, denying, directly or indirectly, any 
aspect 
ofthis Agreement or creating the impression that the allegations in Paragraph 6 of 
this Agreement are without factual basis. This paragraph is not intended to apply to any 
statement made by an individual in the course 
ofany criminal, civil, or regulatory 
proceeding initiated by the government or self-regulatory organization against such 
individual, unless such individual is speaking on behalf ofthe Respondent. Ifit is 
determined by the Commission that a public statement by the Respondent or any related 
person contradicts in whole or in part this Agreement, at its sole discretion, the 
Commission may bring an enforcement action in accordance with Paragraphs 12 through 
15. 
8
 

10. Prior to issuing a press release concerning this Agreement, the Respondent agrees 
to have the text 
of the release approved by the staff of the Division. 
SERVICE 
11. The Respondent agrees to serve by hand delivery or by next-day mail all written 
notices and correspondence required by or related to this Agreement to Karen L. 
Martinez, 
15 W. South Temple, Suite 1800, Salt Lake City, UT 84101, (801) 524-5796, 
unless otherwise directed in writing by the staff 
of the Division. 
VIOLA
nON OF AGREEMENT 
12. The Respondent understands and agrees that it shall be a violation ofthis 
Agreement 
if it knowingly provides false or misleading information or materials in 
connection with the Proceedings or Other Proceedings. In the event 
of such misconduct, 
the Division will advise the Commission 
ofthe Respondent's misconduct and may make 
a criminal referral for providing false information (18 U.S.C. § 1001), contempt (18 
U.S.c. 
§§ 401-402) and/or obstructing justice (18 U.S.C. § 1503 et seq.). 
13. The Respondent understands and agrees that, should the Division determine that 
the Respondent has failed to comply with any term or condition 
of this Agreement, the 
Division will notify the Respondent or its counsel 
of the fact and provide an opportunity 
for the Respondent to make a Wells submission pursuant to the Securities Act 
of 1933 
Release No. 5310. Under these circumstances, the Division may, in its sole discretion 
and not subject to judicial review, recommend to the Commission an enforcement action 
against the Respondent for any securities law violations, including, but not limited to, the 
substantive offenses relating to the Investigation. 
14. The Respondent understands and agrees that in any future enforcement action 
resulting from its violation 
ofthe Agreement, any documents, statements, information, 
testimony, or evidence provided by it during the Proceedings or Other Proceedings, and 
any leads derived there from, may be used against it in future legal proceedings. 
15. In the event it breaches this Agreement, the Respondent agrees not to contest or 
contradict in any future Commission enforcement action the factual statements contained 
in Paragraph 6 above as admissions pursuant to Federal Rule 
ofEvidence 801(d)(2). 
COMPLIANCE WITH AGREEMENT 
16. Subject to the full, truthful, and continuing cooperation ofthe Respondent, as 
described in Paragraphs 3 and 4, and compliance by Respondent with all obligations, 
prohibitions and undertakings in the Agreement during the Deferred Period, the 
Commission agrees not to bring any enforcement action or proceeding against the 
Respondent arising from the Investigation, after the conclusion 
of the Deferred Period. 
9
 

17. The Respondent understands and agrees that this Agreement does not bind other 
U.S. federal, state or self-regulatory organizations, but the Commission may, at its 
discretion, issue a letter to these organizations detailing the fact, manner, and extent 
of its 
cooperation during the Proceedings or Other Proceedings, upon the written request 
of the 
Respondent. 
18. The Respondent understands and agrees that 
if it sells, merges, or transfers all or 
substantially all 
ofits business operations as they exist as ofthe date ofthis Agreement, 
whether such a sale is structured as a stock or asset sale, merger, or transfer during the 
Deferred Period, it shall include in any contract for sale, merger, or transfer a provision 
binding the purchaser or successor in interest to the obligations set forth in this 
Agreement. 
19. The Respondent understands and agrees that the Agreement only provides 
protection against enforcement actions arising from the Investigation and does not relate 
to any other violations or any individual or entity other than the Respondent. 
VOLUNTARY AGREEMENT 
20. The Respondent's decision to enter into this Agreement is freely and voluntarily 
made and is  not the result 
of force, threats, assurances, promises, or representations other 
than those contained in this Agreement. 
21. The Respondent has read and understands this Agreement. Furthermore, the 
Respondent has reviewed all legal and factual aspects 
of this matter with its attorney and 
is fully satisfied with its attorney's legal representation. The Respondent has thorougWy 
reviewed this Agreement with its attorney and has received satisfactory explanations 
concerning each paragraph 
ofthe Agreement. After conferring with its attorney and 
considering all available alternatives, the Respondent has made a knowing decision to 
enter into the Agreement. 
22. The Respondent represents that its Board 
ofDirectors has duly authorized, in a 
the resolution attached as Exhibit A, the execution and delivery 
ofthis Agreement, and 
that the person signing this Agreement has authority to bind the Respondent. 
ENTIRETY OF AGREEMENT 
23. This Agreement constitutes the entire agreement between the Commission and the 
Respondent, and supersedes all prior understandings, 
if any, whether oral or written, 
relating to the subject matter herein. 
24. This Agreement cannot be modified except in writing, signed by the Respondent 
and a representative 
ofthe Commission. 
10 

 
 
 
25. In the event an ambiguity or a question ofintent or interpretation arises, tbis 
Agreement shall be coostmed as ifdrafted jointlybythepartieshereto. andno 
presumption or burdenofproofshallarisefavoringordisfavoringthe Commission orthe 
Respondent byvirtue ofthe authorship ofany ofthe provisions ofthe Agreement. 
The signatories below aclmowledge acceptance of1hc foregoing terms and conditions. 
RESPONDENT 
Ricardo Soler 
ChiefFinancial Officer 
Tenaris 
SA. 
46A, avenue John F. Kennedy 
L-1855 Lux.embomg 
Attached hereto is the Ce~ateofthe Secretary10 ~ Board ofDiJ:ectDrs ofTe:naris 
S.A., 
certifying thatRicardo Soler is, and atthe timeofthe signing and deliveryofthe 
Agreement was, the duly appointed, qualified and acting ChiefFinanciaI Officerofthe 
Company anddulyauthorized to execute the Agreement on behalfofthe Company, and 
thattbe signatureofRicardo Solerappearing on the. Agreement is his genuine signature. 
RESPONDENTS COUNSEL 
Approved as 10 form: 
fi1:1i.~f} 
Sullivan & Cromwell ILl' 
125 Broad Street 
NewYor~NY10004-2498 
(212) 558-3121 
SECURII1ES AND EXCHANGE COMMISSION 
DIVISION OF ENFORCEMENT 
tfl::t j 7, ;;<DIJ 
11 

UNITED STATES OF AMERICA
 
SECURITIES AND EXCHANGE COMMISSION
 

DEFERRED PROSECUTION AGREEMENT 

1. In connection with an investigation, the Division ofEnforcement ("Division") of 
the United States Securities and Exchange Commission ("Commission") alleges that 
Tenaris, S.A. ("Respondent" or "Tenaris"), in or about 2006 through 2008, violated 
Sections 13(b)(2)(A), 13(b)(2)(B) and 30A of the Securities Exchange Act of 1934 
("Exchange Act") by making payments to certain Uzbekistani government officials in 
order to secure an improper advantage in the bidding process for Uzbekistani government 
contracts and by failing to keep accurate books and records relating to those transactions, 
and by failing to maintain internal controls to ensure that the transactions in Uzbekistan 
were properly authorized by management and that the financial statements were prepared 
in conformity with generally accepted accounting principles ("Investigation"). Prior to a 
public enforcement action being brought by the Commission against it, without admitting 
or denying these allegations, Respondent has offered to accept responsibility for its 
conduct and to not contest or contradict the factual statements contained in Paragraph 6 in 
any future Commission enforcement action in the event it breaches this Agreement. 
Accordingly, the Commission and the Respondent enter into a deferred prosecution 
agreement ("Agreement") with the following terms and conditions: 

TERM 

2. The Respondent understands and agrees that the provisions of this Agreement are 
in full force and effect from May 17, 2011 to May 17, 2013 ("Deferred Period"), unless 
expressly stated otherWise. 

COOPERAnON 

3. The Respondent, a corporation organized and operating under the laws of 
Luxembourg and its subsidiaries ("Related Entities") agree to cooperate fully and 
truthfully in the Investigation and any other related enforcement litigation or proceeding 
to which the Commission is a party (the "Proceedings"), regardless ofthe time period in 
which the cooperation is required. In addition, the Respondent agrees to cooperate fully 
and truthfully, when directed by the Division's staff, in any other related official 
investigation or proceeding by any U.s. federal, state, or self-regulatory organization 
("Other Proceedings"). The full, truthful, and continuing cooperation of the Respondent 
and Related Entities shall include, but not be limited to: 

a. producing, in a responsive and prompt manner, all non-privileged 
documents, information, and other materials to the Commission as requested by the 
Division's staff, wherever located, in the possession, custody, or control of the 
Respondent or any of its Related Entities; and 



b. using its best efforts to secure the full, truthful, and continuing· 
cooperation, as defined in Paragraph 4, of current and former directors, officers, 
employees and agents, including making these persons available, when requested to do so 
by the Division's staff, at its expense, for interviews and the provision of testimony in the 
investigation, trial and other judicial proceedings in connection with the Proceedings or 
Other Proceedings. 

4. The full, truthful, and continuing cooperation of each person described in 
Paragraph 3 above will be subject to the procedures and protections of this paragraph, 
and shall include, but not be limited to: 

a. producing all non-privileged documents and other materials as requested 
by the Division's staff;· 

b. appearing for interviews, at such times and places, as requested by the 
Division's staff; 

c. responding to all inquiries, when requested to do so by the Division's 
staff, in connection with the Proceedings or Other Proceedings; and 

d. testifying at trial and other judicial proceedings, when requested to do so 
by the Division's staff, in connection with the Proceedings or Other Proceedings. 

STATUTE OF LIMITATIONS 

5. The Respondent agrees that the running of any statute of limitations applicable to 
any action or proceeding against it authorized, instituted, or brought by or on behalf of 
the Commission arising out of the Investigation ("Proceeding"), including any sanctions 
or reliefthat may be imposed therein, is tolled and suspended during the Deferred Period. 

a. The Respondent and any of its attorneys or agents shall not include the 
Deferred Period in the calculation of the running ofany statute of limitations or for any 
other time-related defense applicable to the Proceeding, including any sanctions or relief 
that may be imposed therein, in asserting or relying upon any such time-related defense. 

b. This agreement shall not affect any applicable statute of limitations 
defense or any other time-related defense that may be available to Respondent before the 
commencement of the Deferred Period or be construed to revive a Proceeding that may 
be barred by any applicable statute oflimitations or any other time-related defense before 
the commencement of the Deferred Period. 

c. The running of any statute of limitations applicable to the Proceeding shall 
commence again after the end of the Deferred Period, unless there is an extension of the 
Deferred Period executed in writing by or on behalf of the parties hereto. 

2 



d. This agreement shall not be construed as an admission by the Commission 
relating to the applicability of any statute of limitations to the Proceeding, including any 
sanctions or relief that may be imposed therein, or to the length of any limitations period 
that may apply, or to the applicability of any other time-related defense. 

STATEMENT OF FACTS l 

6. If this case had gone to trial, the Commission would have presented evidence 
sufficient to prove the following facts: 

Tenaris, SA. 

a. Tenaris, S.A. was a corporation organized under the laws of Luxembourg. 
Tenaris was a global manufacturer and supplier of steel pipe products and related 
services. Tenaris's ADS's were listed on the New York Stock exchange and Tenaris's 
stock was listed on the exchanges of Argentina, Italy, and Mexico. Tenaris had annual 
revenues of $9.9 billion in 2007 and $12 billion in 2008, and had more than 24,000 
employees worldwide. Tenaris, and through its 17 subsidiaries, operated in 12 countries 
and its customers included the world's leading oil and gas companies, as well as 
engineering companies engaged in constructing oil and gas gathering, transportation, and 
processing facilities. 

b. Tenaris's operations included steel pipe sales in the Caspian Sea region, 
including Uzbekistan. The Caspian Sea region accounted for an average of 
approximately 5% of Tenaris's global oilfield services sales and approximately 1% of 
Tenaris's total global sales and services from 2003 to 2008. Tenaris did not have an 
office in Uzbekistan. Its Caspian Sea business was run from offices in Azerbaijan and 
Kazakhstan. 

c. Tenaris obtained steel pipe sales in the Caspian Sea region in part by 
bidding on contracts solicited by government-owned companies, private companies or 
quasi- governmental entities to provide pipeline used in the development and production 
of oil and natural gas. Tenaris often used agents to assist in bidding on contracts in the 
Caspian Sea region. Among other services, those agents provided Tenaris with access to 
information and people that helped it tender bids that had a greater likelihood of being 
awarded by the governmental entities soliciting them. 

DAD Contracts 2006-2007 

d. Between in or around April 2006 through May 2007, Tenaris bid on a 
series of contracts with OJSC O'ztashqineftgaz ("OAO"), to supply OAO with pipeline 
for use in the development and production of oil and natural gas in Uzbekistan. OAO 

1 The facts set forth in this section are made pursuant to settlement negotiations associated with the 
violations alleged by the Division in Paragraph 1 of this Agreement and are not binding against Tenaris in 
any other legal proceeding or on any other person or entity. 

3 



was a subsidiary ofUzbekneftegaz, the state-owned holding company of Uzbekistan's oil 
and gas industry. 

e. OAO was an agency and instrumentality of the government of Uzbekistan 
and its employees were "foreign officials" within the meaning of Section 30A(f)(1 )(A) of 
the Exchange Act. 

f. In or around December 2006, Tenaris was introduced to a potential agent 
("Agent") to help Tenaris bid on certain contracts with OAO. As an incentive to retain 
the Agent, the Agent offered Tenaris's then-regional sales personnel access to the 
confidential bid information of competitors obtained from officials in OAO's tender 
department, who also would allow Tenaris to submit revised bids. Tenaris's then­
regional sales personnel would use the confidential competitor bid information to submit 
revised bids in order to increase the likelihood of Tenaris being awarded the underlying 
contract. 

g. In or around January 2007, Tenaris entered into an agreement with the 
Agent to use its services in bidding on OAO contract M-07-53. Tenaris agreed to pay the 
Agent a commission of3.5% for its services related to that contract. 

h. In or around February 2007, Tenaris bid on contract M-07-53, utilizing the 
Agent's services, which included obtaining confidential bid information of Tenaris's 
competitors through OAO officials and thereafter submitting a revised bid to OAO 
through its officials who were cooperating with the Agent. 

. 
i. On or about April 30, 2007, Tenaris was awarded contract M-07-53 based 

on its revised bid. Pursuant to the terms of contract M-07-53, OAO agreed to pay Tenaris 
$2,719,720 for pipe used in oil and gas development in Uzbekistan. 

j. Between in or around April and May 2007, Tenaris bid on 3 additional 
contracts with OAO utilizing the Agent. In bidding on those contracts, Tenaris's then­
regional sales personnel again obtained the confidential bid information of its competitors 
from OAO officials and submitted revised bids to those officials utilizing that 
confidential bid information. 

k. As a result of Tenaris's then-regional sales personnel's use of the bid 
information of its competitors, Tenaris was awarded contracts M-07-70, M-07-71 and M­
07-72 on or around May 22, 2007. Tenaris agreed to pay the Agent a 3% commission for 
its services related to contracts M-07-70, M-07-71, and M-07-72. 

1. OAO agreed to pay Tenaris $1,499,367 under contract M-07-70, 
$6,378,657 under contract M-07-71 and $8,797,980 under contract M-07-72, for pipe and 
related services. 

m. Tenaris paid the Agent commissions for its services related to contracts 
M-07-53, M-07-70, M-07-71 and M-07-72. In making such payments, Tenaris made use 

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of the means and instrumentalities of interstate commerce in furtherance of such 
payments, including a payment to the Agent on or about July 2, 2007, via same day 
transfer of approximately $32,140.67 through an intermediary bank:, Wachovia Bank: NY 
International, utilizing routing number xxx9 and account number 3xxxxxx1. 

n. Tenaris's then-regional sales personnel understood that a portion of the 
commission Tenaris paid to the Agent for services related to contracts M-07-53, M-07­
70, M-07-71 and M-07-72 would be used to pay OAO officials for opening competitors' 
bids, providing confidential bid information to Tenaris, and replacing Tenaris's original 
bids with its revised bids. 

o. The conduct of the OAO officials in providing Tenaris with confidential 
bid information and allowing Tenaris's then-regional sales personnel to resubmit revised 
bids was in violation of the OAO officials' lawful duty and was done in order to assist 
Tenaris in obtaining or retaining business in Uzbekistan. 

p. According to e-mails written by Tenaris's then-regional sales personnel, in 
or around November 2007, the Agent informed Tenaris's then-regional sales personnel 
that Tenaris's competitors in Uzbekistan had complained to an Uzbekistani government 
agency, Uzbekexpertiza JSC ("Uzbekexpertiza"), that Tenaris had obtained access to 
competitor bid information for contracts M-07-70, M-07-71, and M-07-72. 

q. Uzbekexpertiza was an agency and instrumentality of the government of 
Uzbekistan and its employees were "foreign officials" within the meaning of Section 
30A(f)(1)(A) of the Exchange Act. 

r. Uzbekexpertiza had the authority to cause an investigation of the bidding 
process in which Tenaris bid for contracts M-07-70, M-07-71, and M-07-72. 

s. According to e-mails written by Tenaris's then-regional sales personnel, in 
an effort to avert the potential investigation of the bidding process, the Agent 
recommended that Tenaris and the Agent pay Uzbekexpertiza officials to refrain from 
recommending an investigation against Tenaris or re-opening the bidding process to 
Tenaris's competitors. 

t. Certain e-mails suggest that Tenaris's then-regional sales personnel agreed 
to pay the recommended payment to Uzbekexpertiza officials by the end of December 
2007 in order to avert an investigation into the bidding process of contracts M-07-70, M­
07-71, and M-07-72. It is unknown whether Tenaris ever made any such payment, and 
Tenaris has found no records evidencing any payment. 

u. The agreement among Tenaris's then-regional sales personnel to pay the 
payment to the Uzbekexpertiza officials as recommended by the Agent was described by 
Tenaris's then-regional sales personnel as having been made to assist Tenaris in obtaining 
or retaining business in Uzbekistan. 

5
 



v. In the summer of2008, the M-07-70 contract and all outstanding portions 
of the M-07-72 contract were cancelled. In total, OAO paid Tenaris approximately 
$2,697,598 on the 07-53 contract, $4,585,312 on the 07-71 contract, and $1,651,663 on 
the 07-72 contract. Tenaris's combined profits on OAO contracts M-07-53, M-07-71, and 
M-07-72 were approximately $4,786,438. 

w. In or around 2007, the books, records and accounts reflecting Tenaris's 
transactions related to the OAO contracts, which involved payments to OAO foreign 
officials, were incorporated into Tenaris's consolidated year-end financial statements for 
the respective year. 

x. In or around 2007, Tenaris failed to make and keep books, records, and
 
accounts which accurately and fairly reflected Tenaris's transactions with the agent
 
described above, and which failed to accurately record the payments to OAO officials.
 

y. In or around 2007, Tenaris's system of internal controls failed to detect or 
prevent payments to OAO officials in an effort to obtain and retain business in 
Uzbekistan, including a failure to ensure that proper and effective due diligence was 
conducted on the Agent for the OAO contracts, and that the review process for 
authorization or approval ofpayments to the Agent failed to detect or prevent the illegal 
payments to OAO officials. Tenaris's policies, procedures and training related to 
anticorruption and the Foreign Corrupt Practices Act ("FCPA") compliance in place at 
that time warranted further strengthening to ensure effective compliance with the related 
laws. 

Tenaris's Disclosure 

z. In or about March 2009, a third party disclosed to Tenaris that it had 
become aware that certain sales agency payments made by Tenaris may have improperly 
benefited employees of the third party. In response to that information the Audit 
Committee ofTenaris's Board ofDirectors retained Sullivan & Cromwell LLP to 
investigate the allegations. Thereafter, in a Form 20-F filed with the Commission on or 
about June 30, 2009, Tenaris disclosed the customer's allegations, Tenaris's internal 
investigation, and that it had informed staffof the Division and Department of Justice 
("DOl") about the allegations by the third party. 

aa. In or about July 2009, counsel for Tenaris met with the staff of the 
Division and Department of Justice ("DOJ"), and disclosed preliminary findings of the 
internal investigation. Such disclosure was not related to the facts concerning 
transactions in Uzbekistan. Tenaris counsel informed staff of the Division and DOJ that 
it would conduct a more detailed internal investigation, and would report its findings to 
the staff. 

bb. Tenaris's internal investigation included a world-wide investigation of its 
business operations and controls. Beginning in or about July 2010, Tenaris counsel met 
with the staff of the Division and DOJ to disclose facts related to its internal 

6
 



investigation. Tenaris provided extensive, thorough, real-time cooperation with the staff 
of the Division and DOl which included timely, voluntary and complete disclosure of 
certain conduct, including the facts described above. As a result of its internal 
investigation, Tenaris discovered facts and transactions in Uzbekistan which Tenaris 
included in the report provided to the staff. Tenaris also thoroughly reviewed its 
pre-existing compliance program and undertook steps to update and improve its 
compliance program, and to continue to implement enhanced compliance measures. 
These steps included, in part, adoption of a strengthened Code of Conduct, Business 
Conduct Policy, and Agent Retention Procedure that address anticorruption and 
compliance with the FCPA, and provide for enhanced due diligence procedures related to 
the retention ofthird party agents and review ofpayments to third party agents. Tenaris 
has agreed to provide real and meaningful cooperation with the Commission, DOl and 
any law enforcement agency in connection with this matter. 

PROHIBITIONS 

7. During the Deferred Period, the Respondent understands and agrees to comply 
with the following prohibitions: 

a. to refrain from violating the U.S. federal and state securities laws; 

b. to refrain from seeking or accepting a U.S. federal or state tax credit or 
deduction for any monies paid pursuant to this Agreement; and 

c. to refrain from seeking or accepting reimbursement or indemnification 
from any source, including, but not limited to, payment made pursuant to an insurance 
policy or employment contract, with regard to any monies paid pursuant to this 
Agreement. 

UNDERTAKINGS 

8. During the Deferred Period, the Respondent understands and agrees to perform 
the following undertakings: 

a. to provide written notification to the Division, within fourteen days, if it 
(1) has been charged or convicted of an offense by any U.S. federal, state, or local law 
enforcement organization or regulatory agency, or (2) has been charged or convicted of 
an offense by any foreign law enforcement organization or regulatory agency relating to 
any anti-bribery or securities law, regulation or rule; 

b. to provide written notification to the Division, within fourteen days, if a 
formal or informal complaint has been made against it, or disciplinary action has been 
taken against it by any self regulatory organization relating to any anti-bribery or 
securities law, regulation or rule; 

7 



c. to pay disgorgement obtained or retained as a result of the violations 
alleged in Paragraph 1 in the amount of $4,786,438 plus prejudgment interest of an 
estimated $641,900 for a total of$5,428,338 within 30 days by delivering or mailing by 
next-day mail a certified check, bank cashier's check, or United States postal money 
order, payable to the Securities and Exchange Commission, to the Office of Financial 
Management, Securities and Exchange Commission, Operations Center, 6432 General 
Green Way, Mail Stop 0-3, Alexandria, Virginia 22312 along with a letter identifying the 
Respondent and specifying that the payment is made pursuant to a deferred prosecution 
agreement entered into with the Commission on May 17, 2011 and send an additional 
copy of the letter and check in accordance with the service requirements of Paragraph 11; 

d. to provide the Division with a written certification of compliance with the 
prohibitions and undertakings in this Agreement between forty-five and sixty days before 
the end of the Deferred Period; 

e. to review annually and update, as appropriate, the Code of Conduct 
beginning on February 1,2012; 

f. to require that each director, officer, and management-level employee 
certify compliance with the Code of Conduct on an annual basis beginning on February 
1,2011; and 

g. to conduct effective training regarding anticorruption and compliance with 
the FCPA for (1) all current officers and managers, (2) all employees working in Finance, 
Accounting, Internal Audit, Sales, and Government Relations, (3) all other employees 
working in positions Tenaris deems to involve activities implicated by Tenaris's policies 
regarding anticorruption and compliance with the FCPA, on or before December 31, 
2011, and (4) all such future employees within 90 days of their affiliation with Tenaris. 

PUBLIC STATEMENTS 

9. After the Deferred Period begins, on May 17,2011, the Respondent agrees not to 
take any action or to make or permit any public statement through present or future 
attorneys, employees, Agents, or other persons authorized to speak for it, except in legal 
proceedings in which the Commission is not a party, denying, directly or indirectly, any 
aspect of this Agreement or creating the impression that the allegations in Paragraph 6 of 
this Agreement are without factual basis. This paragraph is not intended to apply to any 
statement made by an individual in the course ofany criminal, civil, or regulatory 
proceeding initiated by the government or self-regulatory organization against such 
individual, unless such individual is speaking on behalf of the Respondent. If it is 
determined by the Commission that a public statement by the Respondent or any related 
person contradicts in whole or in part this Agreement, at its sole discretion, the 
Commission may bring an enforcement action in accordance with Paragraphs 12 through 
15. 

8
 



10. Prior to issuing a press release concerning this Agreement, the Respondent agrees 
to have the text of the release approved by the staff of the Division. 

SERVICE 

11. The Respondent agrees to serve by hand delivery or by next-day mail all written 
notices and correspondence required by or related to this Agreement to Karen L. 
Martinez, 15 W. South Temple, Suite 1800, Salt Lake City, UT 84101, (801) 524-5796, 
unless otherwise directed in writing by the staff of the Division. 

VIOLAnON OF AGREEMENT 

12. The Respondent understands and agrees that it shall be a violation of this 
Agreement if it knowingly provides false or misleading information or materials in 
connection with the Proceedings or Other Proceedings. In the event of such misconduct, 
the Division will advise the Commission of the Respondent's misconduct and may make 
a criminal referral for providing false information (18 U.S.C. § 1001), contempt (18 
U.S.c. §§ 401-402) and/or obstructing justice (18 U.S.C. § 1503 et seq.). 

13. The Respondent understands and agrees that, should the Division determine that 
the Respondent has failed to comply with any term or condition of this Agreement, the 
Division will notify the Respondent or its counsel of the fact and provide an opportunity 
for the Respondent to make a Wells submission pursuant to the Securities Act of 1933 
Release No. 5310. Under these circumstances, the Division may, in its sole discretion 
and not subject to judicial review, recommend to the Commission an enforcement action 
against the Respondent for any securities law violations, including, but not limited to, the 
substantive offenses relating to the Investigation. 

14. The Respondent understands and agrees that in any future enforcement action 
resulting from its violation of the Agreement, any documents, statements, information, 
testimony, or evidence provided by it during the Proceedings or Other Proceedings, and 
any leads derived there from, may be used against it in future legal proceedings. 

15. In the event it breaches this Agreement, the Respondent agrees not to contest or 
contradict in any future Commission enforcement action the factual statements contained 
in Paragraph 6 above as admissions pursuant to Federal Rule ofEvidence 801(d)(2). 

COMPLIANCE WITH AGREEMENT 

16. Subject to the full, truthful, and continuing cooperation of the Respondent, as 
described in Paragraphs 3 and 4, and compliance by Respondent with all obligations, 
prohibitions and undertakings in the Agreement during the Deferred Period, the 
Commission agrees not to bring any enforcement action or proceeding against the 
Respondent arising from the Investigation, after the conclusion of the Deferred Period. 

9
 



17. The Respondent understands and agrees that this Agreement does not bind other 
U.S. federal, state or self-regulatory organizations, but the Commission may, at its 
discretion, issue a letter to these organizations detailing the fact, manner, and extent of its 
cooperation during the Proceedings or Other Proceedings, upon the written request of the 
Respondent. 

18. The Respondent understands and agrees that if it sells, merges, or transfers all or 
substantially all of its business operations as they exist as of the date of this Agreement, 
whether such a sale is structured as a stock or asset sale, merger, or transfer during the 
Deferred Period, it shall include in any contract for sale, merger, or transfer a provision 
binding the purchaser or successor in interest to the obligations set forth in this 
Agreement. 

19. The Respondent understands and agrees that the Agreement only provides 
protection against enforcement actions arising from the Investigation and does not relate 
to any other violations or any individual or entity other than the Respondent. 

VOLUNTARY AGREEMENT 

20. The Respondent's decision to enter into this Agreement is freely and voluntarily 
made and is not the result of force, threats, assurances, promises, or representations other 
than those contained in this Agreement. 

21. The Respondent has read and understands this Agreement. Furthermore, the 
Respondent has reviewed all legal and factual aspects of this matter with its attorney and 
is fully satisfied with its attorney's legal representation. The Respondent has thorougWy 
reviewed this Agreement with its attorney and has received satisfactory explanations 
concerning each paragraph of the Agreement. After conferring with its attorney and 
considering all available alternatives, the Respondent has made a knowing decision to 
enter into the Agreement. 

22. The Respondent represents that its Board ofDirectors has duly authorized, in a 
the resolution attached as Exhibit A, the execution and delivery of this Agreement, and 
that the person signing this Agreement has authority to bind the Respondent. 

ENTIRETY OF AGREEMENT 

23. This Agreement constitutes the entire agreement between the Commission and the 
Respondent, and supersedes all prior understandings, if any, whether oral or written, 
relating to the subject matter herein. 

24. This Agreement cannot be modified except in writing, signed by the Respondent 
and a representative of the Commission. 

10 



   

25. In the event an ambiguity or a question ofintent or interpretation arises, tbis 
Agreement shall be coostmed as ifdrafted jointly bythe parties hereto. and no 
presumption or burden ofproofshall arise favoring or disfavoring the Commission or the 
Respondent by virtue ofthe authorship ofany ofthe provisions of the Agreement. 

The signatories below aclmowledge acceptance of1hc foregoing terms and conditions. 

RESPONDENT 

Ricardo Soler 
ChiefFinancial Officer 
Tenaris SA. 
46A, avenue John F. Kennedy 
L-1855 Lux.embomg 

Attached hereto is the Ce~ateofthe Secretary10 ~ Board ofDiJ:ectDrs ofTe:naris 
S.A., certifying thatRicardo Soler is, and at the time ofthe signing and delivery ofthe 
Agreement was, the duly appointed, qualified and acting ChiefFinanciaI Officerofthe 
Company and dulyauthorized to execute the Agreement on behalfofthe Company, and 
thattbe signature ofRicardo Soler appearing on the. Agreement is his genuine signature. 

RESPONDENTS COUNSEL 

Approved as 10 form: 

fi1:1i.~f} 
Sullivan & Cromwell ILl' 
125 Broad Street 
NewYor~NY10004-2498 
(212) 558-3121 

SECURII1ES AND EXCHANGE COMMISSION 
DIVISION OF ENFORCEMENT 

tfl::t j 7, ;;<DIJ 

11