March 2019 CECO Newsletter to Business Partners
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March 2019 CECO Newsletter to Business Partners

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 recent efforts to ensure compliance, to prevent future problems and to maintain strong relationships with our business partners.


ZTE is actively working to meet all of its compliance obligations under its Superseding Settlement Agreement (“SSA”) with the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”). ZTE is committed to ensuring export compliance to avoid any future issues for ZTE or our business partners. ZTE is cooperating with the Monitor and the Special Compliance Coordinator (“SCC”), achieving milestones under the SSA, updating BIS regarding the steps it is taking to fulfill its SSA obligations, and continuing to make advancements on its export compliance program.


Obligations under the Settlement Agreements with the US Government: ZTE continues to fulfill milestones and make progress on its obligations under the settlements.  This includes submitting various reports on export compliance to the US Department of Commerce and the Monitor and SCC who were appointed under the settlements. As an example, the Company submitted its quarterly filing to BIS regarding trainings that were conducted during Q4 2018, in addition to the November 1st export compliance expenditure report sent to both the Monitor and the SCC. 

与美国政府签订的和解协议下的义务: 中兴公司持续实现里程碑式进步并在履行和解义务方面取得进展。这包括向美国商务部以及根据和解协议指定的监察官和SCC提交各类出口合规报告。例如,除向监察官和SCC发送日期为2018年11月1日的出口合规开支报告外,公司就2018年第四季度开展的培训向BIS提交了季度提交材料。

Communication with Business Partners: ZTE continues to work with its business partners to ensure export compliance in our supply chain and distribution channels.  For example, we collaborate with our business partners to collect and share Export Control Classification Numbers and related classification for our mutual benefit. We look forward to continuing these and other compliance efforts with you and our other business partners. 


Publication of Export Control Classification Numbers: Within 180 days of the issuance of the SSA, ZTE began publishing the applicable Export Control Classification Number and the amount of (and method of calculation for) controlled U.S.-origin content in all of its products.  This information is publicly available on ZTE’s website which went live on December 4, 2018 at and is available in both Chinese and English.  


Export Compliance Forums: Over the last year, ZTE’s export compliance professionals have presented at several conferences in China, including two important conferences that occurred in the fourth quarter of 2018. In October 2018, ZTE presented “Export Control Compliance Construction and Development” at the Compliance Forum of China Enterprise in Cross-Border Investment and Trade held in Beijing. During the following month, ZTE and Wolters Kluwer jointly organized and sponsored the 2018 Legal and Compliance Forum, at which a ZTE employee delivered a presentation on “Corporate Export Compliance Responsibility and Compliance Project Initiatives.”


Extensive Employee Training: The Company continues to update and enhance training curriculum and provides courses to employees tailored to match individual business functions. In addition to other courses, ZTE recently engaged a third-party company, Content Enablers, to develop a suite of training courses ranging from general awareness training to specialized courses targeting executives, middle management and specific job functions. In addition, training through the Subsidiary Compliance Enhancement Program (“SCEP”) was completed during this quarter. Key SCEP accomplishments include organizing compliance trainings for executives and employees and utilizing fly-away teams to carry out on-site training and assistance.

大量的员工培训:公司持续更新和改进培训课程并向员工提供与个体业务职能相符的定制化课程。除其他课程外,中兴公司近期聘请了第三方公司Content Enablers以开发一套涵盖从全员意识培训课程到针对高级管理人员、中级管理层和特定职位的专门课程的培训课程。此外,通过子公司合规提升计划(“SCEP”)开展的培训于本季度完成。SCEP关键成果包括组织面向高级管理人员和员工的合规培训并利用飞行团队提供现场培训和帮助。

ZTE’s Export Compliance Implementation Plans: Our export compliance implementation plans outline, track and memorialize enhancements to our export compliance program. As part of our efforts to fulfill our settlement obligations, our export compliance implementation plans follow the framework outlined by the US Department of Commerce for an effective export compliance program. The Monitor and SCC have received regular updates on the progress of the implementation plans. 


Increased Resources for Export Controls Compliance: ZTE continues to dedicate substantial external and internal resources towards export controls compliance. The Export Controls Compliance Department now includes more than 40 individuals. In addition, ZTE receives extensive support and guidance from a team of external lawyers and consultants. ZTE has significantly increased its compliance budget and intends to dedicate the necessary resources to ensure compliance and to meet its settlement obligations.


ZTE Continues to Cooperate with the Special Compliance Coordinator and the Monitor: ZTE continues to cooperate with the Special Compliance Coordinator, Roscoe Howard Jr., and the Monitor, James M. Stanton. Their teams have visited numerous ZTE sites and have participated in ZTE training and meetings at locations worldwide. For example, in December 2018, SCC team members spent approximately three weeks in China with ZTE personnel to participate in meetings and site visits. The SCC and Monitor have praised the commitment of ZTE’s senior leadership to compliance, as well as the efforts of ZTE’s Legal and Compliance leaders in enhancing the Company’s compliance program. Recently, in January 2019, the Monitor and SCC teams have completed additional site visits and met with ZTE personnel worldwide. In the coming months, ZTE will continue to support the SCC’s and Monitor’s work and implement their recommendations, as part of the Company’s broader effort to continue to strengthen its export compliance program.

中兴公司持续配合特别合规协调员和监察官:中兴公司持续配合特别合规协调员Roscoe Howard Jr.和监察官James M. Stanton。监察官和SCC团队造访了中兴公司的多处场所并参与了中兴公司在全球范围内的培训和会议。例如,2018年12月,SCC团队成员在中国花费了约三周的时间同中兴人员接触,参与会议和现场造访。SCC和监察官肯定了中兴公司高级领导团队的合规决心,以及中兴公司法律与合规领导为改进公司的合规项目而作出的努力。最近于2019年1月,监察官和SCC团队在世界范围内完成了更多的现场造访并会见了中兴人员。在接下来数月,中兴公司将继续支持SCC和监察官的工作并执行他们的建议,而这是公司为持续增强其出口合规项目而开展的更广泛的工作的一部分。

* * * * *

ZTE thanks our business partners for their continued support. If you have questions, please do not hesitate to contact ZTE at or 400-830-8330 or +86 755 26771706.

中兴公司感谢各位业务合作伙伴给予一贯的支持。如您有任何疑问,请随时与中兴公司联系,发送邮件至或拨打400-830-8330或+86 755 26771706。

                                                                                                                       Lawrence Koh

                                                                                                                       Chief Export Controls Compliance Officer
                                                                                                                       ZTE Corporation
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CECO Newsletter to Business Partners