Dear Valued Business Partner:
ZTE is updating and enhancing its export compliance program. ZTE is committed to ensuring export compliance and preventing any future problems for the Company or our business partners.
●Our Senior Management Commitment to Compliance: President Xu Ziyang and other senior executives have issued and continue to issue statements to express senior management’s full commitment to export controls compliance. This commitment is shared by leaders of our business units.
●Enhancing our Curriculum of Export Controls Training: ZTE has provided extensive training and will increase its training on export controls to its employees. ZTE is developing several new training courses on export controls. All employees must complete a “General Awareness” course. Some employees also may be required to complete one or more courses based upon their job function and level. Special courses on export controls compliance have been and are being developed by function and other topics, such as:
o Middle Management Responsibilities
o Senior Management and Executive Responsibilities
o After Sales
o Export Classification
o Human Resources
o Research & Development
o Restricted Party Screening
o Sales & Marketing
o Using the Export Controls Manual
●Export Compliance Forum: ZTE export compliance professionals have presented at several conferences in China. For example, ZTE made a presentation on export control compliance at a MOFCOM symposium in September 2018.
●Export Compliance Procedures at ZTE Subsidiaries. ZTE has been enhancing export controls procedures at its subsidiaries in China and globally. ZTE conducted training and outreach to over 200 subsidiaries and offices.
●Export Screening and Automation: The U.S. Government encourages the use of automated screening processes. ZTE’s innovative Restricted Party List screening tools enable the ZTE Group to conduct automated screening of business partners on a regular basis across multiple operational, financial and communication platforms. Building upon SAP-Global Trade Services data and tools, we are able to screen business partners against a large number of sanctions lists, such as those used by the United States, Europe, Japan and the United Nations.
出口扫描和自动化：美国政府鼓励使用自动扫描程序。中兴公司创新的受限制方清单扫描工具使中兴集团能够在多个运营、财务和通信平台上定期对业务合作伙伴进行自动扫描。基于SAP-Global Trade Services数据和工具，我们能够针对大量制裁名单，例如美国、欧洲、日本和联合国所使用的制裁名单，对业务合作伙伴进行扫描。
●Communication with Business Partners: ZTE continues to work with its business partners to collect Export Control Classification Numbers (“ECCNs”) and related classification information to ensure export compliance in our supply chain and distribution channels. ZTE looks forward to continuing our compliance dialogue with our partners.
●ZTE Continues to Cooperate with the Special Compliance Coordinator (“SCC”) and the Monitor: ZTE continues to cooperate with the SCC, Roscoe Howard Jr., and its Monitor, James M. Stanton. ZTE will continue to implement recommendations from the SCC and the Monitor on our export compliance program. The SCC and Monitor teams have conducted outreach with numerous ZTE sites and have participated in ZTE trainings and meetings at locations worldwide.
中兴公司继续与特别合规协调员（“SCC”）和监察官合作：中兴公司继续与SCC，即Roscoe Howard Jr.及监察官James M. Stanton合作。中兴公司将继续实施SCC和监察官就我们的出口合规项目提出的建议。SCC和监察官团队已经走访了许多中兴公司的场所，并参与了中兴公司在全球各地举办的培训和会议。
●Obligations under the Superseding Settlement Agreement (“SSA”): ZTE continues to fulfill and make progress on its obligations under the SSA, including the submission of various reports to the Bureau of Industry and Security of the U.S. Department of Commerce (“BIS”). In September 2018, ZTE submitted two reports to BIS regarding the ownership and control of ZTE. ZTE also submitted a report to SCC of ZTE’s compliance expenditures on November 1, 2018. ZTE continues to work towards the completion of its other obligations under the SSA through various projects, such as training, export classification projects and compliance enhancement programs for its subsidiaries.
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ZTE thanks our business partners on for their continued support. If you have questions, please do not hesitate to contact ZTE at firstname.lastname@example.org or 400-830-8330 or +86 755 26771706.
中兴公司感谢业务合作伙伴提供的持续支持。如果您有任何疑问，请随时通过complianceaudit@zte.com.cn或400-830-8330或+86 755 26771706与中兴公司联系。
Chief Export Control Compliance Officer
+65 84999511 (Singapore/新加坡)
+86 18588454350 (China/中国)