Anti-corruption Policy for Huawei Partners

Huawei Technologies Deutschland GmbH (hereinafter “Huawei”) upholds the principles of conducting business with integrity, maintaining a strong sense of business ethics, and complying with all applicable laws and regulations. Huawei applies a "Zero-tolerance" approach towards bribery and corruption.

Huawei requires all of its suppliers, service providers, subcontractors, distributors, agents, consultants, ecosystem partners, and other partners (the “Partner(s)”), to comply with all applicable anti-corruption laws and regulations, generally-accepted business ethics, and requirements arising from the Anti-Corruption Policy for Huawei Partners (this “Policy”). Specifically, when Partners provide services directly to Huawei, to Huawei customers, or to third parties on Huawei's behalf in fulfillment of contractual obligations, they must comply with and uphold the following requirements.

1.     Partners are forbidden from engaging in any form of bribery or corruption, including but not limited to:

·       Offering bribes to Public Officials, counterparty stakeholders, or stakeholders that can exert influence over a transaction, with money or anything of value of any form, or for the purpose of obtaining or retaining any business.

"Bribe or Bribery" under this Policy refers to the act of offering, promising, giving or authorizing the transfer of money or anything of value with the intent to improperly influence a decision, secure an unfair advantage, or induce the recipient to act dishonestly. Items of value may include, but are not limited to cash, cash equivalents (such as gift cards and precious metals), inappropriate gifts or entertainment, Travel or hospitality arrangements, improper charitable contributions or donations.

The “Public Officials,” as defined in this Policy, include individuals acting on behalf of government entities; employees of government agencies, state-owned or state-controlled enterprises, and international organizations; members or candidates of political parties; and other personnel who perform public duties under applicable law. When interacting with Public Officials, Partners must ensure full compliance with relevant laws, uphold the standards of honesty and integrity expected of such officials, and strictly adhere to the provisions of this Policy.

·       Any Huawei employee is forbidden from receiving Bribes or offering Bribes (see “Corporate Anti-Bribery Policy” for details). If any Huawei employee attempts to engage, aiding, abetting, inducing or conspiring, the Partner must explicitly refuse to participate and promptly report the incident to Huawei through appropriate channels.

·       Partners are strictly prohibited from offering, promising, or providing any form of Bribe to Huawei employees, whether directly or indirectly, through any means.

2.     Partners must refrain from any improper conduct that could result to joint and several liability of Huawei. They are also responsible for ensuring their own partners or affiliates do not engage in actions that could expose Huawei to such liability.

3.     Partners shall maintain books and records in a truthful, accurate, and complete manner. The creation or use of false, misleading, incomplete, inaccurate or artificial entries in the books and records is strictly prohibited. Additionally, Partners must not establish or utilize any undisclosed or unrecorded accounts under any circumstances.

4.     Partners must establish a robust and effective compliance management system, and implement end to end anti-corruption requirements throughout all aspects of their business operations and processes. To ensure consistent adherence to applicable laws, regulations, and Huawei’s anti-corruption standards, Partners shall pass on Huawei's anti-corruption requirements to their employees and partners, and conduct regularly reviews of their implementation and effectiveness of these requirements.

5.     Partners shall cooperate fully with Huawei. To ensure ongoing compliance with legal, ethical, and anti-corruption standards, Huawei reserves the right to conduct appropriate due diligence and implement relevant control measures. Partners must provide accurate, complete, lawful, and valid documentation, and must not withhold any information that could adversely affect Huawei’s legitimate interests.

If any Partner violates this Policy, or makes any false or fraudulent statement, representation, or warranty, or Huawei has reasonable grounds to suspect that the Partner has committed such misconduct, Huawei reserves the right to immediately suspend or terminate its partnership upon written notice. Meanwhile, Huawei reserves the right to pursue legal action and hold the Partner accountable under applicable laws.

If you have any questions regarding this Policy, or if you become aware of or suspect any violation of applicable anti-corruption laws, regulations, or of Huawei's anti-corruption policies and requirements - whether by a Partner or Huawei employee - you are encouraged to report the matter promptly through the following channel:

1)    Local channel:  Whistleblowing bei Huawei, and whistleblowingHTD@huawei.com

2)    Global channel: BCGcomplain@huawei.com.

Huawei will initiate an investigation into any reported concerns and will take appropriate measures to protect the whistleblower(s) from threats, retaliation or adverse consequences. To the extent permitted by law and practical circumstances, Huawei will maintain the confidentiality of the whistleblower’s identity.

In the event there is any inconsistency between this Policy and applicable local laws and/or regulations, the provision imposing the stricter requirements shall take precedence.

Last Update: September 2025