Code of Conduct for Partners

I. PURPOSE

This Code of Conduct for Partners of Huawei Technologies Switzerland AG (“Code of Conduct”) is released to promote and ensure the absolute integrity of Huawei’s business dealings with its partners (including Huawei suppliers), hereinafter the “Partners” It is intended to establish clear compliance standards and ethical principles which all Partners of Huawei are expected to comply with.

II. APPLICABILITY

This Code of Conduct applies to all distributors and/or Huawei Partners and their employees, temporary workers, agents, subcontractors, and similar individuals or entities. Huawei Partners (“Partners”) refer to any party that (i) sells Huawei products or services; (ii) cooperates with Huawei in joint solutions development and sales and/or (iii) provides products or services to Huawei, including but not limited to channel partner, solution partner, supplier, agent and consultant. Huawei expects all our Partners to be familiar with and comply with applicable laws and regulations and demonstrate high standards of business ethics.

III. LEGAL COMPLIANCE

1. General Legal Compliance

The Partners shall comply with all applicable laws and regulations in force in their place of incorporation and the places in which they operate as well as any applicable international laws and rules. The Partners are expected to ensure that cooperation with Huawei will not be negatively affected by their legal compliance problems.

2. Legal Compliance

Partners must comply with applicable laws and regulations in force in their place of incorporation and the places in which they operate as well as any applicable international laws and rules. Partners are expected to ensure cooperation with Huawei will not be negatively affected due to legal compliance problems.

2.1 Labor Protection

The Partners must provide their employees with a healthy work environment where they are treated with dignity and fairness and ensure that their employees are free from discrimination or harassment for any reason whatsoever, including skin color, ethnicity, age, gender, sexual orientation, religion, or political affiliation.

2.2 Environmental Compliance

The Partners must conduct their operations in an environmentally responsible business manner and in strict compliance with applicable environmental laws and standards.

2.3 Government Customers

Partners must comply with all applicable bidding or procurement laws when conducting business with governments, public institutions, state-owned enterprises, governmental departments, quasi-governmental bodies or local authorities where such bidding or procurement regulations apply (either at a national or international level). Partners shall also abide by the applicable codes of conduct of such governmental or public institutions or organizations when interacting with the same and their officers or employees.

2.4 Anti-Bribery

1) Partners hereby expressly acknowledge that compliance with applicable legislation on the prevention of bribery and corruption is condition precedent to entering into this Agreement and a business relationship with Huawei;

2) Partners acknowledge that it is familiar with and will abide by the anti-bribery laws in all countries in which it is incorporated or established and in which it does business, and agree that they will not take or knowingly permit any action or inaction to be taken that would cause loss of reputation, goodwill or opportunity to Huawei, that constitutes a crime or cause Huawei to violate any applicable law;

3) Partners hereby declare to ensure compliance with applicable legislation on the prevention bribery and corruption, in connection with its activities, and to the Partner’s best knowledge that its directors, officers, employees and agents, have, in the course of their respective duties, complied with such legislation, and having received adequate inhouse training with respect to the above referred legislation;

4) Partners shall abstain from having or establishing any relation with any third parties that do not ensure compliance with applicable legislation on the prevention of bribery and corruption, or that could in any way harm Huawei’s integrity and reputation;

5) Partners and its directors, employees, agents or any person who provides services for or on their behalf shall commit to resort only to legitimate and ethical business practices and will under no circumstances engage in any activity, practice or conduct, or take any direct or indirect action or inaction that would likely constitute an offense under any anti-bribery laws, including but not limited to:

• Offering or accepting, directly or indirectly, gifts, payments in cash, securities, payment vouchers, communication equipment, vehicles, stationery or office goods of high value, donations, rebate, payoff, influence payment, facilitation payment, kickback or any other type of pecuniary or non-pecuniary advantage, or promise of the same, from any natural or legal person, whether from the public or private sector, that could compromise or condition the integrity and impartiality of their duties, or with the aim of illicitly obtaining or maintaining any business or advantage or inducing any undue influence.
• Offering or promising to offer, directly or indirectly, any gifts, courtesies, hospitalities, invitations or any other type of pecuniary or non-pecuniary advantage to any natural or legal person in the public sector may constitute or be deemed to constitute a socially adequate conduct or a practice contrary to local customs and traditions.
• Making or promising to make any unlawful sponsorships or donations, including contributions to political parties or candidates to political roles (as well as their close relatives and associates).
• Offering to or accepting from Huawei´s employees or their close relatives and associates any of the aforementioned advantages, or invitations to events without the prior written consent of Huawei, including but not limited to travel, entertainment of high consumption, or travels to scenic resorts under false pretense of business meetings, as a way to obtain illicit benefits or maintain cooperation with Huawei, except if such activities are paid for by Huawei.
• Any form of bribery to Huawei’s current or former employees, their close relatives or associates through any agent, such as through a “consultancy” or other intermediaries by signing “consultant agreements” and paying “consultant fees”.
• Any action or involvement with persons, banks or other entities that might violate any applicable economic sanctions, regulations, embargoes or restrictive measures enacted, administered, imposed or enforced by the United Nations Security Council and/or other relevant governmental institution, agency or authority or any applicable anti-money laundering and counter terrorist financing laws.
• Cover up any information that may compromise Huawei´s interests.

6) Partners shall support Huawei in building a business culture of honesty and integrity by rejecting any solicitation for kickbacks and favors from Huawei’s employees or their close relatives or associates during the course of day-to-day business, and undertakes to immediately file a report to Huawei’s internal department in charge through the channels listed hereunder upon occurrence or suspicion of any act or omission that may deemed as a violation of applicable legislation on the prevention of bribery and corruption. Partners further acknowledge that its failure to reject or report such solicitation or its agreement to satisfy such solicitation shall be deemed as committing bribery itself, and Partner shall take relevant liabilities.

3. Unfair Competition

Partners must at all times promote, in the commercial activities in which they engage, fair, free and effective competition that does not harm the market, customers and all those with whom Huawei maintains or aims to maintain commercial or professional relations. Partners also undertake to not monopolize the market or engage in any unfair competition practices individually or in collusion with others. Typical examples of this conduct include but are not limited to practices that damage the rights and interests of end users: (i) dividing markets through agreement or collusion; (ii) fixing resale prices; (iii) coordinating in competing bids; (iv) requiring purchase of tie-in products; and (v) abusing a dominant position in the market.

4. Cyber Security, Data Protection and Money Laundering

The Partners shall strictly abide by all applicable laws and regulations regarding cyber security, data protection and money laundering of the countries/provinces/states in which they operate and shall not infringe the freedom of communication and privacy of end users or any further stakeholders, as the case may apply.

5. Export Control

Partners shall strictly abide by: (i) the applicable laws, regulations, and resolutions regarding export control of the countries in which they operate; (ii) any export control laws of the United States; and (iii) any further export control obligations Huawei communicates to a Partner from time to time whether set out in Partners contract or otherwise.

IV. BUSINESS ETHICS

1. Complete and Truthful Materials

The Partners must ensure that all materials they provide to Huawei are truthful, factual, legitimate, and valid and that full authorization has been obtained from third parties if the materials contain any confidential information related to a third-party. The Partners must also acknowledge that all information they provide to Huawei, including but not limited to purchase orders, sales reports, special price applications, rebates, payment applications, and changes to important company information, are truthful, accurate, and complete.

2. Falsified Revenue

The Partners are not allowed to assist Huawei employees in recognizing falsified revenue, recognizing revenue in advance, or intentionally delaying revenue recognition by such means as creating fraudulent projects, inflating customer requirements, signing multiple contracts for the same project, or providing fraudulent receipts or acceptance reports, neither are the Partners allowed to forge/falsify stamps, official documents, or correspondences of Huawei in any form.

3. Lawful Acquisition and Use of Competitor Information

The Partners are prohibited from using any illegal or unethical means to acquire and use trade secrets or other confidential information of others, including but not limited to improper solicitation or receipt of confidential information from customers, a competitor's employee, or any other party, whether or not such information is owned by the competitor or the third-party.

4. Marketing Communication and Advertising Media

In the course of marketing communication, the Partners shall not make false/misleading statements or exaggerate product performance. Without prior written permission from Huawei, the Partners shall not disclose information regarding their projects in cooperation with Huawei to the media.

During external business interactions, the Partners shall not make any false or misleading statements to any party.

5. Subject to Huawei Audits

The Partners shall not cover up any information that may compromise Huawei's interests. To ensure compliance with this Code of Conduct, Partners shall be subject to reasonable audits from Huawei or third parties on its behalf.

6. Compliance with Huawei's Partner Policies

To the extent permissible by Swiss law, the Partners must strictly abide by Huawei's Partner policies, including but not limited to policies and regulations on Partner management, Partner incentives, and supply paths. They must also recognize Huawei's exclusive right to develop and interpret the said policies and regulations.

7. Unauthorized Commitments

The Partners shall not make commitments to end users or any third party on matters in which they have not been authorized in writing by a Huawei representative with such express authority to do so.

Any losses incurred by Huawei from a Partner's unauthorized commitment or its failure to reject the unauthorized commitment of Huawei employees (i.e. those Huawei employees not expressly authorized to make such a commitment) shall be fully borne by the Partner on a full indemnity basis and Huawei shall not be obligated to any contractual commitments to Partner arising from such actions.

8. Defamation

The Partners must operate with integrity and shall not defame or disparage Huawei or its competitors. The Partners are prohibited from making false or misleading statements regarding competitors or their products and services.

9. Bribing Huawei Employees

The Partners are not allowed to bribe or transfer illicit benefits to any Huawei employee in any forms whatsoever, including but not limited to cash, negotiable securities, and payment vouchers, in an attempt to obtain illicit benefits or maintain cooperation with Huawei. In addition, Partners are not allowed to give inappropriate gifts and/or etiquette to Huawei employees that exceed the appropriateness to the situation, or any other conduct that could be construed as inappropriate conduct. Whether the entertainment or gifts are to be qualified as appropriate business etiquette or not shall be determined by Huawei at its discretion taking into account various factors including considering whether those involved in the giving or receiving would be embarrassed should such events or actions be made known to the public. This clause also applies to the family members and other close relatives of Huawei employees.

10. Conflict-of-interest relationship

The Partners shall not allow those who currently work at Huawei or their family members to have a stake in their company. In the event that a Huawei employee or his/her immediate family member(s) works for a Partner, or acts as an employee, consultant, board member, executive, or shareholder of the Partner, the Partner shall report such situations to Huawei immediately.

11. Intellectual Property Rights and Confidential Information

The Partners shall respect Huawei's intellectual property rights. Without prior written permission, the Partners shall not disclose any confidential information they have access to during their dealings with Huawei nor use any Huawei intellectual property except in accordance with any applicable license granted by Huawei.

V. COMPLIANCE MANAGEMENT

1. Establishing a Compliance System

Huawei encourages all Partners to establish their own internal compliance management system to ensure compliance with all Swiss applicable laws and regulations, including without limitation, such laws and regulations related to fair competition, sanction, export control, and alignment with Huawei's policies.

2. Communicating Huawei's Principles

The Partners must strictly manage the conduct of their employees, ensure employees abide by their own business conduct guidelines, and require their employees to abide by this Code of Conduct.

VI. MISCELLANEOUS

1. Consequences of any Violation of this Code of Conduct

Any violation of this Code of Conduct may result in review and reduction of incentives Partners are entitled to or the immediate termination of the business relationship with Huawei. In addition, Huawei reserves the right to request Partners to indemnify all losses caused to Huawei due to their violation of this Code of Conduct.

2. Submitting Questions or Reporting Violations

If you have a reasonable belief of the existence of misconduct of this Code of Conduct, please refer to <Huawei Switzerland Whistle Blowing Policy and Procedure>.

3. Data Protection

Huawei Technologies Switzerland AG, as data controller, may process the minimum required personal data, necessary relating the herein stated purpose and to comply with this policy. Huawei strictly adheres to all applicable laws and regulations and Swiss Federal Data Protection Act (09/2023). To know how Huawei processes your data, review our general Data Protection Policy in https://www.huawei.com/ch-en/privacy-policy.

VII. EXCEPTIONS and DEVIATIONS

Any exceptions or deviations from the requirement set out in this document need to be approved by the Huawei Switzerland CEO.

VIII. OWNER and CONTACT PERSON

Huawei Technologies Switzerland AG Legal Affairs Department reserves the right to amend and interpret these Regulations at any time. Huawei reserves the right to supplement and change this Code of Conduct at any time.

IX. EFFECTIVE DATE

This file takes effect as of Sep 10th, 2025, and remains valid for 5 years.