Compliance Policy

As a global leader in ICT solutions, Huawei operates across multiple domains including telecommunications networks, enterprise business, digital power, and cloud services. In managing business relationships among internal employees, as well as with external users, customers, suppliers, shareholders, and other Interested Parties, the company is committed to adhering to the highest standards of business conduct—complying not only with all applicable national laws and regulations but also upholding the highest ethical business principles. This represents both our compliance values and the primary principle guiding our business operations.

To this end, Huawei Technologies Switzerland AG has established the following compliance policy based on its purpose, values, objectives, and strategic framework:

I. Scope of Application

The company is committed to complying with its applicable compliance obligations, including applicable laws and regulations, contractual and customer requirements, and relevant internal policies and requirements.

II. Compliance Commitment

The company commits to complying with applicable laws and regulations, international conventions, and internal company policies in all business operations within the countries and regions where it operates; and to continuously establish, implement, maintain, and improve its compliance management system, thereby providing a framework for setting compliance objectives.

This Compliance Policy shall be implemented and enforced throughout the company through appropriate governance, processes, controls, training, monitoring and corrective actions.

III. Compliance Governance

The company's compliance management system is led by the Country Board of Directors and top management, with designated compliance risk control owners assigned to each risk area to ensure comprehensive oversight across all domains. When encountering complex issues, employees may seek assistance, guidance, or clarification from their business unit managers, the Legal Department, Human Resources Department, or the relevant compliance risk control owner.

Huawei Switzerland Chief Compliance Officer is responsible for the company's operational compliance, has direct access to the board of directors, and participates in major decision-making. The compliance function operates free from improper interference, possesses adequate authority, resources, and professional capabilities commensurate with its responsibilities, and provides independent advice to the organization. The compliance function collaborates with governance, risk, audit, legal, and other functions. The responsibilities of the compliance function do not relieve any other individual of their compliance obligations.

The company has established an independent reporting process. Any employee may, at their own discretion, report any misconduct related to Huawei or arising from its business, management, and operations to their immediate supervisor, the Human Resources Department, or through the company's dedicated reporting channel, either openly, confidentially, or anonymously.

IV. Compliance Objective Framework

The company identifies and manages compliance objectives based on its applicable compliance obligations and compliance risks, including the following core compliance domains within the current CMS scope: workforce management compliance, visa compliance, cyber security, privacy protection, trade compliance, trade secret protection, ABC (Anti-Bribery and Corruption), customs compliance, competition law compliance, and EHS, using these as the framework for setting compliance objectives.

V. Raising Concerns and Prohibition of Retaliation

The company encourages employees and external parties to report, in good faith, any suspected violations of laws or regulations or any breaches of the company's code of business conduct to the Human Resources Department or via the reporting email address.

The company commits to strictly maintaining the confidentiality of reported information and whistleblowers, and will not tolerate any form of punishment or retaliation against individuals who in good faith seek advice or report suspicious conduct or potential violations of compliance requirements.

VI. Consequences of Violations

Employees who violate compliance requirements will be subject to disciplinary actions, up to and including termination of employment and civil or criminal prosecution. In addition, under applicable laws, disciplinary actions also apply to individuals who instigate, assist, or approve such violations, who are aware of such violations but fail to report them promptly in accordance with company policies, or who intentionally provide false statements or conceal facts during the company's investigation of such violations. Where applicable, violations by business partners or other third parties may result in contractual remedies, suspension or termination of the business relationship, or other appropriate measures.

VII. Documented Management

This policy is available as documented information, communicated within the company organization, and accessible to interested parties as appropriate.