+ People

ZTE has implemented a compliance program that transcends all levels of the Company. The Compliance Management Committee (CMC) organizes ZTE's overall compliance efforts. Under the leadership of the CMC, ZTE has established an efficient and professional compliance management team to reinforce rules and regulations through the Center of Expertise (COE) and to get closer to the business through 14 business unit (BU) compliance teams. The COE and BU compliance teams conduct compliance management of the Company's business modules and subsidiaries. ZTE has over 400 compliance points of contact (POCs) throughout the global organization that ensure compliance management of subsidiaries and transmit compliance concepts and policies to the front lines of marketing and business. Apart from the COE-BU-POC team, ZTE has a Compliance Audit Department (CAD) to independently audit compliance, conduct independent investigations, and it has set up the Global Law & Policy Research Institute to be the think tank of ZTE. Currently, ZTE has more than 400 full-time legal and compliance personnel, accounting for approximately 6‰ of ZTE's total employees.

+ Process

ZTE is building best-in-class compliance programs, featuring continuous improvements to ensure policies and procedures are fully implemented, prevent systemic risks, and safeguard the interests of ZTE and its business partners. ZTE's compliance enhancements observe international standards and rules and they are implemented to provide support and accountability within ZTE. To help hold the Company accountable, ZTE has also established multiple whistleblowing channels, including a whistleblowing platform managed by an independent third party, for employees to report compliance violations more freely.

+ Technology

ZTE recognizes the importance of technology and automation in a global compliance program. ZTE uses a Robotic Process Automation (RPA) to streamline its compliance management process. For example, ZTE has implemented SAP Global Trade Systems (GTS) software, a trade compliance tool used by many major multinational corporations, to ensure that transactions comply with all applicable laws in the countries in which it operates, including the export control law of the United States, and has automated its compliance management process.

ZTE recognizes the importance of technology and automation in a global compliance program and continuously invests in the development of digital tools and system digitalization through compliance data governance, compliance requirement embedding, and compliance system development. Based on years of experience in compliance, ZTE has independently developed the Export Compliance Screening System (ECSS), the world's first lightweight SaaS digital compliance system, integrating core functions such as product ECCN classification management, controlled product review, restricted/concerned party list screening, sanctioned country/region screening, customer type and end-use review, master data management, and audit report output. The Company also develops several mobile apps to satisfy agile business scenarios.

+ Outreach

ZTE conducts industry outreach through relevant conferences, compliance associations, and other communications channels with business partners, government agencies, and external advisors to stay abreast of various regulatory changes and compliance best practices. 

Since 2019, ZTE has held three compliance symposiums. At each symposium, experts and professionals from various fields shared their ideas with each other. The symposiums have also provided precious opportunities for us to gain more insights into compliance. ZTE also shared compliance insights at global compliance forums such as the 2022 ACES Compliance Summit.