Export Control Compliance
It is a basic policy of ZTE Corporation, its subsidiaries and divisions (collectively as ZTE) to comply with global export control laws and regulations including those of China and US. As a globally-leading provider of telecommunications equipment and network solutions, ZTE executes applicable control requirements of sales, transfer, export, reexport and dealing of hardware, software and technology. ZTE makes every endeavor to comply with global export control laws and regulations to gain trust from partners and the public, mitigate the operational risk, but also takes this as an obligatory duty as ZTE plays an important role in the international market.
ZTE performs strict Sanctioned Party Screening on clients, freight forwarders, visitors and employees and also conducts detailed due diligence on potential business partners. If the party is sanctioned, ZTE resolutely refuses to seek for business opportunities. ZTE strictly follows the controls of products and technologies, forbids any export or transfer of controlled item and technology without license and prohibits using products for military purposes, monitoring or other human right violation purposes.
ZTE has established Compliance Committee to ensure the implementation of export compliance program. Compliance Committee is the highest authority within ZTE which is in charge of establishing and implementing export compliance policies and procedures. Legal and Compliance Department, as its secretary unit conducts compliance control on ZTE business including research & development, sales, logistics, engineering and service. Any dealing, export and other business activities related to controlled items or technologies must be reviewed by Compliance Committee. According to relevant export control laws and regulations and ZTE export control compliance requirements, the Compliance Committee has veto power against whether to perform such business activities.
ZTE Export Control Compliance Manual has set up comprehensive and detailed requirements, including sanctioned party screening, license management, records management, violation report, audit and reexport control, etc. The manual requires that each department shall follow ZTE business conduct code, export compliance program, import and export management measures and import and export material inventory operation guidelines. Meanwhile ZTE integrates compliance requirement originated from export control laws and regulations and compliance manual into the main procedures including LTC, HPPD and supply chain and impose obligation to each department which involves in export. ZTE has introduced an advanced IT system to screen business partners and conduct transactions review. Through transmission the review results to relevant business systems, ZTE could achieve compliance control towards core business systematically and automatically.
ZTE cooperates with professional institutions to organize and implement comprehensive export compliance training. The training for all employees is focused on the introduction of the basic compliance requirements. The training for different business unit is emphasized on core requirements applicable for each business procedure. The core position training is focused on the “must known knowledge” for important positions. Through various and comprehensive training, ZTE continually improves compliance awareness and impart applicable business compliance requirement differentially to all employees.
ZTE periodically conducts export control compliance risk evaluation on business procedure, audits and inspects high risk countries and important business activities and carries on recording keeping requirements. Based on audit and inspection, ZTE continually optimizes business procedure and control schemes and punishes any employee who violates ZTE’s export control policy.
ZTE will strictly carry out export compliance program and comply with law and regulations applicable to this compliance plan, meet the compliance commitment made to the business partners and actively undertake relevant export control compliance obligation.