Quarterly CECO Newsletter to Business Partners – Q3 2021
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Quarterly CECO Newsletter to Business Partners – Q3 2021

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 2021 to ensure export control compliance and to maintain strong relationships with our business partners.

Track policy changes in a timely manner to efficiently support business development: In this quarter, ZTE has continued to pay close attention to regional situations, analyzed and predicted the impact of possible policy changes on ZTE's business, and prepared plans for business changes in advance. At the same time, the company’s Export Control Compliance Dept. attended the virtual annual meeting of U.S. Department of Commerce, Bureau of Industry and Security in 2021 to learn about the cutting-edge trends of major supervisory authority in US export control, it will help us to better comply with export compliance requirements. For the EU regulations on export control of dual-use items which came into effect in September, the Company also followed changes in the regulation and released interpretations of the regulation.

New achievements in the construction of compliance manuals: Building a compliance manual is an important part of building an effective compliance system. ZTE has been committed to continuously improving the compliance manuals and expanding its influence in the compliance rule system. In this quarter, ZTE further updated the export control compliance clauses of the Corporate-Level Manual, and initiated the annual revision of the Corporate-Level Manual and trained operating subsidiaries on manual development. The "Regulations and Policies" and "Eight Elements of ECP" modules in the manual practice community have been completed, realizing the timely response of the compliance manual to the changes of policies and regulations and the positive interaction between the manual and other compliance elements. Also,we established a mandatory feedback mechanism from risk assessment result to the manual practice community. The performance manner of risk assessment activities, problem detection, and manual revision suggestions shall be fed back to the Export Compliance Manual Project Team in a timely and effective manner through the risk assessment module in the manual practice community. This promotes the bi-directional interaction and exchange between risk assessment project and manual project, and ensures that the compliance management and control in the business process are consistent with the requirements in the compliance manual.

Continuous promotion on export authorization control: In terms of export authorization control, ZTE headquarter dispatched teams to operating subsidiaries to provide guidance on ECCN online publication. Through in-depth understanding of the subsidiary's business processes, ZTE headquarter helped subsidiaries identify weaknesses and optimized them in many aspects, such as organization, process specification, system control, business operation results and training effect verification, to continuously improve the ECCN online publication capacity of subsidiaries and independently build an export control compliance system. In addition, for the management and control of the export authorization system, ZTE has implemented Export Compliance?Scan?System ( “ECSS” )in two subsidiaries. Through the implementation of the ECSS system, the subsidiary can identify export control compliance risks, train its own export control compliance management expert team and ECSS maintenance team to further improve the export control compliance system. In terms of GTS implementation, the GTS system has been upgraded, and the implementation scope of GTS has been continuously expanded. ZTE's automatic compliance management and control capabilities have been effectively improved.

Carry out external compliance communication actively : ZTE continued to actively carry out research cooperation in the field of compliance and exchange experience in the construction of compliance system with customers and partners globally in this quarter. The company's hierarchical compliance exchanges with important customers and partners around the world are being carried out in an orderly manner, and the compliance and credit enhancement work is further deepened. The company's improved and standardized external compliance communication mechanism has better demonstrated ZTE's excellent compliance corporate image and enhanced the recognition of the company's compliance brand in the industry.

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ZTE thanks our business partners for your consistent 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
                                                                                         +65 84999511 (Singapore/新加坡)
                                                                                         +86 15768250208 (China/中国)