DATE: 15 September 2023
TO: Directors, Officers, Employees, and Contract Employees
FROM: Li Zixue, Chairman of ZTE Corporation
Xu Ziyang, President of ZTE Corporation
SUBJECT: 2023-2024 Export Control Compliance Policy
Export Compliance is critical to the business of ZTE Corporation and its majority owned or controlled
subsidiaries and affiliates (collectively, “ZTE”).Compliance not only protects value, but it also creates
value. ZTE has been building its value for its customers, shareholders, and employees, through the
dedication and vigilance to export compliance of every individual. ZTE requires employees and contract
employees to work together, including with the Export Control Compliance Department (“ECC”), and the BU
Compliance Team to make ZTE stronger. Export compliance is everyone's responsibility.
I.Management Commitment to ZTE Obligations
On June 8, 2018, the U.S. Department of Commerce Bureau of Industry and Security (“BIS”) approved the
Superseding Settlement Agreement (“SSA”) with ZTE.ZTE also entered into the following joint settlement
agreements in March 2017: (1) Plea Agreement with the U.S. Department of Justice; (2) BIS Settlement
Agreement ; and (3) the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC“)
2018年6月8日,美国商务部工业与安全局(“BIS”)批准了其与中兴通讯达成的《替代和解协议》(“SSA”)。中兴通讯还于2017年3月签订了以下协议: (1)与美国司法部达成《认罪协议》; (2)BIS《和解协议》; (3)美国财政部外国资产管理办公室(“OFAC”)《和解协议》。
It is the policy and commitment of ZTE to cooperate fully with the BIS-appointed Special Compliance
Coordinator (“SCC”), Roscoe C. Howard, Jr. and his team[ The term of the Monitor, James M. Stanton,
ended as scheduled on March 22, 2022 (U.S. time)]. All employees and contract employees must fully
cooperate with the SCC and his team under the requirements of the monitorship.
中兴通讯的政策和承诺是与BIS指定的特别合规协调员(“SCC”)Roscoe C. Howard,Jr.及其团队充分合作[ 监察官(“Monitor”)James M.
In addition to the commitments that ZTE has made under the SSA, ZTE has also set a goal, with
self-motivation, of building a world-class Export Compliance Program based on industry best practices.
This requires work and cooperation by everyone, no matter whether you are an employee from a business
unit, act as a compliance practitioner within the Company, or are a contract employee of ZTE.
II.Management Commitment to Compliance with Export Control Laws
It is ZTE policy to comply fully with all applicable laws and regulations, including restrictions under
export control and economic sanctions laws and regulations. Compliance with ZTE's Export Compliance
Program and the laws and regulations on which it is based is an essential requirement for ZTE's
employees, contract employees, and business teams.
Export control and economic sanctions laws and regulations include export control and economic sanctions
laws and regulations of China, the European Union, the United States,and other countries/regions. As
examples, (1) ZTE makes certain products incorporating U.S. contents that are fully controlled by the
U.S. export control and economic sanctions laws and regulations, such as the Export Administration
Regulations (“EAR”) administered by BIS and economic sanctions regulations administered by OFAC; (2)
shipments via Hong Kong should comply with Hong Kong's Import and Export (Strategic Commodities)
Regulations; and (3) shipments out of China mainland should comply with Export Control Law of the
People's Republic of China. ZTE is committed to the compliance of its global businesses with applicable
export control and economic sanctions laws and regulations.
出口管制和经济制裁法律法规包括中国、欧盟、美国和其他国家/地区的出口管制和经济制裁法律法规。例如, (1)中兴通讯制造的特定产品因并入了美国成分, 而需要遵循如BIS经管的《出口管理条例》(“EAR”)和OFAC经管的经济制裁规定之类的美国出口管制和经济制裁法规; (2)途径香港的货运需要遵守香港的《进出口（战略物品）规例》; (3)离开中国大陆的货运需要遵守《中华人民共和国出口管制法》。中兴通讯致力于使其全球业务遵守可适用的出口管制和经济制裁法律法规。
ZTE is also committed to taking steps on an export compliance risk basis to ensure that transactions
undertaken by anyone operating with or on behalf of ZTE are in compliance with applicable export control
and economic sanctions laws and regulations.
Violations of these laws and regulations may result in serious consequences for ZTE and responsible
individuals, including criminal and/or civil fines, Restricted Party designation and even imprisonment,
or re-imposition of the Suspended Denial Order as well as damage to ZTE's and the individual's
reputation. Non-compliance with these laws and regulations, this Policy, and the procedures the Company
has established will not be tolerated. Employees and contract employees who violate this Policy will be
subject to significant disciplinary action up to and including termination.
The Board of Directors and the Export Compliance Committee of ZTE has been fully supporting the Export
Compliance Program. ZTE is committed to providing sufficient resources to ensure continued compliance
with applicable export control and economic sanctions laws and regulations. We understand that
compliance creates value, and we ask each of you to support this effort to create value for ZTE and take
your compliance responsibilities very seriously. The success of ZTE depends on your full cooperation and
support of this critical mission. We will depend on your participation to create value for ZTE.
The ZTE Export Control Compliance Policy requires the following:
●Employees and contract employees must complete a certification (please refer to the end of this
policy) regarding compliance with ZTE's 2023-2024 Export Control Compliance Policy, unless excused, in
extraordinary circumstances, from doing so after review and approval by ECC.
●Employees and contract employees must comply with applicable export control and economic sanctions laws
and regulations, as well as all relevant policies and procedures promulgated by ZTE to ensure
●Employees and contract employees must provide accurate, complete, and timely information to BU
Compliance Team, ECC, and the SCC and his team. If employees and contract employees are aware that
inaccurate or misleading information has been provided to BU Compliance Team, ECC, or the SCC and his
team, they are required to provide the accurate information or correct any misleading statements.
●Employees and contract employees must fully understand how export control and economic sanctions laws
and regulations apply to the work that they do, participate fully and in good faith in all applicable
compliance training, report any actual or potential compliance issues or violations to the appropriate
compliance personnel, ensure that business documents, records, data, and information are accurate and
complete and that required records are maintained and filed in the proper locations, and ask questions
of BU Compliance Team, ECC or Chief Export Compliance Officer (“CECO”) if they are uncertain as to what
requirements might apply.
员工和合同工必须充分了解出口管制和经济制裁法律法规如何适用于其工作, 并充分地、诚信地, 参与所有可适用的合规培训, 向适当的合规人员报告任何实际或潜在的合规问题或违规行为, 确保业务文档、记录、数据和信息准确完整, 并对上述信息做好记录保存, 以及在合适的位置归档, 在不确定哪些要求可能适用时, 向BU合规团队或出口管制合规部或首席出口管制合规官(“CECO”)提出咨询。
●Before exporting, reexporting, procuring, or otherwise transferring commodities, software or
technology, or providing related services, the proper export classification(s) of the items must be
confirmed under due diligence, and ZTE must confirm that no prior authorization or license is required
from any government authority. In this regard, for example, certain products manufactured and/or sold by
ZTE are subject to China and/or U.S. dual-use export controls. To the extent that prior export
authorization is required, ZTE must not provide any services (e.g., testing, repair, return, support,
procurement) or export, reexport, or otherwise transfer commodities, software, or technology without
first obtaining the authorization.
●Currently, ZTE will not conduct business with any parties located, headquartered, registered in
countries or regions that are subject to comprehensive territorial sanctions (“Sanctioned
Countries/Regions” currently, Iran, Syria, North Korea, Cuba, Crimea region, “Donetsk People's Republic”
(“DNR”) and “Luhansk People's Republic” (“LNR”) regions), whether or not U.S.-origin items are involved
and whether or not the items or services are provided to or through these countries/regions. This means
that ZTE should not conduct any business with companies from the Sanctioned Countries/Regions as the
vendor, order party, bill-to party, consignee, end-user, intermediary, logistics provider, bank,
carrier/vessel, or as any other party to the transaction. The only exception is with regard to ZTE's
exit from historic business in these countries/regions. Any activities related to ZTE's exit from
historic business in these countries/regions, including those countries/regions that may have had their
comprehensive territorial sanctions lifted such as Sudan, must be reviewed in advance by CECO, or his
designees, for export compliance purposes.
目前，中兴通讯不会与位于、或其总部位于、或注册于受全面区域制裁的国家或地区（“受制裁国家/地区”，现为伊朗、叙利亚、朝鲜、古巴、克里米亚地区、“顿涅茨克人民共和国”(“DNR")和“卢甘斯克人民共和国”(“LNR")地区）的任何当事方开展业务，无论是否涉及美国原产物项，也无论是否向该等国家或地区提供物项或服务，亦或是过境该等国家或地区。这意味着中兴通讯不得与来自受制裁国家/地区的公司(供应商、订购方、付款方、收货人、最终用户、中间人、物流供应商、银行、承运人/船方或交易的任何其他方)开展任何业务。唯一例外是中兴通讯在该等国家或地区历史业务的退出。任何与中兴通讯在该等国家或地区历史业务退出的相关活动，包括那些已取消全面区域制裁的国家或地区(例如苏丹), 必须事先由CECO或其指定人员, 基于出口合规目的进行审查。
●In addition, attention shall be paid to countries/regions subject to the sanctions imposed by the UN,
the EU, China, the U.S., or any other governments or organizations that have jurisdiction over the
transactions. The ECC is responsible for identifying these countries/regions and making corresponding
●ZTE does not directly or indirectly engage in any business with Restricted Parties, such as parties
that are sanctioned by the United States or other governments, except business activities which are in
full compliance and have been reviewed in advance by CECO, or his designees. Such parties including but
not limited to individuals and entities identified on (i) the Specially Designated Nationals and Blocked
Persons List (“SDN”) maintained by OFAC or (ii) the Denied Persons List or the Entity List maintained by
BIS. For example, the CECO or his designees may approve a transaction with a party on the Entity List
involving items that are not subject to the EAR .
中兴通讯不得直接或间接与任何受美国或其他政府制裁的受限制主体开展业务, 除非业务活动完全合规, 并经CECO或其指定人员事先审查。这些主体包括但不限于(i)OFAC经管的《特别指定国民及被封锁人员清单》(“SDN”); 或(ii)由BIS经管的《被拒绝人员名单》或《实体清单》中指明的个人或实体。例如, CECO或其指定人员可以批准与实体清单一方进行不受EAR管辖物项的交易。
●Employees and contract employees must follow company compliance procedures established to reduce these
risks. Such compliance procedures at ZTE include, but not limited to, entering accurate and complete
name and address information in ZTE systems for business partners, including vendors, customers, and
other partners; properly classifying ZTE products; understanding all the parties involved, directly or
indirectly, in the business transactions; performing compliance screening and export authorization
determination. Conducting additional due diligence, and obtaining end-user or end-use statements is also
sometimes required on an export compliance risk basis when necessary, for example, business involving
regions posing heightened risks of diversion, risks of Restricted Parties and/or restricted end uses, or
any other red flags.
Exceptions to this Policy require advanced legal advice and guidance from CECO or his designees.
●Employees and contract employees may not publicly comment on the March 2017 Settlement Agreement,
March 2017 Plea Agreement, and June 2018 Superseding Settlement Agreement (collectively, “the Settlement
Agreements”), the conduct giving rise to the Settlement Agreements, the SCC, the U.S. Court-appointed
Monitor(whose term expired on March 22, 2022 U.S. time), or any other related matter in any public
forum, including on any external instant messaging or social media communication platforms without the
prior approval of ECC.
在未获得出口管制合规部事先批准的情况下, 员工和合同工不得就2017年3月签署的《和解协议》、2017年3月签署的《认罪协议》和2018年6月签署的《替代和解协议》(统称, “和解协议”), 以及导致“和解协议”的行为、SCC、美国法院指定的监察官(其任期已于2022年3月22日(美国时间)结束), 或其他相关事项, 在任何公共论坛、包括在任何外部即时通讯或社交媒体通讯平台上公开评论。
●Employees and contract employees must fully cooperate with the SCC and his team, take requests from the
SCC and his team very seriously, respond in a truthful, timely, and complete manner and in no way
interfere with or impede the monitorship, and timely provide available business records as requested by
the SCC and his team. Fulfilling requests from the SCC and his team quickly, efficiently, and accurately
is critical to the ongoing health and success of ZTE's business.
员工和合同工应当全面配合SCC及其团队, 认真对待SCC及其团队提出的需求, 诚实、及时、完整进行应答, 绝对不得干扰或者阻碍监管, 及时提供SCC及其团队要求的可适用的业务记录。迅速、高效以及准确完成SCC及其团队的需求, 对于中兴通讯业务持续健康、成功发展至关重要。
●If you have any questions concerning this Policy, please contact immediately CECO or ECC.
●Employees and contract employees are required to report any actual or potential export compliance
issues or violations. Any reports of actual or potential violations may be made to BU Compliance Team,
ECC, or Compliance Audit Department anonymously, and under no circumstances will any employee or
contract employee be subject to retaliatory action for reporting in good faith an actual or potential
员工和合同工必须报告任何实际或潜在的出口合规问题或违规行为。任何实际或潜在违规的报告可匿名向BU合规团队、出口管制合规部或合规稽查部提出, 且在任何情况下, 任何员工或合同工均不会因善意举报实际或潜在违规行为而遭受报复。
●Additionally, if an employee or contract employee has knowledge of actual or potential violations and
fails to report such actual or potential violations to BU Compliance Team, ECC or Compliance Audit
Department, he/she may be subject to disciplinary action up to and including termination.
此外, 如果员工或合同工知道实际或潜在违规行为但没有向BU合规团队、出口管制合规部或合规稽查部报告此类实际或潜在违规行为, 他/她可能会受到纪律处分，最高处分可至（包括）被解雇。
Selected Points of Contact in ECC
Koon (Lawrence Koh)
Head of ECC
China中国: +86 157-6825-0208
Singapore新加坡 +65 8499-9511
Deputy Head of
Director of Compliance
China中国: +86 136-8880-5511
Compliance Reporting Options
If you are uncomfortable reporting matters directly to ECC or BU compliance team, you
can also utilize
ZTE's other reporting options including some which allow you to remain anonymous.
●ZTE Compliance Audit Department 中兴通讯合规稽查部
https://www.zte.com.cn/china/whistleblowing/report(for employees in China)
https://www.zte.com.cn/global/whistleblowing/report(for employees overseas)
http://lcm.zte.com.cn - Compliance Audit-Violation Report
http://lcm.zte.com.cn - 合规稽查 - 违规线索报
Compliance Audit Dept., ZTE R&D Building, 55 Hi-Tech South Road, Nanshan District,
深圳南山区科技南路55号, 中兴通讯研发大楼, 合规稽查部
●Independent third-party compliance reporting platform
400-0707-099 (Mainland China)
+ 8621-3313-8584 (Overseas, Hongkong, Macao and Taiwan)
+ 8621-3313-8584 (海外 、香港、澳门、台湾)
In addition to the above options for reporting actual or potential violations, the SCC and
his team has
also established the Special Compliance Coordinator Confidential Reporting Program for
compliance-related questions and concerns. The SCC reporting program can be accessed
or by calling the independent Compliance Reporting Line at +1-202-831-6700.
Violations or concerns can be reported directly to the SCC and his team by sending emails to