Export Control Compliance

As a globally-leading provider of telecommunications equipment and network solutions, ZTE executes applicable control requirements of sales, transfer, export, reexport and dealing of hardware, software and technology. ZTE makes every endeavor to comply with global export control laws and regulations to gain trust from partners and the public, mitigate the operational risk, and takes this as an obligatory duty as ZTE plays an important role in the international market. 

• ZTE Export Control Compliance Rule System: Based on external export control laws and regulations, ZTE Export Control Compliance Rule System includes the export control compliance policy, export control compliance manuals and work instructions, which are updated and maintained in a timely manner. According to the Company's business, we have established the Export Control Compliance Manual Family, which has developed comprehensive and detailed requirements of the export control compliance program. Meanwhile, we integrate compliance requirements originated from internal export control compliance rule system into the main business procedures including LTC, HPPD and supply chain and impose obligations to each department which involves export activities.

• Risk Assessment: With the anchor of the effective ECP construction,  ZTE periodically conducts comprehensive or specific risk assessment activities related to ZTE's business activities and hopes to provide a holistic view on export compliance inherent risks.

• Automatic Management and Control System: To incorporate rules into business and implement automatic system management and control, ZTE has invested resources on automated compliance systems including SAP-GTS, which enables the Company to screen its business partners, conduct embargoed-country screening, perform de minimis calculations regarding whether items are subject to the EAR, and, based on the items' jurisdictional status, determine whether the items are controlled for the country of destination. Additionally, the Company has developed a compliance screening system, ECSS, that similarly provides restricted party screening, embargoed-country screening, de minimis calculations, and license determination reviews.

• License Management: ZTE attaches great importance to the management of licensed items and license application. ZTE has created written procedures and assigned employees defined roles and responsibilities to ensure any use or disposal of licensed items complies with the EAR and track the status of the licensed items regularly. ZTE also has actively cooperated with customers to submit re-export license applications, to ensure the proposed transactions fully comply with applicable global export control laws and regulations.