Trade Compliance

One of the core principles adopted by Huawei Technologies Co., Ltd. (hereinafter referred to as "Huawei") is to abide by all applicable export control laws and regulations; fulfill export control obligations and responsibilities; and sustain Huawei's corporate commitment to being an honest and responsible enterprise deserving of trust from its customers, suppliers, and other partners. Huawei believes that compliance with applicable export control laws and regulations enables the company to mitigate trade compliance risks and guarantee Huawei's continued success.

Huawei has established and implemented its internal compliance program (ICP) based on a "catch-all" control regime, and prioritizes export control obligations above commercial interests. If Huawei believes that products, technologies, or services to be exported, whether tangible or intangible, may be used for developing or manufacturing weapons of mass destruction, their delivery systems, or unauthorized conventional military equipment, or for any other prohibited end-use pursuant to applicable laws and regulations that may jeopardize national or regional peace or stability, or fall into the hands of terrorist organizations, Huawei will, based on the principle of "catch-all" control, implement relevant export control measures and refrain from exporting such products, technologies, or services.

Huawei has established a Trade and Customs Compliance management framework for formulating and improving the company's import and export control compliance policies, regulations, and processes, and promoting the implementation of relevant requirements in all applicable business units. Huawei verifies and screens transaction parties involved in its business operations, conducts export control classifications for its products and technologies, and obtains export control licenses when necessary. Huawei has built a robust recordkeeping system, strengthened the training and development of export control knowledge and skills, and conducted periodic internal assessments and audits.

All Huawei staff are required to work toward meeting Huawei's Trade and Customs Compliance requirements and carrying out related corporate policies. Therefore, Huawei has established an incentive and accountability system. Huawei employees who do not abide by applicable laws and regulations shall be held legally liable.