Compliance Audit 

Independent audit and investigation are important functions of the Company's compliance program and compliance system construction, and this function is undertaken by the Compliance Audit Dept. ("CAD"). CAD is an independent department to play the role of the third line of defense for the Company's compliance management, providing an independent and objective evaluation of the effectiveness of the Company's compliance risk management, punishing violations throughout the Company and defending the value of compliance. The work of CAD mainly includes the implementation of compliance audits in various compliance areas, compliance reporting management, and investigation of violations.

• Compliance Audit: Compliance Audit refers to an independent activity carried out by CAD to inspect whether the compliance regulations and policies are appropriate, whether the compliance management process is complete, and whether compliance management requirements have been executed as required. The Compliance Management Committee is the leading organization that manages the compliance audits of the Company. It's responsible for the building of the Company's compliance audit system, supervising and providing guidance on the implementation of compliance audits. Under the guidance of the Compliance Management Committee, CAD is in charge of drafting the Company's documents concerning the compliance audit system, formulating the Company's overall compliance audit program and annual audit plan, and advancing the implementation of compliance audits in an orderly manner.

• Violation Investigation:  Violation Investigation refers to the activities performed by CAD when identifying, and investigating the alleged violations, punishing the violations, analyzing root causes and proposing rectification suggestions accordingly. The scope of violation investigation includes: 1) incidents or behaviors that violate ZTE's compliance regulations and policies, 2) violations of external export control, anti-commercial bribery or data protection laws and regulations that may cause or have caused legal risks, negative reports or economic loss to ZTE. The investigation execution follows the following principles: Lawfulness and Compliance, Independence, Confidentiality, Investigator Protection and Due Respect and Integrity.

• Compliance Whistleblowing:  Compliance Whistleblowing refers to the action of a whistleblower reporting an internal employee or unit through the website, email, telephone, letter, or visit, regarding an alleged violation of external laws and regulations related to export control, anti-commercial bribery, data protection, and ZTE's compliance policies of related fields. The reporting can be made in real name or anonymously. CAD receives and handles report clues, and assumes responsibility for the reporter information protection and anti-retaliation, and assesses the rewards for compliance reporting.

If there are reasonable reasons to suspect that an employee has committed a violation, any employee or partner of the company can make reports through the following channels:

External independent third-party compliance reporting channels:

Website: http://www.tip-offs.com.cn/ZTE

Email: ZTEWhistleblowing@tip-offs.com.cn

Tel: 400-0707-099 (Chinese Mainland); +8621-3313-8584 (all other areas globally)

Internal compliance reporting channels:

Email: complianceaudit@zte.com.cn

LCM system: <http://lcm.zte.com.cn> Compliance Audit-Report Violation Clue Module

Letter/visit address: Compliance Audit Dept., ZTE Corporation R&D 26/F, 55 Hi-Tech South Road, Nanshan District, Shenzhen

The primary principle of CAD in dealing with reporting is to strictly keep such information confidential. The Company takes a zero-tolerance attitude towards any form of retaliatory behavior, which would be deemed a serious violation of the Company's rules and would lead to severe punishment even being dismissed.