Dear Valued Business Partner:
At ZTE, we believe that export compliance is conducive to the sustainable business development of you and ZTE. This newsletter describes some of the major efforts we have made over the last year to ensure export control compliance. We believe these compliance construction measures will help to maintain a sound relationship with you.
First, in terms of rule navigation, ZTE has developed, by the manual project, a Corporate-Level Export Control Compliance manual and BU-level manuals corresponding to ZTE business features. This manual contains both general compliance principles and scenario-based guidelines, forming a compliance manual family. In 2021, ZTE Corporation guided the operating subsidiaries to complete the development of their own manuals and the establishment of the manual family. At the same time, we have completed annual revision on the released manuals according to the changes in business practices and external policies and regulations. Through the manuals community of practice, the interaction mechanism among manuals, policies and regulations, and ECP (Export Compliance Project) 8 elements is formed. Next, the ZTE Compliance manual project will promote digital construction, and complete the construction of the export control compliance portal website with the manuals as the core. ZTE is looking forward to more exchanges with you in this field.
首先，在规则引领方面，中兴通讯通过手册项目开发了与自身业务特点相匹配的出口管制合规手册总册以及各业务域分册，既有总的合规原则也有场景化指引，形成了合规手册族系。2021年，中兴通讯股份指导经营型子公司完成了手册的开发，手册族系搭建完成。同时，我们也根据业务实践和外部政策法规的变化对已发布手册做了年度修订，通过手册实践社区形成手册与政策法规、ECP（Export Compliance Project）八要素的互动机制。下一步，中兴通讯合规手册项目将推进数字化建设，完成以手册为核心的出口管制合规门户网站建设，期待与您在这一领域有更多交流。
Secondly, among the four elements of export control (Items, Party, Country, and End Use), ECCN classification of items is an important basic work. Since 2018, ZTE has established a professional ECCN classification expert team. After more than three years of construction, the three-level responsibility structure for export control classification has been established. The personnel who are engaged in ECCN classification shall pass the examination and be certified with the professional qualification certification. Every six months, ZTE will carry out classification expert certification to continuously improve the classification ability of ECCN.Currently, there are over 300 certified classification experts.
In addition, to establish a first-class compliance system, ZTE has independently developed and designed the Export Compliance Screening System（ECSS）since 2020. The ECSS system can be interconnected with the common systems in the industry and can cover various industry modes. In 2021, the ECSS has been deployed and implemented in four ZTE subsidiaries to help the subsidiaries achieve automatic export compliance management and control, and trained a group of professional teams that are leading the industry. Through the implementation of the ECSS system in the subsidiaries, the accuracy, ease of use and stability of the ECSS are continuously improved, and a professional team that is familiar with the system process and has the ability of export control compliance consulting service is trained. Backed by ZTEC's digital technology product development capabilities and ZTEC's enterprise compliance management experience, We will provide support for the system control of more subsidiaries in 2022.
Finally, in response to the digital transformation demand, with the help of the digital technology product department of the company, Export Control Compliance department and the business units jointly developed the digital risk assessment tools and data platform, applying the data power to the risk assessment management, and performing precise prediction and effective governance before the risk escalation. This tool makes reference to the data extraction and inspection logic of external professional organizations, and fully combines with the company's business models to make the system visualized. Digital forensic analysis has replaced manual operation, and plays an important role in the internalization of the company's capabilities and the improvement of the risk assessment capabilities.
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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.
Chief Export Control Compliance Officer
+65 84999511 (Singapore/新加坡)
+86 15768250208 (China/中国)