Quarterly CECO Newsletter to Business Partners – Q1 2022
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Quarterly CECO Newsletter to Business Partners – Q1 2022

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 in the first quarter of 2022 to ensure export control compliance. We believe these compliance construction measures will help to maintain a robust relationship with you.

As you know, since late February, the United States, Japan, the United Kingdom, the European Union and other countries and organizations have launched a large number of economic sanctions and export control measures against Russia and Belarus. For Russia and Belarus, the Russia/Belarus FDP rule (Foreign Direct Product rule) and Russia/Belarus-MEU FDP rule (FDP rule for Military End User List) have controlled the whole industry chain, preventing specific items or technologies subject to EAR from being obtained by Russia and Belarus or by entities related to these countries. At the same time, the control of items or technologies against Russia and Belarus is expanded and the export authorization scope is narrowed. In addition, a large number of restrictions are made in specific industries and investment and financing fields. A large number of parties and individuals are added into the SDN list (Specially Designated Nationals And Blocked Persons List), the NS-MBS list (Non-SDN Menu-Based Sanctions List) and the Entity List.
如您所知,二月下旬以来,美国、日本、英国、欧盟等国家与组织对俄罗斯、白俄罗斯出台了大量的经济制裁与出口管制措施:针对俄罗斯、白俄罗斯,通过Russia/Belarus FDP规则(外国直接产品规则)以及Russia/Belarus-MEU FDP规则(针对军事最终用户清单主体的FDP规则),实现对全产业链条的管控,阻止特定受EAR管辖的物项或技术被俄罗斯、白俄罗斯或者与这些国家相关的主体获得,同时扩大了针对俄罗斯、白俄罗斯的物项或技术的管控范围并收缩出口授权范围;此外还在特定行业、投融资领域等方面做出了大量的限制;大量主体和个人被加入SDN清单(特别指定国民清单)、NS-MBS清单(非特别指定国民菜单式制裁清单)、实体清单。

Since the beginning of the policy changes of export control and economic sanctions in Russia and Belarus, ZTE has quickly and closely followed up the policy changes and made analysis and interpretation, actively identified appropriate export authorization and conducted business review, comprehensively analyzed the compliance risks caused by the policy changes, and ensured that relevant business activities comply with applicable laws and regulations. In terms of system control, ZTE also timely adjusted GTS and other compliance control systems. In the face of rapid and complex policy changes, ZTE will continue to pay close attention to policy changes, further evaluate and optimize the compliance control scheme according to the risk changes, ensure the legal compliance of the company's business activities, and strive to provide risk response solutions that can make you and our company achieve a win-win situation.

ZTE is also pushing forward the Export Compliance Program construction and building a compliance system in an all-round way. In terms of management commitment, we continue to promote "Compliance Interviews by the Senior Management." In terms of risk assessment, we analyzed and sorted out the export control compliance risk points of internal and external concern, established a risk assessment model, and determined the risk assessment monitoring indicators that can be realized through IT system. In terms of export authorization, we will connect more business types with our subsidiaries to GTS and continue to promote the deployment of ECSS(Export Compliance Screening System)of our subsidiaries. In terms of training, we launched a new round of online compliance training for all employees in 2022 to continuously improve their compliance awareness. In terms of audit, we launched the 2022 audit project update plan. In terms of manuals, we have confirmed the development strategy of manuals in electronic version and continue to promote the construction of compliance manuals of subsidiaries. At the same time, ZTE is continuing to cooperate with the third-party supervisory authority in monitorship, and actively presents the progress of ZTE's compliance construction to the supervisory authority to promote mutual trust in monitorship.
中兴通讯也在持续推进ECP(出口合规项目)建设,全方位建设合规体系。在管理层承诺方面,我们持续推进“高级管理层向下谈合规”。在风险评估方面,我们分析和整理了内外部关注的出口管制合规风险点并建立了风险评估模型,并确定可通过IT 系统实现的风险评估监控指标。在出口授权方面,我们将更多的业务类型与子公司接入GTS,并在继续推进子公司ECSS(出口合规扫描系统)部署。在培训方面,我们开启了2022年新一轮的全员线上合规培训,不断提高全员的合规意识。在审计方面,我们启动了2022年审计项目更新计划。在手册方面,我们确认了手册电子化开发策略,同时在继续推进子公司合规手册建设。同时,中兴通讯也在继续全力配合第三方监管机构的监察工作,积极向监管机构展示我司的合规建设进展,促进监管互信。

Lawrence koh 许绍勤 Chief Export Compliance Officer 首席出口管制合规官 ZTE Corporation 中兴通讯股份有限公司 Lawrence.koh@zte.com.cn +65 84999511 (Singapore/新加坡) +86 15768250208 (China/中国)