Dear Valued Business Partner:
At ZTE, we understand that export compliance benefits both our company and our business partners. This update describes some of our efforts in Q2 2021 to ensure export control compliance and to maintain strong relationships with our business partners.
Track policy changes in a timely manner to efficiently support business development: In this quarter, ZTE closely tracked and analyzed the US export control and economic sanctions against Myanmar, the Internal Compliance Mechanism for Export Control by Exporters of Dual-use Items, and US release of Non-SDN Chinese Military-Industrial Complex Companies List and other changes in the laws and regulations on export control and economic sanctions. Besides, ZTE has efficiently contributed to the adjustment of the business compliance guidelines, strictly regulated the business process, ensuring that ZTE's business can be carried out in compliance and compliance risks could be lowered resultfully.
New achievements in the construction of compliance manuals: The construction of compliance manuals is an important step of an effective compliance system. ZTE is committed to continuously enhancing compliance manuals. Among those great progress on ZTE’s export compliance manuals in this quarter, we have released the Export Control Compliance Dept. manual, and completed the manual development empowerment training for several subsidiaries. Three pilot subsidiaries’ self-compiled manuals have been certified and are going to be released later. In addition, the manual practice community has been established and preliminarily run by the manual project team, which makes the manual element and other compliance elements or compliance fields interact well.
Continuous promotion on export authorization control: ZTE has been continuously carrying out ECCN classification expert training and certification, established a three-level ECCN classification expert team to improve the professional level of ECCN classification through human resource construction, and deployed and implemented ECSS in the subsidiaries smoothly. At the same time, the risk assessment and compliance inspections on the subsidiaries’ ECCN publication have been completed, which could help the subsidiaries to identify weak points and propose improvement suggestions from the aspects of organization, process specifications, system management and control, business operation results and training implementation verification, so as to continuously improve the ECCN publication ability and meet the requirements of ECCN publication. In addition, the GTS implementation team continuously promoted the optimization of screening tools to screen addresses in English, and standardized the management of compliance screening data through the data monitoring platform, to continuously improve the integrity and accuracy of compliance screening. The company's automatic compliance management and control capabilities were effectively improved.
Comprehensive risk assessment: In this quarter, the ECP (Export Compliance Program) risk assessment project of ZTE has continued to carry out a comprehensive risk assessment work in key business fields such as R&D, supply chain and engineering services, under the combination of both the guiding principles in the Corporate-Level Manual and the BU-Level Manuals and the 2020 risk assessment pilot experienced. It uses the questionnaire to collect the relevant information of each business unit, and then identifies the inherent risks in the business activities of each priority department through multiple methods, and verifies the integrity and effectiveness of compliance control. Next, based on the differentiated risks and the corresponding risk levels of each business unit, the company will formulate management and control measures to invest resources efficiently and achieve hierarchical compliance management.
实施全面的风险评估工作：本季度，公司ECP(Export Compliance Program)风险评估项目继续以合规手册总册及分册中的指导性原则为基础，结合2020年风评试点经验，在研发、供应链、工程服务等重要业务领域全面开展风险评估工作。使用问卷收集各业务单位相关信息，筛选出不同优先等级的部门，再通过多种方法识别各优先级的部门经营活动中的固有风险并验证合规管控的完整性和有效性。接下来，公司将根据各业务单位的差异化风险及相应风险等级制定管控措施，高效投入资源，实现合规的分级化管理。
Carry out external compliance communication actively: ZTE actively conducts experience exchanges of compliance research and compliance system construction with industry partners, renowned scholars, and enterprise research institutes, draws on useful experience and disseminates the methodology of advanced compliance system construction. Nowadays, ZTE's compliance brand is gradually recognized by many parties in the industry. In addition, the company's compliance exchanges with domestic and overseas key customers and partners are also progressing steadily. In the first half of 2021, the company has conducted nearly twenty compliance exchanges. Through external communication and experience sharing, the company’s customers and partners has further gained faith from ZTE, and strengthened their confidence in ZTE’s robust development.
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ZTE thanks our business partners for your consistent support. If you have questions, please do not hesitate to contact ZTE by your point of contact.
Chief Export Control Compliance Officer
+65 84999511 (Singapore/新加坡)
+86 15768250208 (China/中国)