Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM OMB No. 1124-0006; Expires April 30,2017 Exhibit A to Registration Statement Pursuant to the Foreign Agents Registration Act of 1938, as amended U.S. Department of Justice Washington. DC 20530 INSTRUCTIONS. Furnish this exhibit for EACH foreign principal listed in an initial statement and for EACH additional foreign principal acquired subsequently. Thefilingof this document requires the payment of afilingfee asset forth in Rule (d)(1), 28 C.F.R. § 5.5(d)(1). Compliance is accomplished by fil ing an electronic-Exhibit A form at http://www.fara.gov. Privacy Acl Statement, The filing of this document is required by the Foreign Agents Registration Act of 1938, as amended, 22 U.S.C. § 611 el seq., for tlie purposes of registration under the Act and public disclosure. Provision of the information requested is mandatory, and failure to provide this information is subject to the penalty and enforcement provisions established in Section 8 of the Act. Every registration statement, short form registration statement, supplemental statement, exhibit, amendment, copy of informational materials or other document or informationfiledwith the Attorney General under this Act is a public record open to public examination, inspection and copying during the posted business hours ofthe Registration Unit in Washington, DC. Statements are also available online at the Registration Unit's webpage: htlp:/Avww. fara.gov. One copy of every such document, other than informational materials, is automatically provided to thc Secretary of State pursuant to Section 6(b) of the Act, and copies of any and all documents are routinely made available to other agencies, departments and Congress pursuant to Section 6(c) ofthe Act. The Attorney General also transmits a semi-annual report to Congress on the administration of the Act which lists the names ofall agents registered under the Act and the foreign principals they represent. This report is available to the public in print and online at: http://wvvw,fara.gov. Public Reporting Burden. Public reporting burden for this collection of information is estimated to average .49 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions forreducingthis burden to Chief, Registration Unit, Counterespionage Section, National Security Division, U.S. Department of Justice, Washington, DC 20530; and to the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 2. Registration No. 1. Name and Address of Registrant S.G.R. LLC Government Relations and Lobbying, 1775 I St. NW, Suite 410, Washington, D.C. 20006 3. Name of Foreign Principal 6379 4. Principal Address of Foreign Principal Inovo BV (as a result of work SGR did for Flynn Intel Group Inc.) Inovo BV- 47 Adireaanstraat> 3581 SC Utrecht, Netherlands 5. Indicate whether your foreign principal is one ofthe following; • Government ofa foreign country' • Foreign political party H Foreign or domestic organization: I f either, check one of the following: D Committee • Partnership S Corporation • Voluntary group • Association • Other (specify) • Individual-State nationality If the foreign principal is a foreign government, state: a) Branch or agency represented by the registrant NA b) Name and title of official with whom registrant deals NA 7. If the foreign principal is a foreign political party, state: a) Principal address NA b) Namc and title of official with whom registrant deals NA c) Principal aim ^ l "Government of a foreign conntTy," as defined in' Section 1 (e) of the Act, includes any person or group of persons exercising sovereign de facto or de jure political jurisdiction over any country, other than the United States, or over any part of such country, and includes any subdivision of any such group arid any group or agency to which such sovei cigu de facto or dc jure authority or functions are directly or indirectly delegated. Such term shall include any faction or body of insurgents within a country assuming to exercise governmental authority whether such faction or body of insurgents has or has not been recognized by the United States. FORM NSD-3 Revised 03/14 Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM 8. If the foreign principal is not a foreign government or a foreign political party: a) State the nature of the business or activity of thisforeignprincipal. Inovo BV is a Dutch company incorporated in 2005 to provide business consultancy services. b) Is this foreign principal: Supervised by a foreign government, foreign political party, or other foreign principal Owned by a foreign government, foreign political party, or other foreign principal Directed by a foreign government, foreign political party, or other foreign principal Controlled by a foreign government, foreign political party, or otherforeignprincipal Financed by a foreign government, foreign political party, or other foreign principal Subsidized in part by a foreign government, foreign political party, or other foreign principal YesD No a YesD No SI YesD No H Yes D No S3 Yes • No S Yes D No 13 9. Explain fully all items answered "Yes" in Item 8(b), (Ifadditional space is needed, afull insert page must be used) NA 10. If the foreign principal is an organization and is not owned or controlled by aforeigngovernment, foreign political party or other foreign principal, state who owns and controls it. According to information received by SGR, Inovo BV is owned and controlled by Ekhim Alptekin, EXECUTION In accordance with 28 U.S.C. § 1746, the undersigned swears or affirms under penalty of perjury that he/she has read the information set forth in this Exhibit A to the registration statement and that he/she is familiar with the contents thereof and that such contents are in their entirety true and accurate to the best of his/her knowledge and belief. Date of Exhibit A Name and Title 3/2/2017 Signature James C Courtovich, Managing Partner Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM OMB No. 1124-0004; Expires April 30,2017 u.s. Department of Justice Washington, DC 20530 Exhibit B to Registration Statement Pursuant to the Foreign Agents Registration Act of 1938, as amended INSTRUCTIONS. A registrant must mmish as an Exhibit B copies of each written.agreement and the terms and conditions of each oral agreement with bis foreign principal, including all modifications of such agreements, or, where no contract exists, a full statement ofall the circumstances by reason of which the registrant is acting as an agent of a foreign principal. Compliance is accomplished by filing an electronic Exhibit B form at litip://www. fani.gov. Privacy Act Statement. The filing of this document is required for the Foreign Agents Registration Act of 1938, as amended, 22 U.S.C. §611 el seq., for the purposes of registration under the Act and public disclosure. Provision of the informationrequestedis mandatory, and failure to provide the information is^subject to the penalty and enforcement provisions established in Section 8 of the Act. Every registration statement, short form registration statement, supplemental statement, exhibit, amendment, copy of informational materials or other document or infonnationfiledwith the Attorney General under this Act is a public record open to public examination, inspection and copying during thc posted business hours of the Registration Unit in Washington, DC. Statements are also available online at tlie Registration Unit's webpage: http://www.fara.gov. One copy of every such document, other than informational materials, is automatically provided to the Secretary of State pursuanttoSection 6(b) of the Act, and copies of any and all documents are routinely made available to other agencies, departments and Congress pursuant to Section 6(c) of the Act. The Attorney General also transmits a semi-annual report to Congress on the administration of the Act which lists the names of all agents registered under the Act and tlie foreign principals they represent. This report is available lo the public in print and online at: http://www.fara. gov. Public Reporting Burden. Public reporting burden for this collection of information is estimated to average .33 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate or any other aspect of this collection ofinformation, including suggestions for reducing this burden to Chief, Registration Unit, Counterespionage Section, National Security Division, U.S. Dcparunent of Justice, Washington, DC 20530; and to the Office ofinformation and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. 1. Name of Registrant 2. Registration No. S.G.R. LLC Government Relations and Lobbying 6379 3. Name of Foreign Principal Inovo BV (as a result of work SGR did for Flynn Intel Group Inc.) Check Appropriate Box: . 4. H The agreement between the registrant and the above-named foreign principal is a formal written contract. If this box is checked, attach a copy of the contract to this exhibit. 5. • There is no formal written contract between the registrant and the foreign principal, the agreement with the above-named foreign principal has resulted from an exchange Of correspondence. If this box is checked, attach a copy of all pertinent correspondence, including a copy of any initial proposal which has been adopted by reference in such correspondence. 6. • The agreement or understand ing between the registrant and the foreign principal is the result of neither a fonnal written . contract nor an exchange of correspondence between the parties. If this box is checked, give a complete description below of the terms and conditions ofthe oral agreement or understanding, its duration, the fees and expenses, if any, to be received. 7. Describe fully the nature and method of performance of the above indicated agreement or understanding. See Attached FORM NSD-4 Revised 03/14 Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM o". Describe fully the activities the registrant engages in OP proposes to engage in on behalf of the above foreign principal. See Attached 9. Will the activities on behalf of the above foreign principal include political activities as defined in Section l(o) ofthe Act and in the footnote below? Yes H No • If yes, describe all such political activities indicating, among other things, the relations, interests or policies to be influenced together with the means to be employed to achieve this purpose. See Attached EXECUTION In accordance with 28 U.S.C. § 1746, the undersigned swears or affirms under penalty of perjury that he/she has read the information set forth in this Exhibit B to the registration statement and that he/she is familiar with the contents thereof and that such contents are in their entirety true arid accurate to the best of his/her knowledge and belief. Date of Exhibit B Name and Title 3/2/2017 James C. Courtovlch, Managing Partner Signature Footnote: "Political activity," as 'defined'in Section l(o) ofthe Act; means any "activity which the person engaging in believes will, or that the person intends to, in any way influence any agency or official of the Government ofthe United States or any section of the public within the United States with reference to formulating, adopting, or changing the domestic or foreign policies ofthe United Stales or with reference to the political or public interests, policies, or relations ofa government of a foreign country or a foreign political party. Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Attachment to Exhibit B Note: Effective October 2016, SGR LLC Government Relations and Lobbying ("SGR") elected to register under the Lobbying Disclosure Act ("LDA") for a subcontracting project from Flynn Intel Group ("FIG"), which had been hired by Inovo BV. SGR registered under the LDA based on information it received from FIG and based on the fact that FIG registered under the LDA for its work for Inovo BV. SGR understood from FIG that Inovo BV is a private entity not owned or controlled by a foreign government. Recently, SGR learned that FIG now plans to file under the Foreign Agents Registration Act ("FARA") for its work for Inovo BV. FIG has explained that this is due to the subject matter ofthe overall engagement between FIG and Inovo BV. Because SGR's work under the subcontract related to FIG's engagement with Inovo BV, SGR is also now filing under FARA. Responses to Items 7-9. In late September 2016, FIG hired SGR to provide services to FIG. SGR and FIG entered into a contract formalizing the scope of this work in early October 2016. Pursuant to SGR's contract with FIG, SGR agreed to perform public affairs work designed to encourage and strengthen relations between the governments and business communities of the United States, Turkey, and Europe. This work included research and analysis of the political environment and related third party groups in the United States. It also included providing strategic support for message development and communications strategies, including government and media outreach. SGR understood that the goal of these efforts was to improve the business climate and investment opportunities related to Turkey by demonstrating stability. SGR received no direction, input, or fundingfromanyone other than FIG. Pursuant to SGR's contract with FIG, SGR performed research, support, and outreach activities for a period of time that was less than two months. Contacts with media personnel and government officials are summarized in the below chart. As part of these efforts, SGR engaged several journalists and policy-makers on national security and education issues concerning how these related to the relationships between the countries of Turkey and the United States. SGR also researched and analyzed the effect of Mr. Fetullah Gulen's presence in the United States in this context. It monitored media and policy updates as they related to Mr. Gulen and charter schools to assist in advance planning related to a public affairs campaign designed to provide information regarding these issues. Also, at the specific request of FIG, SGR created a graphic summarizing important issues based on publicly available materials. SGR exchanged multiple versions of this graphic with FIG that included revisions based on FIG's feedback and input. SGR did not publish or otherwise disseminate this graphic or any other materials based on the above work. Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Date October 11-12, 2016 October 12, 2016 October 13-14, 2016 October 27, 2016 Contact Tim Griffin Contact Title Lt. Gov. Arkansas Michael Stratford Tim Griffin Politico Morning Edition Lt. Gov. Arkansas Miles Taylor November 7, 2016 Taylor Shapiro Staff, House Homeland Security Committee Washington Post Outreach Description E-mails regarding media coverage related to charter schools E-mail about media coverage related to charter schools E-mail and a telephone conversation about charter schools Introduction meeting at FIG; discussion regarding H1B visas and charter schools E-mail about possible meeting SGR received three payments from FIG under the contract. It received $15,000 on September 28, 2016; $10,000 on October 20, 2016; and $15,000 on November 15, 2016. SGR disbursed $177.95 related to this work, for multiple Uber rides from October 4, 2016 through October 27, 2016. On or about November 7, 2016, an employee at FIG contacted SGR to request assistance in placing an opinion piece that General Michael Flynn had written. As standard practice, SGR confirmed with FIG that the document was written within the company (a question that would be asked by any op-ed page editor). In recent discussions, FIG has explained that this article was not written Under the direction or control of Inovo BV; rather it was an issue on which General Flynn wanted to opine. SGR assisted FIG by contacting The Hill to secure publication. Further, SGR e-mailed multiple U.S. and international media contacts with a copy of the article once it was published in The Hill. By its terms, SGR's contract with FIG ran from September 20, 2016 through December 20, 2016. SGR completed all work related to this contract within the first two months of its term. SGR's work relating to FIG and Inovo BV and its indirect relationship with Inovo BV stopped at the same time as FIG suspended its operations, which was in November 2016. Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM FLYNN INTEL qiOUl' INC.. Independent Advisory Services Agreement This agreement is executed by and between Flynn Intel Group, inc., a U.S. entity with its principal offices located at 44 Canal Center Plaza, Suite 400, Alexandria, Virginia, 22314 hereinafter called The "company" and S.G.R, LLC Government Relations and Lobbying, a U.S. company with its principal offices located at 1775 I St NW,. Suite 410, Washington D.C. 20006, hereinafter called "advisor" or "SGR" on this date, September 20, 2016; Together, the Company and the advisor shall be referred to as the "parties" in this agreement Nature of the relationship between the client and the advisor The advisor is not an employee of ah agent of the Company. The advisor is an independent contractor, engaged for specific purpose of providing services defined in the scope of services paragraph of this agreement for a specified period of time as described In the term and termination paragraph of this agreement Scope Of services SGR will work with the Company to develop and execute a public affairs plan to encourage and strengthen relations between the, governments and business communities Of Turkey, Europe and the United States. Activities will include but are not.limited to the distribution of fact-based, actionable intelligence:to targeted government officials and media in order to: • • • Provide new and proprietary information arid resources to relevant congressional committees, leadership, and Executive Branch officials. Leverage SGR's network of U.S. and international media contacts to obtain positive coverage that positions Turkey, and its adversaries, In an accuratelight Develop independent and credible surrogates to offer favorable, independent views about Turkey and the root causes of the country's ongoing political turmoil. Term and termination This agreement is effective as of September 20, 2016 and shall continue in effect for a period of 90 days until December 20, 2016. Parties to this agreement may terminate this agreement with or without cause at any time. N otafications may be made through electronic mail addressed to each party's respective electronic email address. Compensation As compensation for the performance of the services described above, SGR will be paid $30,000. Payment for services shall correspond to specific deliverables at defined time interval. Team Leaders to define deliverables and time targets. i Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM Example: October 4,2016 = Engagement and initial research / $15,000.00 December 20,2016 = Engagement completion / $15,000.00 All expenses associated with the. completion af defined deliverables shall be pre-approved by the Company. The advisor shall not incur any expenses without prior, written approval of the company. Confidentiality The terms and conditions of this agreement shall remain confidential. Parties agree to maintain each other's informatiofl in strict confidence throughout the course of this engagement and after its termination. The advisor agrees to return, all such confidential material tb. the client at the: end of the engagement Signed by: •(LA The Client o^kk. ----- The Advisor James C. Coiirtovich S.G.R. LLC Government Relations and Lobbying L)ate 2J> Date: 10/5/201 s 2 Received by NSD/FARA Registration Unit 03/07/2017 6:22:45 PM