Quarterly CECO Newsletter to Business Partners – Q3 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 Q3 2019 to ensure export control compliance, to prevent future problems and to maintain strong relationships with our business partners.
●Compliance Communications with Multinational Telecommunications Operators: In the third quarter of 2019, ZTE held numbers of meetings including export compliance topics with multiple world's leading multinational telecommunications operators at ZTE headquarters. ZTE’s Chief Legal Officer (“CLO”) Spencer Shen and ZTE’s Chief Export Compliance Officer (“CECO”) Mr. Lawrence Koh, attended the meetings. Also, ZTE’s regional export compliance directors have held meetings with telecommunications operators within their region, such as in China and Kenya. By participating in these meetings, a greater level of confidence on export control compliance has been achieved with our customer’s through illustrating our compliance program and enhancements to date.
●Compliance Communication with Suppliers: In the third quarter of 2019, ZTE’s CECO has made direct communication with the senior management personnel of the suppliers. This direct contact is an important practice under the high-level communication channel between ZTE and suppliers, which is beneficial to enhance the understanding of both parties and promote the exchange of compliance information.
●Continued Communication with Business Partners: ZTE will continue to provide Export Control Compliance support to its business partners to ensure that our business partners are able to understand and comply with ZTE's Export Control Compliance policies and terms signed with ZTE, and can understand and comply with all U.S. and export control regulations, so as to assist ZTE in controlling export compliance risks.
●Continued Enhancements to Expand ECCN Database: ZTE released the de mininmis calculations and the ECCN of the items subject to Export Administration Regulations (“EAR”) based on a 10% de minimis calculation. In addition, the updated function of the ECCN fuzzy logic query improves the efficiency and ease of use of ECCN queries for business partners.
●Continued Progress on SCEP: ZTE's Subsidiary Compliance Enhancement Plan ("SCEP") has completed the second-phase plan which includes completing the on-site visits with the ZTE subsidiaries. The next-phase plan on implementing the enhancement action plan, and completing the 2019 SCEP checklist is in progress. The Compliance Enhancement Action Plan executed by ZTE will further enhance the Export Control Compliance capabilities of ZTE subsidiaries and form a platform for future development.
●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. As part of the Company's efforts to strengthen its Export Compliance Program, ZTE will continue to work closely with the SCC team and the Monitor team to further improve its 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。 作为公司强化其出口合规项目的一部分，中兴通讯将会继续与SCC团队和监察官团队密切合作，进一步开展合规体系完善的相关工作。
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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 or email at email@example.com by telephone on 400-830-8330 or +86 755 26771706.
中兴通讯感谢各位业务合作伙伴给予一贯的支持。如您有任何疑问，请随时与您的中兴通讯接口人联系，或发送邮件至complianceaudit@zte.com.cn，或拨打400-830-8330或+86 755 26771706。
Chief Export Compliance Officer
+65 84999511 (Singapore/新加坡)
+86 18588454350 (China/中国)