2022 Export Control Compliance Policy
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ZTE's 2022 Export Control Compliance Policy

DATE:        15 September 2022

日期:       2022年9月15日

TO:           Directors, Officers, Employees and Contract Employees

致:          全体董事、管理人员、员工和合同工

FROM:       Li Zixue, Chairman of ZTE Corporation

                 Xu Ziyang, President of ZTE Corporation

自:         李自学,中兴通讯股份有限公司董事长


SUBJECT:  2022 Export Control Compliance Policy

主题:      2022年出口管制合规政策

Export Compliance is critical to the business of ZTE Corporation and its majority owned or controlled subsidiaries and affiliates (collectively, "ZTE"). Compliance not only protects value, but it also creates value. ZTE has been building its value for its customers, shareholders, and employees, through the dedication and vigilance to export compliance of every individual. ZTE requires employees and contract 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 and 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 ; and (3) the U.S. Department of the Treasury Office of Foreign Assets Control (“OFAC“) Settlement Agreement. 

It is the policy and commitment of ZTE to cooperate fully with the BIS-appointed Special Compliance Coordinator (“SCC”), Roscoe C. Howard, Jr. and his team. All employees and contract employees must fully cooperate with the SCC and his team under the requirements of the monitorship.   
中兴通讯的政策和承诺是与BIS指定的特别合规协调员(“SCC”)Roscoe C. Howard,Jr.及其团队充分合作。所有员工和合同工应当全面配合SCC及其团队的监管要求。

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 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 applicable laws and regulations, including restrictions under export control and economic sanctions laws and regulations. Compliance with ZTE’s Export Compliance Program and the laws and regulations on which it is based is an essential requirement for ZTE’s employees, contract employees and business teams.

Export control and economic sanctions laws and regulations include export control and economic sanctions 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 controlled by the U.S. export control and economic sanctions laws and regulations, such as the Export Administration Regulations (“EAR”) administered by the BIS and economic sanctions regulations administered by the OFAC; (2) shipments via Hong Kong should comply with Hong Kong’s 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 and regulations.

ZTE is also committed to taking steps on an export compliance risk basis to ensure that transactions undertaken by anyone operating with or on behalf of ZTE are in compliance with applicable export control and economic sanctions laws and regulations.

Violations of these laws and regulations may result in serious criminal and/or 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 these laws and regulations, this Policy and the procedures the Company has established will not be tolerated. Employees and contract employees who violate this Policy will be subject to disciplinary action and/or termination.

The Board of Directors and the Export Compliance Committee of ZTE has been fully supporting the Export Compliance Program. ZTE is committed to providing sufficient resources to ensure continued compliance with applicable export control and economic sanctions laws and regulations. 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 (please refer to the end of this policy) regarding compliance with ZTE’s 2022 Export Control Compliance Policy, unless excused, in extraordinary circumstances, 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 and contract employees must provide accurate, complete and timely information to BU Compliance Team, ECC, and the SCC and his team. If employees and contract employees are aware that inaccurate or misleading information has been provided to BU Compliance Team, ECC, or the SCC and his team, 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 applicable compliance training, report any actual or 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 BU Compliance Team, ECC or Chief Export Compliance Officer (“CECO”) if they are uncertain as to what requirements might apply.

●Before exporting, reexporting, procuring, or otherwise transferring commodities, 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 commdities, 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 subject to comprehensive territorial sanctions (“Sanctioned Countries/Regions” currently, Iran, Syria, North Korea, Cuba, Crimea region, “Donetsk People's Republic” (“DNR”) and “Luhansk People's Republic” (“LNR”) regions), whether or not U.S.-origin items are involved and whether or not the items 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 historic business in these countries/regions. Any activities related to ZTE’s exit from historic business in these countries/regions, including those countries/regions that may have had their comprehensive territorial sanctions lifted such as Sudan, 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 List or the Entity List 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 with a party on the Entity List involving items that are not subject to the EAR . 

●Employees and contract employees must follow company compliance procedures established to reduce these risks. Such compliance procedures at ZTE include, but 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 the business transactions; performing compliance screening and export authorization determination. Conducting additional due diligence, and obtaining end-user or end-use statements is also sometimes required on an export compliance risk basis when necessary, for example, business involving regions posing heightened risks of diversion, risks of Restricted Parties and/or restricted end uses, or any other red flags.

Exceptions to this Policy require advanced legal advice and guidance from CECO or his designees.

●Employees and contract 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(whose term expired on March 22, 2022 U.S. time), 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 ECC.

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

●If you have any questions concerning this Policy, please contact immediately CECO or ECC. 

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

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

Selected Points of Contact in ECC











Koh Sow Koon (Lawrence Koh)

Chief Export Compliance Officer


Head of ECC Department






China中国: +86 157-6825-0208

Singapore新加坡 +65 8499-9511

Xie Xianxin


Deputy Head of ECC







China中国: +86 186-7553-6545

Wang Songtao


Director of Compliance


China and the Americas




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 and Africa




UAE阿联酋: +971 52 820 5519

Sergey Dovgulya

ECC Regional Contact of EU and Russia


Europe and Russia






+7 910 472 36 79

Compliance Reporting Options

If you are uncomfortable reporting matters directly to ECC or BU compliance team, 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
  http://lcm.zte.com.cn - 合规稽查 - 违规线索报

●Letter/Visit 信函/亲临:
  Compliance Audit Dept., ZTE R&D Building, 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 actual or potential violations, the SCC and his team has also established the Special Compliance Coordinator Confidential Reporting Program for export compliance-related questions and concerns. The SCC reporting program can be accessed through:
or by calling the independent Compliance Reporting Line at +1-202-831-6700.
Violations or concerns can be reported directly to the SCC and his team by sending emails to Reporting@scc1.org.

Li Zixue, Chairman of ZTE Corporation                        Xu Ziyang, President of ZTE Corporation 
李自学,中兴通讯股份有限公司董事长                           徐子阳,中兴通讯股份有限公司总裁