ZTE Anti-Bribery Compliance Policy

DATE: June 28, 2019
TO: All ZTE employees, shareholders, and business associates
FROM: Chairman of ZTE
            President of ZTE
SUBJECT: Anti-Bribery Compliance Policy

Bribery breaches public trust, poses a threat to economic and social development, and hinders fair trade. In order to fight bribery, most countries where ZTE Corporation is engaged in business have implemented anti-bribery laws and regulations, and treat bribery as a criminal act. To ensure full compliance with these laws and regulations, and in particular to ensure that business is conducted globally in accordance with the principles of fairness, integrity and transparency, ZTE has a "zero-tolerance" attitude towards any form of bribery, including bribery by directors, managers, employees and contract workers (hereinafter referred to as "relevant personnel") or business associates working in the name or for the benefit of ZTE. In short, the company will not tolerate any form of bribery.

ZTE strictly prohibits any form of bribery in the course of conducting business in the public or private sectors. ZTE's relevant personnel or business associates operating in the name or for the benefit of ZTE shall not, directly or indirectly, offer to pay, promise to pay, pay or authorize to pay money or anything of value to any person in public sectors or private enterprises in order to unduly influence any act or decision of the recipient's proper capacity or to obtain or retain business or other improper interests in the business conduct. ZTE has developed a series of regulations, procedures and guidance to minimize the risks of bribery, and further incorporate integrity, transparency and "doing the right thing" into an integral part of the corporate compliance culture, thus promoting our credibility globally.

It is ZTE's policy to comply fully with all applicable anti-corruption and anti-bribery laws and regulations of the countries in which ZTE operates businesses, including requirements and guidance under the related anti-corruption and anti-bribery regulations. Compliance with ZTE’s Anti-Bribery Compliance Program and the laws and regulations on which we are based is an essential requirement for all ZTE employees and business units.

ZTE is also committed to ensuring that transactions undertaken by anyone operating on behalf of the company, including third parties, are in compliance with applicable anti-corruption and anti-bribery laws and regulations. ZTE will take effective measures to ensure that ZTE's partners and third parties are aware that they are expected to comply with the highest standards of integrity and the related anti-bribery compliance requirements when carrying out any act or doing any business on behalf of ZTE.

Anti-corruption and anti-bribery laws and regulations include anti-corruption and anti-bribery laws and regulations of China, the Foreign Corrupt Practices Act (FCPA) of the United States, the United Kingdom Bribery Act (UKBA), and other laws and regulations of countries/regions in which our business operates. ZTE is committed to the strict compliance of its global businesses with applicable anti-corruption and anti-bribery laws. This Policy applies to all board members, management members, and employees of all ZTE departments, subsidiaries and branches, and to all business associates.

Violations of these above laws and regulations will result in serious criminal and civil penalties, including but not limited to fines, imprisonment, and other sanctions or punishments that might impact the entire global business of ZTE. Non-compliance with this Policy, these above laws and regulations, the procedures and the requirements our Company has established will not be tolerated. Employees who violate this Policy will be subject to disciplinary action and/or contract termination.

Our Anti-Bribery Compliance Program has full support of the Board of Directors and the Compliance Management Committee. ZTE is committed to providing sufficient resources and expertise to ensure continued compliance with applicable anti-corruption and anti-bribery laws. 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. ZTE will be issuing a full range of new anti-bribery compliance measures, including but not limited to a revised Anti-Bribery Compliance Manual, regulations and guidance on specified bribery risks. We will also implement additional anti-bribery compliance training, and depend on your participation to create value for ZTE.

The ZTE Anti-Bribery Compliance Policy requires the following:
●All employees of ZTE must complete a statement regarding compliance with the Anti-Bribery Compliance Policy.
●All employees of ZTE, business associates must comply with applicable anti-corruption and anti-bribery laws and regulations, as well as all relevant policies, regulations, and procedures promulgated by ZTE to ensure compliance. 
●All employees of ZTE, business associates must fully understand how anti-corruption and anti-bribery laws apply to the work that they do, participate fully and actively in all compliance training, report any potential compliance issues or violations through effective channels, ensure that records, data and information are accurate, complete and saved, and ask questions to the Anti-commercial Bribery Dept. of ZTE if you are uncertain as to what requirements might apply.
●Exceptions to this Policy require advance legal advice and guidance from the Anti-commercial bribery Dept.

All employees of ZTE are required to report any potential anti-bribery compliance issues or violations. Any reports of potential violations may be made to the compliance contact of your BU, compliance manager, compliance director, supervisor, director of your Dept. or more higher level management, or to the Compliance Audit Dept. or anonymously, and under no circumstances will any ZTE employee be subject to retaliatory action for reporting in good faith an actual or suspected violation.

Reporting Hotline
If you are uncomfortable reporting matters directly to the above personnel, you can also utilize ZTE's other reporting options including some which allow you to remain anonymous.
Email:  complianceaudit@zte.com.cn            Website:  www.zte.com.cn
Phone:  400-830-8330(China)    +86 755 2677170(Global)


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