Quarterly CECO Newsletter to Business Partners – Q1 2020
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Quarterly CECO Newsletter to Business Partners – Q1 2020

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 Q1 2020 to ensure export control compliance, to prevent future problems and to maintain strong relationships with our business partners.


Export Control Compliance work during the epidemic period: Due to the outbreak of the Coronavirus Disease 2019(“COVID-19”), the normal operation of the company has been affected to some extent. In order to minimize the impact,  the ZTE Compliance Depts. have adopted countermeasures such as remote working, personnel in key positions working on site under the prerequisite of ensuring safety, online compliance training performed batch by batch, information exchanging with compliance-related parties in a timely manner. Through the efforts of all employees, most of the tasks on Export Control Compliance are still orderly carried out as originally planned.


Export compliance manual update: In order to make the Export Control Compliance system better, ZTE made an export control compliance manual update plan in 2019. In this plan, ZTE divided the compliance manual into Corporate-Level Manual and Business-Unit-Level Manuals. As the Corporate-Level Manual, the general Export Control Compliance policies and overall requirements are stated in the manual. The Business-Unit-Level Manuals are detailed description with the introduction of service scenarios. They clarify the compliance risks, compliance management and control requirements as well as the compliance management and control plans in common service scenarios in each business field. They also provide supplementary cases to help explaining complicated or special scenarios. This innovation takes into account both the principle and practicality of the compliance manual, and provides more comprehensive and systematic guidance for a group companies like ZTE.


Continued Progress the ECCN project: to promote the work of subsidiary's  Export Control Classification Number (“ECCN”) online publishing and to improve data integrity and accuracy, the ZTE ECCN team has conducted a compliance interview with the subsidiaries about the ECCN online publishing. At the same time, the ECCN team will provide subsidiaries the Subsidiary ECCN Publication Operation Guideline to guide them to effectively complete the work of the ECCN online publishing.  


Risk assessment of the subsidiary: As the focus of ZTE 2020 Export Control Compliance's work, in terms of risk assessment of the subsidiary, ZTE quantified the risks of export control of entities, and produced risk assessment reports for different types of entities   according to different risk levels. This assessment provides basic support and guidance for Export Compliance Program (“ECP”) construction and normalization check/self-check for different types of entities. 


Continued progress of the SAP-GTS system implementation project: In order to promote the management and control of SAP-Global Trade Services (“SAP-GTS”) system input and prevent possible export control compliance risks, ZTE SAP-GTS system implementation team conducted an audit on IT general control execution of 14 SAP-GTS-related IT feeder systems, audit scope includes access control management, version release process and change management etc. At the same time, SAP-GTS system implementation team has further optimized the Legal and Compliance Management (“LCM”) system party screening on country field to reduce and avoid any miss determination of the country field on restricted party screening and help users to better and more strictly identify the risk of restricted parties.  


Cooperation with external regulators: In February 2020, ZTE Chief Export Compliance Officer (“CECO”) Mr. Xu Shaoqin (Lawrence Koh)  held discussions with the Special Compliance Coordinator(“SCC”) and the Monitor in Washington DC  , USA. Through this kind of  discussions, ZTE and the external regulators have gained deeper understanding of each other and helped establish a further cooperation of mutual benefit and trust. 

和外部监管机构的协作:2020年2月份,中兴通讯首席出口管制合规官(“CECO”)许绍勤先生(Lawrence Koh)在美国华盛顿和特别合规协调员(“SCC”)和监察官进行了会谈。中兴通讯通过开展此类会谈,加深了和外部监管机构对彼此的了解,有助于建立更进一步互利互信的合作关系。

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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
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