2021 Export Control Compliance Policy
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2021 Export Control Compliance Policy

DATE:        16 September 2021

日期:       2021年9月16日

TO:           Directors, Officers, Employees and Contract Employees

致:          全体董事、管理人员、员工及合同工

FROM:       Li Zixue, Chairman of ZTE

                 Xu Ziyang, President of ZTE

自:         李自学,中兴通讯董事长


SUBJECT:  2021 Export Control Compliance Policy

主题:      2021年出口管制合规政策

Export Compliance is critical to the business of ZTE. Compliance not only protects value, but it also creates value. ZTE has been building its value for our customers, shareholders, and employees, through the dedication and vigilance to export compliance of every employee. ZTE requires employees to work together, including with the Export Control Compliance Department (“ECC”), and the BU Compliance Team to make ZTE stronger. Export compliance is everyone’s responsibility.

I.Management Commitment to ZTE Obligations

On June 8, 2018, the U.S. Department of Commerce Bureau of Industry & Security (“BIS”) approved the Superseding Settlement Agreement (“SSA”) with ZTE. ZTE also entered into the following joint settlement agreements in March 2017: (1) Plea Agreement with the U.S. Department of Justice; (2) BIS Settlement Agreement (which was superseded by the SSA); and (3) Office of Foreign Assets Control (OFAC) Settlement Agreement.

It is the policy and commitment of ZTE to cooperate fully with the U.S. Court-appointed Monitor, James M. Stanton and his team, and the BIS-appointed Special Compliance Coordinator (“SCC”), Roscoe C. Howard, Jr. and his team. All employees must fully cooperate with the SCC and Monitor teams under the requirements of the monitorships.  
中兴通讯的政策和承诺是与美国法院指定的监察官James Stanton及其团队以及BIS指定的特别合规协调员(“SCC”)Roscoe C. Howard,Jr.及其团队充分合作。所有员工应当全面配合SCC以及监察官团队的监管要求。

In addition to the commitments that ZTE has made under the SSA, ZTE has also set a goal, with self-motivation, of building a world-class export control compliance program based on industry best practices. This requires work and cooperation by everyone, no matter whether you are an employee from a business unit, act as a compliance practitioner within the Company, or are a contract employee of ZTE.

II.Management Commitment to Compliance with Export Control Laws

It is ZTE policy to comply fully with all local rules and regulations, as applicable, including restrictions under economic sanctions and export control laws and regulations, of the countries in which it operates its businesses. Compliance with ZTE’s Export Compliance Program and the regulations on which it is based is an essential requirement for ZTE’s employees, contract employees, and businesses.

Export control regulations include export control laws and regulations of China, the European Union, the United States, and other countries/regions. As examples, (1) ZTE makes certain products incorporating U.S. content that are fully subject to the U.S. export control and economic sanctions regulations, such as the Export Administration Regulations (“EAR”) administered by the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) and economic sanctions regulations administered by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”); (2) shipments via Hong Kong should comply with the Import and Export (Strategic Commodities) Regulations; and (3) shipments via China mainland should comply with Export Control Law of the People's Republic of China. ZTE is committed to the compliance of its global businesses with applicable export control and economic sanctions laws. This Policy generally applies to directors, officers, employees, and contract employees of ZTE departments, branches, and subsidiaries and affiliates over which ZTE Corporation has majority ownership or control.
出口管制法律法规包括中国、欧盟、美国和其他国家/地区的出口管制法律法规。例如,(1)中兴通讯制造的特定产品会并入受美国出口管制和经济制裁规定管辖的美国成分,因此需要遵循如BIS经管的《出口管理条例》(“EAR”)和OFAC经管的经济制裁规定;又例如,(2)途径香港的货运需要遵守香港的《进出口(战略物品)规例》; 再如,(3)途径中国大陆的货运需要遵守《中华人民共和国出口管制法》。中兴通讯致力于使其全球业务遵守可适用的出口管制及经济制裁法律法规。本政策适用于中兴通讯控股控制的中兴通讯各部门、分支机构、子公司、和关联公司的董事、管理人员、员工和合同工。

ZTE is also committed to taking steps on an export compliance risk basis to ensure that transactions undertaken by anyone operating on behalf of ZTE, including agents, distributors, and resellers are in compliance with applicable export control and sanctions laws. This commitment extends to promoting compliance on an on-going basis with terms and conditions of export authorizations.

Violations of these laws and regulations may result in serious criminal and civil penalties, including fines, imprisonment, exclusion from the export licensing process, denial of export privileges and other sanctions which would impact the entire global business of ZTE. Non-compliance with this Policy, these laws, and the procedures the Company has established will not be tolerated. Employees who violate this Policy will be subject to disciplinary action and/or termination.

The Export Compliance Program has our full support and that of the Board of Directors and the Export Compliance Committee. ZTE is committed to providing sufficient resources and expertise to ensure continued compliance with applicable export control and sanctions laws. We understand that compliance creates value, and we ask each of you to support this effort to create value for ZTE and take your compliance responsibilities very seriously. The success of ZTE depends on your full cooperation and support of this critical mission. We will depend on your participation to create value for ZTE.

III.Policy Requirements

The ZTE Export Control Compliance Policy requires the following:

●Employees and contract employees must complete a certification regarding compliance with the Export Control Compliance Policy, unless excused from doing so after review and approval by ECC.

●Employees and contract employees must comply with applicable export control and economic sanctions laws and regulations, as well as all relevant policies and procedures promulgated by ZTE to ensure compliance.

●Employees must provide accurate, complete and timely information to the Export Control Compliance Department, BU Compliance Team, outside counsel, the Monitor, and the SCC. If employees are aware that inaccurate or misleading information has been provided to Export Control Compliance Department, BU Compliance Team, outside counsel, the Monitor, or the SCC, they are required to provide the accurate information or correct any misleading statements.

●Employees and contract employees must fully understand how export control and economic sanctions laws and regulations apply to the work that they do; participate fully and in good faith in all compliance training; report any potential compliance issues or violations to the appropriate compliance personnel; ensure that business documents, records, data, and information are accurate and complete and that required records are maintained and filed in the proper locations; and ask questions of Chief Export Compliance Officer (“CECO”), the Export Control Compliance Department, or BU Compliance Team if they are uncertain as to what requirements, including U.S. restrictions, might apply.

●Before exporting, reexporting, procuring, or otherwise transferring goods, software or technology, or providing related services, the proper export classification(s) of the items must be confirmed under due diligence, and ZTE must confirm that no prior authorization or license is required from any government authority. In this regard, for example, certain products manufactured and/or sold by ZTE are subject to China and/or U.S. dual-use export controls. To the extent that prior export authorization is required, ZTE must not provide any services (e.g., testing, repair, return, support, procurement) or export, reexport, or otherwise transfer goods, software, or technology without first obtaining the authorization.

●Currently, ZTE will not conduct business with any parties located, headquartered, registered in countries or regions that are sanctioned by the United States (“Sanctioned Countries/Regions,” currently, Iran, Syria, North Korea, Cuba, and Crimea), whether or not U.S.-origin items are involved and whether or not the goods or services are provided to or through these countries/regions. This means that ZTE should not conduct any business with companies from the Sanctioned Countries/Regions as the vendor, order party, bill-to party, consignee, end-user, intermediary, logistics provider, bank, carrier/vessel, or as any other party to the transaction. The only exception is with regard to ZTE’s exit from business in these countries/regions. Any activities related to ZTE’s exit from business in these countries/regions must be reviewed in advance by CECO, or his designees, for export compliance purposes.

●ZTE does not engage in any business with Restricted Parties, such as parties that are sanctioned by the United States or other governments, including but not limited to those that relate, directly or indirectly, to individuals and entities identified on (i) the OFAC List of Specially Designated Nationals (“SDN”) or (ii) the Denied Persons or Entity Lists maintained by BIS, except activities which are in full compliance and have been reviewed in advance by CECO, or his designees For example, the CECO or his designees may approve a transaction involving a non-EAR item to a party on the Entity List. 

●ZTE employees must exercise appropriate due diligence and follow company procedures established to reduce these risks. Such compliance processes at ZTE include, but are not limited to: entering accurate and complete name and address information in ZTE systems for business partners, including vendors, customers, and other partners, properly classifying ZTE products, understanding all the parties involved, directly or indirectly, in business transactions, screening known third parties against Restricted Parties Lists, seeking representations, on an export compliance risk basis and/or due diligence, from third parties regarding operations or affiliations in Sanctioned Countries/Regions, special scrutiny of transactions in regions posing a heightened risk of diversion to, or involvement of, Sanctioned Countries/Regions (e.g., the Middle East), obtaining end-use or end-user statements when required such as with respect to a “military end user” and “military-intelligence end user” and identification of warning signs that indicate an export may be destined to an unlawful end-user or end-use or that a business transaction might involve a Sanctioned Countries/Region or a company on one of the Restricted Parties Lists.

As previously reported, Sudan is no longer on the list of Sanctioned Countries/Regions in the ZTE Export Control Compliance Policy. The U.S. Government determined that Sudan is not a state sponsor of terrorism and revised the EAR, effective January 14, 2021. These changes to the EAR followed the issuance of a general license by OFAC authorizing most transactions involving Sudan in January 2017, and the termination of the Sudanese Sanctions Regulations in October 2017. 
-- The Company can sign new contracts and conduct new business involving Sudan. 
-- If a particular project relates to any of the Company’s historical activities in Sudan and involves any EAR items previously delivered to Sudan without a required EAR license, these changes to the EAR are not retroactive and historical violations shall not be exempted without further review; in such cases, a waiver under the EAR may be required. ECC has been and will continue to work with the Business Units to wind down the historic business in Sudan such as collection of payments under historic contracts; payment of vendors or contractors; and the write off of monies owed or related accounting considerations. Any activities related to ZTE’s historical transactions in Sudan must be reported to, reviewed and approved in advance by CECO, or his designees, for export compliance purposes.
-- 公司现在可以签订涉及苏丹的新的合同,开展新的业务。
-- 但如果某一项目与公司在苏丹的任何历史活动有关,并且涉及之前向苏丹交付的任何受EAR管辖且未获得相应许可的物项,此类历史违规活动在没有进一步审查前不受本次EAR规则变动的豁免,这种情况可能需要EAR下的额外授权。ECC已经并将继续与各业务单位合作关停苏丹历史业务,包括历史合同下的收款、向供应商或承包商付款、以及欠款核销或相关财务调整。任何与中兴通讯在苏丹的历史交易相关的活动都必须事先向CECO或其指定人员报告、并被审查和批准,以确保出口合规。

●Exceptions to this Policy require advance legal advice and guidance from CECO or his designated delegate.

●ZTE employees may not publicly comment on the March 2017 Settlement Agreement, March 2017 Plea Agreement, and June 2018 Superseding Settlement Agreement (collectively, “the Settlement Agreements”), the conduct giving rise to the Settlement Agreements, the SCC, the U.S. Court-appointed Monitor, or any other related matter in any public forum, including on any external instant messaging or social media communication platforms without the prior approval of the Export Control Compliance Department.

●ZTE employees must fully cooperate with both the SCC and the Monitor teams. ZTE employees must take requests from the SCC and the Monitor very seriously.  Employees must respond in a truthful, timely and complete manner and in no way interfere with or impede the monitorships. Employees must timely provide available business records as requested by the SCC and the Monitor. Fulfilling requests from the SCC and Monitor quickly, efficiently, and accurately is critical to the ongoing health and success of ZTE’s business.  

●If you have any questions concerning this Policy or the legality of a particular transaction, please contact immediately CECO, and his colleagues at the Export Control Compliance Department.

●Employees and contract employees are required to report any potential export compliance issues or violations. Any reports of potential violations may be made to the Export Control Compliance Department, BU Compliance Team, or Compliance Audit Department anonymously, and under no circumstances will any ZTE employee or contract employee be subject to retaliatory action for reporting in good faith an actual or suspected violation.

●Additionally, if a ZTE employee or contract employee has knowledge of potential violations and fails to report such potential violations to the Export Control Compliance Department, BU Compliance Team, or Compliance Audit Department, he/she may be subject to disciplinary action and/or termination.

Selected Export Control Compliance Department Points of Contact











Koh Sow Koon (Lawrence Koh)

Chief Export Compliance Officer


Head of the ECC Department






China中国: +86 157-6825-0208

Singapore新加坡 +65 8499-9511

Xie Xianxin


Deputy Head of the ECC Department







China中国: +86 186-7553-6545

Wang Songtao


Director of Compliance






China中国: +86 139-2655-9115

Hu Zhe


Director of Compliance






China中国: +86 138-2879-2755 

Deng Yiqian


Director of Compliance






China中国: +86 150-1280-6330

Zheng Weiwei


Director of Compliance, China and APAC


China and APAC







China中国: +86 136-8880-5511


Director of Compliance, MEA


Middle East & Africa




UAE阿联酋: +971 52 820 5519

Sergey Dovgulya

ECC Regional Contact of EU and Russia


Europe & Russia






+7 910 472 36 79

Debbie Mires

Director of Compliance, the Americas


The Americas





+1 972-671-8885 X 81104

Compliance Reporting Options

If you are uncomfortable reporting matters directly to the Export Control Compliance Department, you can also utilize ZTE’s other reporting options including some which allow you to remain anonymous.

●ZTE Compliance Audit Department  中兴通讯合规稽查部
  Website 网站:
  https://www.zte.com.cn/china/whistleblowing/report (for employees in China)
  https://www.zte.com.cn/global/whistleblowing/report (for employees overseas)
  Email 电子邮箱:

●LCM 法律合规管理系统:
  http://lcm.zte.com.cn - Compliance Audit-Violation Report"

●Letter/Visit 信函/亲临:
  Compliance Audit Dept., ZTE headquarters, 55 Hi-Tech South Road, Nanshan District, Shenzhen

●Independent third-party compliance reporting platform 独立第三方合规举报平台
  Website 网站: 
  Email 电子邮箱: 
  Hotlines 热线: 
  400-0707-099 (Mainland China) 
  400-0707-099 (中国大陆)   
  + 8621-3313-8584 (Overseas, Hongkong, Macao and Taiwan)
  + 8621-3313-8584(海外 、香港、澳门、台湾)

In addition to the above options for reporting potential violations of U.S. export control laws and regulations, the SCC team has also established the Special Compliance Coordinator Confidential Reporting Program for compliance-related questions and concerns. The SCC reporting program can be accessed through:
or by making a phone call. Dialing instructions for different countries/regions are available on the website by clicking File a Report.
或通过电话。 您可在网站点击“提交举报”获得不同国家/地区的拨号指导。
Violations or concerns can be reported directly to the SCC by sending emails to Reporting@scc1.org.

Li Zixue, Chairman of ZTE                        Xu Ziyang, President of ZTE
李自学,中兴通讯董事长                           徐子阳,中兴通讯总裁

Addendum to 2021 Export Control Compliance Policy regarding the Conclusion of the Monitor’s Monitorship

The Company has received a U.S. court order confirming that the term of probation and the term of the Monitor, James M. Stanton, have ended as scheduled on March 22, 2022 (U.S. time).
公司已收到美国法院判决,确认公司缓刑期及监察官(“Monitor”)James M. Stanton的任期已于原定的2022年3月22日(美国时间)届满结束。

The Special Compliance Coordinator ("SCC"), Roscoe C. Howard, Jr.,  will continue to perform his duties as set forth in the June 8, 2018 Superseding Settlement Agreement and the related order between the Company and the Bureau of Industry and Security under the U.S. Department of Commerce. The Company will continue to fully cooperate with the SCC in a proactive, transparent, and supportive manner.

特别合规协调员(“SCC”)Roscoe C. Howard, Jr将继续履行公司与美国商务部工业与安全局在2018年6月8日签订的《替代和解协议》及相关命令中规定的职责。公司将会继续秉承协作、透明和支持的态度全力配合SCC的工作。