Ensuring Operational Compliance
We conduct business with integrity, adhere to common business ethics, and observe all applicable laws and regulations in the countries and regions in which we operate. This is a guiding principle for our management team. For years, we have worked hard to build a compliance management system that aligns with industry best practices and embeds compliance management into every link of our business activities and processes. These efforts continue to this day. Huawei values and works hard to create a culture of integrity, and requires all employees to comply with its Business Conduct Guidelines (BCGs). Outside of the organization, we openly engage and share experiences with our business partners, giving them insights into our development of a global compliance system.
Huawei has appointed a compliance officer for each of its subsidiaries worldwide and established oversight-oriented subsidiary boards, which manage and oversee the operational compliance of these subsidiaries.
- The company has incorporated compliance into the key performance indicators (KPIs) of its subsidiaries, and established an award and disciplinary mechanism to steer compliance management among subsidiaries.
- Under the guidance of the group's unified compliance requirements, all subsidiaries set their own compliance management policies and systems with reference to local laws and regulations, and ensure appropriate compliance management in the countries and regions where we operate.
- Following thorough risk identification and assessment processes, subsidiaries set annual compliance objectives, develop and implement control measures, and regularly review progress, thereby ensuring compliance objectives are achieved.
- Subsidiaries also perform self-checks, ad-hoc inspections, and independent internal audits, and invite third parties to audit key compliance areas, to ensure that compliance management is effective.
Huawei values and works hard to create a culture of integrity, and requires all employees to comply with its BCGs. On this basis, each subsidiary has released detailed employee behavior guidelines to ensure employees incorporate compliance requirements into everything they do.
In 2019, 99.98% of our employees studied and signed the BCGs.
Huawei Employee Business Conduct Guidelines + Subsidiaries' tailored employee behavior guidelines: Incorporating compliance requirements into employee behavior
In 2019, Huawei continued to strengthen its compliance across multiple domains, including trade compliance, financial compliance, anti-bribery compliance, intellectual property and trade secret protection, and cyber security and privacy protection. Compliance requirements have been embedded into our business activities and processes. We have worked openly and proactively with stakeholders like customers, partners, and government regulators, and shared our compliance initiatives and practices with them to foster mutual understanding and trust. Through ongoing efforts to strengthen compliance, Huawei continues to win the respect and recognition of governments and partners around the world.
Anti-corruption and Anti-bribery
Integrity is at the core of our operations. We adhere to common business ethics and observe all applicable laws and regulations in the countries and regions in which we operate. We have zero tolerance for bribery or corruption.
We conduct all business under the legal framework that supports fair competition and opposes bribery and corruption. We place our obligation to fight bribery and corruption above our own commercial interests, and we are working to ensure that our business is conducted in a fair and transparent manner.
- We are strengthening our anti-bribery and anti-corruption compliance management system in four ways: a culture of compliance, governance and oversight, prevention-discovery-response, and continuous operations. We regularly conduct compliance audits to identify potential risks in all business scenarios, develop targeted control measures, and embed these measures into our business activities and processes.
- Huawei values and works hard to create a culture of integrity.
- All employees are required to study, sign, and comply with the company's BCGs and its anti-bribery and anti-corruption policies. We also provide anti-bribery and anti-corruption training programs for key employee groups.
- All third parties who do business with Huawei must comply with and uphold Huawei's anti-bribery and anti-corruption policies, and observe the Huawei Supplier Social Responsibility Code, Code of Conduct for Partners of Huawei, and Honesty and Integrity Agreement.
- We have established complaint channels through which employees and other parties can report violations. We have also established three lines of defense through which we can identify risks, discover problems, and make improvements.
- We continually communicate with our stakeholders, including industry peers, consultants, partners, and NGOs, about compliance, clarifying our views on anti-bribery and anti-corruption. This helps ensure that all stakeholders have a clear understanding of Huawei's compliance regulations and policies.
Intellectual Property Rights (IPR) and Trade Secret Protection
Huawei applies common international IPR rules and handles IPR affairs in accordance with international conventions. We adopt a proactive, amicable attitude towards addressing IPR issues through various channels like cross-licensing and business partnerships. In addition, we invest in long-term R&D and continuously enrich our IPR portfolio. Huawei is one of the world's largest patent holders. As of December 31, 2019, Huawei held more than 85,000 active patents, over 30,000 of which were granted in China and over 50,000 outside of China.
As a follower, practitioner, and contributor of IPR rules, as well as an innovator, Huawei protects its own IPR and respects the IPR of others. We have embedded requirements for protecting trade secrets into our policies, systems, and processes. We have also defined clear requirements for employees to respect IPR and the trade secrets of third parties during business activities, and we ensure all employees are aware of related requirements and carry out business activities in a lawful and contractual manner.