As a global leader in telecommunications and information technology, ZTE is always committed to adhering
to high standards of ethics and integrity in global business activities, strictly abiding by applicable
anti-corruption and anti-bribery laws and regulations , to eliminate corruption and bribery in any form.
We always adhere to the values of transparency and integrity in our interaction with business associates
and governments, to ensure ZTE's compliance operation.
Continual Improvement of Anti-Bribery Management System
ZTE has established a robust Anti-Bribery Compliance Program and is reviewing and improving it
continually, to ensure that the program can effectively prevent, detect, and respond to bribery. The
anti-bribery compliance program consists of core elements including tone from the top, effective
compliance organization, sufficient resource input, systematic risk assessment, comprehensive compliance
policy system, effective process control, extensive and tailored training and communication, ongoing
monitoring & review and improvement.
ZTE's Anti-Commercial Bribery Compliance Department has brought together multiples of anti-corruption and
anti-bribery compliance experts, subject matter experts experienced in ISO 37001 Standard, risk
assessment, due diligence, internal audit, and lawyers, law professionals from the world's top 500
multinational enterprises, the leading Four Accounting firms, and national top institutions. Our experts'
compliance management experience covers anti-corruption and anti-bribery core elements, the mechanisms of
risk assessment, due diligence, compliance review, training and communication, continuous supervision and
improvement, and internal audit work together with the BU compliance team full of front-line business
experience to build up the Anti-Bribery Management System and improve its effectiveness continually,
creating value and protecting value for the company.
ZTE conducts systematic risk assessment for relevant entities and businesses in accordance with the
annual risk assessment plan, and implements effective management and intensive control in business
scenarios. In accordance with 2021 risk assessment plan , ZTE has completed risk assessment for the
business in multiple countries and improved the risk control mechanism accordingly; Interconnection
between business and compliance IT system has been established and IT tools used to optimize the
anti-bribery compliance control process and continually improve the overall process and integrated
compliance risk control. Based on compliance management system, the company has set up the Legal and
Compliance Management System (LCM), and embeds each business process to effectively detect and prevent
risks. The Business Partner Screening (BPS), a first-class business partner scanning system in the
industry, is introduced to scan all certification business associates instantly and improve the level of
compliance management and control of business associates. Meanwhile, ZTE has developed anti-bribery
compliance online learning courses for all employees, and has output various process guidelines,
instructions and scenario cases for key positions, and organized various training and discussions to
improve compliance awareness. The company periodically reviews the effectiveness of the anti-bribery
compliance program and continuously monitors and controls the anti-bribery compliance risks in the
company's business activities. At the same time, compliance audit is carried out independently on a
regular basis, defects or weakness (if any) is required to be rectified timely.
ZTE is committed to continually improving the Anti-Bribery Management System and building the
anti-bribery compliance brand. Based on the academic circles, joint legal circles, and cooperation with
the Chamber of Commerce, ZTE Compliance Lecture is held regularly to actively build and maintain an
industry compliance ecosystem. At the same time, ZTE has always attached importance to compliance
communication with domestic and global enterprises, and has developed cooperative and win-win
relationships with business associates to create a fair, transparent and honest business environment for
the healthy and sustainable business development.
Anti-Bribery Compliance and Corporate Social Responsibility
ZTE actively participates in international and domestic anti-corruption and anti-bribery summits, and
joins the Honesty and Anti-Corruption Association; Organizes compliance seminars with universities,
customers, business associates and third parties, and shares compliance management experience.
Recognition of ZTE's Anti-Bribery Compliance from society:
●Transparency International Ranking
In July 2016, ZTE ranked 8th in the Transparency International survey report for large multinational
companies in emerging markets, becoming the only Chinese company to rank among the top 25 in the report.
The anti-corruption compliance program score (88%) is far higher than the enterprise average score (48%)
under research investigation.
●China Enterprise Anti-Fraud Alliance
In August 2016, ZTE joined the anti-fraud alliance of Chinese enterprises, and implemented anti-fraud
actions and systems through innovation and cooperation to jointly build a transparent and honest business
●Trust and Integrity Enterprise Alliance
In January 2018, ZTE joined the Trust and Integrity Enterprise Alliance, jointly promoting the business
philosophy of honesty, self-discipline and law-abiding, and creating a business environment of good-faith
operation and trustworthy consumption.
●Corporate Social Responsibility Recognition
In the 2018 sustainability report of the independent evaluation organization, ZTE's anti-corruption and
anti-bribery compliance policies and program both reached 100(full marks) . In 2021, ZTE (H) has been
included among the FTSE4Good Index Series for fourth consecutive year since its first inclusion in