Quarterly CECO Newsletter to Business Partners – Q4 2019

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 Q4 2019 to ensure export control compliance, to prevent future problems and to maintain strong relationships with our business partners.

2019 ZTE Multinational Enterprise Trade Compliance Forum:  ZTE hosted the first ZTE Multinational Enterprise Trade Compliance Forum in Shenzhen in November 2019. Guests from ZTE, industry associations, industry-renowned law firms, and multinational companies were invited to discuss and exchange views on the compliance management in the global trade operation of multinational enterprises and controlling international operation risks in the new era.  Sessions included "Compliance Organizational Structure and Local Compliance of Transnational Enterprises", "Compliance Culture Cultivation", “Reexports, License Exceptions and Licensing”, “Export Compliance Training and Reaching Different Audiences within the Corporation”, and several other important topics. Chief Operating Officer ("COO") of ZTE Xie Junshi and Chief Legal Officer ("CLO") of ZTE Shen Nan shared with the guests ZTE executives' views on the importance of the trade compliance culture. During the Forum, Chief Export Compliance Officer ("CECO") of ZTE Lawrence Koh and several experts in the Export Control Compliance field of his team shared the theme of ZTE's understanding and achievements in Export Control Compliance. The Forum received enthusiastic feedback from the participants. At the Forum, ZTE demonstrated its achievements in developing an export compliance program and its steps in building export control compliance system.

2020 ZTE Global Partners Conference: On November 7, 2019, ZTE held the Global Partners Conference 2020 with the theme of "5G Era, Creating the Future" in Shenzhen.  More than 200 strategic and core suppliers from around the world were invited. Chief Executive Officer (“CEO”) of ZTE Xu Ziyang, COO Mr. Xie Junshi, and CLO Mr. Shen Nan, and other senior managements attended the meeting and made speeches. In his opening speech, Mr. Xu Ziyang stressed once again the ZTE’s general requirements of adhering to compliance as the strategic cornerstone of enterprise development and embedding compliance work in every aspect of daily business. Mr. Shen Nan also introduced the current progress of ZTE's compliance system construction, including promoting investment in resources, improving compliance awareness, and coordinating between organizations, and strengthening tool development and compliance digital transformation at the same time. At the end of the speech, Mr. Shen Nan also expressed the company's willingness to continue to cultivate legal compliance brands in the future and build compliance with the partners..

Continuous in-depth Export Control Compliance training: ZTE Export Control Compliance training is continuing to expand in breadth and depth. Considering the Export Control Compliance training requirements of overseas local employees, some courses are  available in multiple languages. At the same time, the content of training is also evolving to more position-related training, including online compliance awareness courses for functional areas. Currently, ZTE has also started planning for 2020 Export Compliance Training  

Continued Progress on SCEP: ZTE's subsidiary compliance enhancement plan ("SCEP") has completed the second phase plan including the on-site visit of the subsidiary, and the project has entered the third phase – the implementation of the enhancement action plan and the review of the implementation results. Currently, the SCEP checklist for 2019 is being reviewed. It is expected that the checklist will be completed by the end of the year, and such ZTE entities are scheduled to sign the Export Control Compliance Certificate before January 31, 2020.  ZTE further strengthened and consolidated the implementation of Export Control Compliance in controlled subsidiaries/branches through the implementation of SCEP in 2019.

Obligations under the Agreements with the US Government: ZTE continues to fully cooperate with the Special Compliance Coordinator (“SCC”), Roscoe Howard Jr., and the Monitor, James M. Stanton, who have been appointed by the US government under its agreements. The suggestions made by the SCC team and the Monitor team will support the Company to strengthen its Export Compliance Program and further improve the Company's Export Control Compliance system.. 
与美国政府协议下的义务:中兴通讯将继续完全配合与美国政府协议下指定的特别合规协调员(”SCC”)Roscoe Howard Jr. 和监察官James M. Stanton的工作。 SCC团队和监察官团队提出的建议,将会支撑公司强化其出口合规项目,并进一步完善公司的出口管制合规体系。

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ZTE thanks our business partners for their continued support. If you have questions, please do not hesitate to contact ZTE by your point of contact.

                                                                                             Lawrence Koh

                                                                                             Chief Export Control Compliance Officer 
                                                                                             ZTE Corporation
                                                                                            +65 84999511 (Singapore/新加坡)
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