We conduct business with integrity, adhere to standard business ethics, and observe all applicable laws and regulations in the countries and regions in which we operate. This is a guiding principle for our management team. For years, we have invested heavily in building a compliance management system that aligns with industry best practices and embeds compliance management into every link of our business activities and processes. These efforts continue to this day. We value and work hard to create a culture of integrity. All employees are required to comply with our Business Conduct Guidelines (BCGs).
The Huawei Compliance Management White Paper, released in 2020, draws on our extensive experience in compliance management as well as on international standards, guidelines, and best practices. It describes how we manage compliance in a risk-based manner, while accommodating the characteristics of different countries and business domains.
Building a professional compliance management team is a long-term effort. In every country or region where we operate, we appoint full-time compliance officers who manage and oversee the operational compliance of local subsidiaries. In particular, we have taken the following steps to ensure local compliance:
- Compliance is included in the key performance indicators (KPIs) for every team. We adopt a reward and discipline mechanism for good/poor compliance records, and steer subsidiaries' investment in compliance management.
- Guided by Huawei's general compliance requirements, all subsidiaries develop their own compliance management policies and systems with reference to local laws and regulations, to ensure that all of our business activities comply with local law.
- Subsidiaries identify and analyze compliance risks, and on that basis set annual compliance objectives, develop and implement control measures, and regularly review progress to ensure that the measures are effectively implemented.
- Self-assessments, checks by compliance oversight bodies, and independent internal audits are conducted to assess whether compliance management mechanisms are effective. These assessments inform continuous improvement in compliance management.
Huawei is committed to building a culture of compliance and an atmosphere of integrity. Our senior management team leads by example and lives our core value of integrity. The company runs a variety of awareness programs – including internal communications, training, and exams – that remind employees of their obligations and responsibilities in compliance.
In 2020, Huawei continued to enhance our compliance program across multiple domains, including anti-corruption, anti-bribery, protection of intellectual property and trade secrets, trade compliance, financial compliance, cyber security, and privacy protection. We have engaged and collaborated openly and proactively with stakeholders including our customers, partners, and government regulators, to foster mutual understanding and trust. Through ongoing efforts to strengthen compliance, Huawei continues to win the respect and approval of governments and partners around the world.
STORY-Anti-corruption and Anti-bribery
Huawei has zero tolerance for bribery or corruption. In every country in which we operate, we conduct all business under a legal framework that supports fair competition and opposes bribery and corruption. We place our obligation to fight bribery and corruption above our own commercial interests, and we are working to ensure that our business is conducted in a fair and transparent manner.
- We are strengthening our anti-bribery and anti-corruption compliance system in four ways: a culture of compliance, governance and oversight, compliance risk assessment and prevention-discovery-response techniques, and continuous operations. We regularly conduct compliance audits to identify potential compliance risks in all business scenarios, develop targeted control measures, and embed these measures into our business activities and processes.
- Huawei values and works hard to create a culture of integrity. All employees are required to study, sign, and comply with the company's BCGs and anti-corruption policies. Our customized training addresses the different risk scenarios in different countries and regions where Huawei operates, and is available for different employee groups. Training content is distributed in many ways, such as video, forums, and dedicated online training channels, in order to facilitate learning. All partners of Huawei – whether they are directly providing services and fulfilling their contractual obligations to Huawei, or providing services and fulfilling their contractual obligations to Huawei customers or other third parties on behalf of Huawei – are also required to comply with all applicable laws and regulations, industry ethical standards, and Huawei's Anti-corruption Policies for Partners, Huawei Supplier Social Responsibility Code of Conduct, Code of Conduct for Partners of Huawei, and Honesty and Integrity Agreement.
- We have established complaint channels through which employees and other parties can report violations. When Huawei receives a complaint, we launch an investigation and protect the whistleblower from any form of threat or retaliation by keeping their identity secret.
- We continually communicate with our stakeholders (e.g., industry peers, consultants, partners, and NGOs) about compliance, clarifying our position and views on anti-bribery and anti-corruption. This helps ensure that all stakeholders have a clear understanding of Huawei's compliance regulations and policies.
For details about Huawei's statements and policies on anti-corruption and anti-bribery, please visit www.huawei.com/en/.
Anti-corruption training at Huawei Thailand
STORY-Intellectual Property and Trade Secret Protection
Huawei is dedicated to its long-term investments into R&D and continuously enriching its intellectual property (IP) portfolio. Huawei is one of the world's largest patent holders. By the end of 2020, Huawei held more than 100,000 active patents, across over 40,000 families. The company believes that respecting and protecting IP is the foundation of innovation. As a follower and practitioner of IP rules, and a contributor to those rules, as well as an innovator, Huawei has reached cross-license agreements with major ICT companies around the world. We also work tirelessly to improve the environment for protecting innovation and IP in the industry and across countries and regions.
Huawei is committed to protecting its own IP and trade secrets, while respecting those of others. We explicitly prohibit our employees from improperly acquiring, disclosing, using, or disposing of trade secrets of others. Specifically, the key measures Huawei has taken to protect the trade secrets of others include:
- Issuing the Regulations on Respecting and Protecting Third Party Trade Secrets, which sets out clear rules that employees must follow to respect and protect trade secrets of others during business activities and ensure that employees carry out business activities legally and in accordance with our contracts.
- Embedding trade secret protection requirements into business processes such as R&D, sales, procurement, and HR, conducting regular reviews, and continuously improving management mechanisms by taking away lessons and case studies from day-to-day operations.
- Organizing publicity, training, and exams on trade secret protection for all employees, so that they are all fully aware of the obligations and responsibilities they have in terms of trade secret protection compliance.
- Conducting supervision, including checks and audits, to examine efforts aimed at protecting trade secrets of others and thus ensuring effective implementation of policies, rules, and processes.
- Establishing an accountability system based on official corporate policies such as the Accountability Protocol for Infringements of Other Parties' Trade Secrets and the Accountability Rating Criteria for Information Security Violations to hold violators accountable.
Huawei has long been dedicated to complying with all applicable laws and regulations of the countries and regions in which it operates. These include all applicable export control and sanction laws and regulations of the UN, China, the US, and the EU. We have expended immense effort for more than 10 years to establish a mature and sustainable internal system for trade compliance in line with industry best practices and to constantly improve this system.
Following industry best practices, we have established an integrated trade compliance management department within the company. This department manages trade compliance across both group functions and field offices. We have also established specialist teams in our global offices that monitor changes to local laws, integrate trade compliance into the company's rules and processes, and manage and oversee trade compliance in each link of our business operations, from procurement, R&D, and sales to supply and services.
Huawei continuously works to push employees to further their own trade compliance awareness. Every employee must sign the BCGs each year, which includes a commitment to comply with all applicable export control laws and regulations. Huawei provides training sessions on trade compliance to managers and employees across the company, and the format of this training varies from session to session. These efforts, combined with targeted training for specific business scenarios, help employees to fully understand the company's and their own responsibilities and obligations for export control.
Since Huawei Technologies Co., Ltd. and some of its affiliates were added to the Entity List by the US Department of Commerce, the company has reiterated the importance of compliance with export controls and has worked to ensure control measures are in place. We have also maintained communication with our customers, suppliers, and other partners, enhancing mutual understanding and trust.
For details about Huawei's statement of compliance with export control regulations, please visit www.huawei.com/en/.
Compliance publicity at Huawei's subsidiary in Saudi Arabia