DATE: 6 September 2019
日 期： 2019年9月6日
TO: Directors, Officers, Employees and Contract Employees
SUBJECT: 2019 Export Control Compliance Management Commitment Statement
ZTE Corporation and its subsidiaries and branches (collectively, "ZTE") are fully committed to compliance with all applicable export control and sanctions laws and regulations. ZTE has committed and will continue to commit substantial resources to ensure compliance with applicable export control and sanctions laws around the world. Throughout this past year, ZTE has implemented a full range of additional export control compliance measures at our subsidiaries（with majority ownership or control） worldwide and has rolled out extensive training programs.
The Export Compliance Committee— which is the chief organization for ZTE's compliance management—and all ZTE management fully support ZTE's ongoing goal to have a best-in-class export control and sanctions compliance program. This past year, ZTE achieved significant milestones on export compliance and will continue to build on that progress to further enhance its export compliance program. It is the responsibility of every individual to fully support this effort.
ZTE's Export Compliance Program will continue to be subject to audits, monitoring and assessments (including regular announced and unannounced site visits), by the Independent Compliance Monitor (“Monitor”), appointed by the U.S. Court, and the Special Compliance Coordinator ("SCC"), appointed by the U.S. Department of Commerce, Bureau of Industry and Security pursuant to the June 8, 2018 Superseding Settlement Agreement. Any failure to fully comply with ZTE's Export Control Compliance Policy and management's statements regarding cooperation and honesty with the Monitor, the SCC, the Export Control Compliance Department, or ZTE's outside counsel and support teams will result in significant discipline up to and including termination.
Please review ZTE's 2019 Export Control Compliance Policy, and follow and understand the requirements of the 2019 Export Control Compliance Policy. All directors, officers, employees, and contract employees must comply with all applicable export control and sanctions laws and regulations as well as all policies and procedures promulgated by ZTE to ensure compliance. Under no circumstances will exports, re-exports, procurements, or transfers (in-country) be made contrary to law or policy by any employee or entity on behalf of ZTE. For example, ZTE makes certain products incorporating U.S. content that are fully subject to the U.S. export control and economic sanctions regulations, including products subject to national security/dual-use controls. Accordingly, all directors, officers, employees, and contract employees must fully understand how export control and economic sanctions laws apply to the work that they do, participate fully in all compliance training, report any potential compliance issues or violations to the appropriate compliance personnel, ensure that records, data and information are accurate and complete and that required records are maintained, and ask questions of Koh Sow Koon (Lawrence), Chief Export Compliance Officer, Export Control Compliance Department, Business Unit Compliance personnel, or the Export Compliance Committee if they are uncertain as to what requirements, including U.S. restrictions, might apply.
请审阅中兴通讯2019年的出口管制合规政策，遵循并理解该政策的要求。全体董事、管理人员、员工和合同工都必须遵守所有可适用的出口管制和制裁法律法规以及中兴通讯为确保合规而颁布的政策和流程。在任何情况下，任何员工或实体均不得代表中兴通讯在违反法律或政策的情况下开展出口、再出口或转移（国内）活动。例如，中兴通讯制造的特定产品会并入受美国出口管制和经济制裁规定的管辖的美国成分，该成分包括受美国国家安全/军民两用出口管制规定管辖的产品。因此，所有董事、管理人员、员工和合同工必须充分理解出口管制和经济制裁法律如何适用于其工作，全面参与所有合规培训，向适当的合规人员报告任何潜在的合规问题或违规行为，确保记录、数据和信息的准确性和完整性，并确保所需记录得到保存，在不确定哪些要求（包括美国限制）可能适用时，向首席出口管制合规官Koh Sow Koon (Lawrence)、出口管制合规部、BU合规人员或出口合规委员会提出咨询。
Violations of the export control and economic sanctions laws may result in serious consequences for ZTE and responsible individuals, including criminal and/or civil fines, sanctioned party designation and even imprisonment, as well as damage to the individual’s and ZTE's reputation, or re-imposition of the Suspended Denial Order. Any director, officer, employee, and contractor found to be in violation of the laws or policies will be subject to disciplinary actions by the Company, up to and including termination, in addition to legal responsibilities.
Compliance not only protects value, but it also creates value. ZTE has been building its value for our customers, shareholders, and employees, through the dedication and vigilance to export compliance of every employee. I ask each of you to continue to take this matter very seriously and to continue to report all export compliance concerns, questions, or potential violations that you identify. If you have any questions concerning potential violations, procedural uncertainties, or if you have suggestions to improve our compliance program, please contact Lawrence Koh, Chief Export Compliance Officer, his colleagues at Export Control Compliance Department, or the Reporting Hotline.
Li Zixue, Chairman of ZTE Xu Ziyang, President of ZTE