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Huawei Supplier Social Responsibility Code of Conduct

Huawei is a leading global provider of information and communications technology (ICT) infrastructure and smart devices. Our mission is to bring digital to every person, home and organization for a fully connected, intelligent world. To this end, Huawei is committed to supporting the United Nations Sustainable Development Goals (SDGs) and working closely with our partners up and down the supply chain to fulfil our corporate social responsibility (CSR) and create a sustainable value chain.

The Huawei Supplier Social Responsibility Code of Conduct (the "Code") has been developed with reference to the Responsible Business Alliance (RBA) Code of Conduct and Joint Audit Cooperation (JAC) Supply Chain Sustainability Guidelines, as a part of our supplier CSR agreement and Huawei's CSR requirements for all suppliers.

Huawei requires suppliers to comply with all applicable laws and regulations, which is a prerequisite for cooperation with Huawei. We encourage suppliers to draw on internationally recognized industry standards and best practices to improve their CSR management. With reasonable notice, Huawei has the right to conduct onsite audits of suppliers to assess their compliance with this Code.

Huawei has developed a procurement CSR management system based on the OECD Due Diligence Guidance for Responsible Business Conduct and IPC-1401 Corporate Social Responsibility Management System Standard. We incorporate CSR into every link of our procurement process, from material qualification, supplier qualification and selection, to performance evaluation and portfolio management. Where suppliers are equally matched in other factors, those that perform better in CSR are given priority for share of business or business opportunities. For suppliers with poor CSR performance, especially those who are found to have crossed the CSR red lines we draw for suppliers, we may instruct them to resolve existing issues within a specified timeframe, and reduce their share of business or business opportunities. We may even terminate our business relationships with those that fail to make improvements within the required timeframe.

This Code applies to all suppliers who provide products and/or services to Huawei Investment & Holding Co., Ltd. and/or its global subsidiaries and affiliates ("Huawei"). This Code applies to all workers, including temporary workers, migrant workers, apprentices, student workers, contract workers, direct employees, and any other type of workers.

This Code consists of five sections: labor standards, health and safety, environmental protection, business ethics, and management systems.

1. Labor Standards

1.1 Freely Chosen Employment

Suppliers must ensure that all workers are employed on a purely voluntary basis. Suppliers must not employ any form of slave labor (including all forms of modern slavery), forced labor, bonded labor, indentured labor, or prison labor. Suppliers must not restrict workers' freedom of movement, retain workers' identity documents, or engage in any form of human trafficking. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. Workers must not be required to pay any deposits, recruitment fees, or any other fees to their employers or agents.

1.2 Child Labor and Young Workers

1. Suppliers must comply with all applicable laws and regulations in their country relating to minimum working age, and must not use child labor in any form.

2. Suppliers must implement an appropriate mechanism to verify the age of workers during hiring. Workers under the age of 18 must not perform work that may jeopardize their health or safety.

3. Suppliers must ensure proper protections for student workers and apprentices in accordance with applicable law and regulations.

1.3 Working Hours

Suppliers must comply with all applicable laws and regulations relating to working hours and breaks. All overtime must be voluntary. A standard workweek (excluding overtime) must be defined based on local law, and must not exceed 48 hours. Total working hours in any week must not exceed 60 hours. Workers must at least have one day off after every six consecutive days of work.

1.4 Wages and Benefits

Compensation paid to workers must comply with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits. Suppliers must pay wages to their workers in full and on time, and workers must be provided with understandable wage statements.

1.5 Humane Treatment

Suppliers must not engage in any act of violence, including verbal abuse, threats, corporal punishment, sexual harassment, physical coercion, illegal body searches, or cross-gender body searches against workers, nor is there to be the threat of any such treatment.

1.6 Non-discrimination

Suppliers must not engage in discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, membership of an organization, protected genetic information or marital status in hiring and employment practices such as wages, promotions, rewards, access to training, or termination. In addition, workers or potential workers must not be subjected to medical tests or physical exams that could be used in a discriminatory way.

1.7 Freedom of Association

In conformance with local law, suppliers must respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Suppliers must establish channels for communication between the company and its workers or their representatives, and hold regular engagement sessions. Workers and/or their representatives must be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.

2. Health and Safety

Suppliers must provide a healthy, safe working environment. Working conditions that put worker safety or health at risk are prohibited. Fire and explosion risks must be controlled, and concrete steps must be taken to prevent any fatalities in industrial incidents and to prevent potential incidents and occupational illness arising from, associated with, or occurring in the course of work, such as epidemics caused by infectious diseases.

2.1 Working Conditions

1. Suppliers must obtain, maintain, and keep up to date all required health and safety permits, and must comply with the requirements of those permits.

2. Suppliers must identify potential health and safety risks (e.g., fire safety, industrial hygiene, physically demanding work, and machine safeguarding) and reduce or eliminate such risks through hazard elimination, hazard substitution, engineering controls, preventative maintenance, and safe working procedures (including lockout/tagout). Where necessary, workers are to be provided with proper personal protective equipment. Suppliers must also take reasonable steps to protect female workers, especially pregnant women and nursing mothers.

3. Procedures and systems are to be in place to prevent, manage, track, and report occupational injury and illness including provisions to implement corrective actions to eliminate their causes and facilitate return of workers to work.

4. Suppliers must provide workers with appropriate health and safety training in the local language(s). Health and safety related information must be clearly posted in the facility.

2.2 Living Conditions

Workers are to be provided with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. Worker dormitories are to be maintained to be clean and safe and provided with reasonable personal space.

2.3 Emergency Preparedness

Potential emergency situations and events are to be identified and assessed, including risk of fire, explosion, fatal accidents, and mass poisoning. Suppliers must implement emergency plans and response procedures including: emergency reporting, emergency treatment, employee notification and evacuation procedures, worker training and drills, and recovery plans. Such plans and procedures must focus on minimizing harm to life, the environment, and property.

2.4 Absolute Rules

Suppliers must observe the following safety rules, ensure awareness and compliance of all workers, and monitor their compliance:

1. Working at height:

(1) Never working at height without appropriate qualifications and training

(2) Always using suitable personal protective equipment

(3) Never walking or standing underneath suspended loads

(4) Never dropping tools or other objects when working at height

2. Driving:

(1) Always wearing seat belts, either as a driver or a passenger

(2) Never using a hand-held phone while driving

(3) Never exceeding speed limits

(4) Never driving while fatigued

3. Electrical work:

Never carrying out electrical work without appropriate qualifications

4. Alcohol and drugs:

Never working under the influence of alcohol or other drugs

3. Environmental Protection

3.1 Environmental Permits and Reporting

All required environmental permits (e.g., discharge monitoring), approvals and registrations are to be obtained, maintained, and kept current, and their operational and reporting requirements are to be followed.

3.2 Products Environmental Requirements

Suppliers must adhere to all applicable laws, regulations, and customer requirements regarding prohibition or restriction of specific substances, such as the Restriction of Hazardous Substances (RoHS) and Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), and take effective measures to prohibit or restrict the use of specific substances in products and manufacturing.

3.3 Pollution Prevention

Suppliers must comply with all applicable environmental laws and regulations on pollutants (e.g., wastewater, waste gas, and solid waste), including rules on their generation, transport, storage, disposal, and release into the environment. The generation and emissions of pollutants are to be minimized or eliminated at the source. No poisonous or harmful pollutants may be released into the environment, and measures must be taken to prevent noise pollution.

3.4 Energy Saving and Emissions Reduction

Suppliers must take steps to minimize their use of resources, find low-impact substitutes, reduce their consumption of energy, water, and natural resources, and minimize greenhouse gas emissions.

4. Business Ethics

4.1 Integrity

Suppliers must not engage in corruption or unethical conduct. Suppliers must prohibit any form of bribery, gift giving, conflict of interest, falsification, cutting corners, and fraud, and keep all promises.

4.2 Intellectual Property

Intellectual property rights are to be respected; transfer of technology, know-how or knowledge is to be done in a manner that protects intellectual property rights, and customer information is to be safeguarded.

4.3 Fair Business, Advertising and Competition

Standards of fair business, advertising, and competition are to be upheld.

4.4 Protection of Identity and Non-Retaliation

Programs that ensure the confidentiality, anonymity, and protection of supplier and worker whistleblowers are to be maintained, unless prohibited by law. Suppliers must have a communicated process for their workers to be able to raise any concerns without fear of retaliation.

4.5 Responsible Sourcing of Minerals

Suppliers must take reasonable steps to exercise due diligence on the source and chain of custody of the tantalum, tin, tungsten, gold, and cobalt in the products they manufacture, and make their due diligence measures available to customers upon customer request.

4.6 Privacy

Suppliers must commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Suppliers must comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

5. Management Systems

5.1 Company Commitment, Management Accountability and Responsibility

Suppliers must publish CSR policy statements in the local language(s) affirming their commitment to compliance with all applicable laws, industry standards, customer requirements, and this Code, and continual improvement. These statements must be endorsed by their senior management.

Suppliers must assign a senior executive to be responsible for CSR. Suppliers must realize that CSR is part of business management, establish internal appraisal and accountability mechanisms, integrate CSR into corporate function operations, and accept customer onsite audits and disclose information upon request.

5.2 Risk Assessment and Risk Management

Suppliers must identify CSR risks and opportunities associated with their own operations according to applicable laws, industry standards, customer requirements, this Code, and their own strategic needs. Appropriate measures must be taken to control and mitigate the identified risks.

5.3 Management of Upstream Suppliers

Suppliers must establish a procurement CSR management system and incorporate this Code into the procurement requirements for their suppliers, including written commitment, criteria of qualification and selection, and regular audits.

5.4 Internal Audit and Management Review

Suppliers' senior management must regularly assess the CSR performance of their own operations and their suppliers to ensure the appropriateness, adequacy, and effectiveness of the CSR management system.

Huawei reserves the right to interpret this Code.