Statement of Anti-Bribery Compliance Commitment

Huawei Technologies España S.L. (hereinafter referred to as “Huawei”) recognizes that corruption can have a detrimental effect on society by undermining legal system, damaging social and economic development and free and fair competition. Huawei is committed to carrying out our business in an honest and ethical manner which is reflected within our Core Values that form the foundation of Huawei.

Huawei has a zero tolerance of bribery and corruption. Huawei will comply in all respects with all applicable domestic and international laws, standards and principles relating to Anti-Bribery and Corruption (hereinafter referred to as “ABC”) in each of the countries in which Huawei trades, operates or has any other activity.

We are committed to the following business principles:

- To carry out our business fairly, honestly and transparently;

- To not make or receive bribes, or condone the offering of bribes on our behalf, so as to gain a business advantage;

- Avoid doing business with others who do not accept our principles and who may harm our reputation;

- Keep transparent and updated records;

- Make sure that everyone in our business knows and adheres to our principles;

- Keep our principles even when it becomes difficult.

Huawei is committed to the above principles and has developed and implemented ABC program to support our principles, which includes the appointment of a dedicated compliance officer to oversee implementation and continuing review. The compliance officer will report directly to the Country Board of Directors. Huawei also commit to continuously improving the anti-bribery management system and maintaining the authority and independence of the related function.

The ABC risk assessment is performed regularly, at least once per year. In the event of a significant change to the structure or activities of the organization, ad hoc review shall be conducted.

The ABC function will ensure that the program is developed in accordance with all relevant anti-bribery laws, including Spanish Criminal Code, implementation of the program to ensure that the policies and procedures as follows are embedded throughout the Company and monitoring and review of the program to ensure compliance. In order to measure the effectiveness of the ABC program, the annual report must be reviewed every year to ensure that the company strictly adheres to ABC-related policies and remains in compliance with local laws and regulations. The Code of Conduct and the ABC program must be reviewed every three years or whenever there is a change in the attributions or in the organic or corporate structure of the entity that justifies the revision of the principles, values and rules of action within the entity.

The company recognize that continues training to our employees is crucial for an effective compliance program. We commit to provide regular training to our management, employees and partners in order to continuously increasing their ABC awareness.

Any breach by employees or others working on our behalf will result in disciplinary action being taken, up to and including termination of employment. Similarly, any third parties working for Huawei, e.g. contractors, agents or suppliers, will have the business relationship reviewed and/or terminated if they breach of principles.

Huawei has established a whistleblowing channel and encourages everyone to raising concern in good faith or on the basis of a reasonable belief. Huawei will launch investigations and protect the whistleblower from threats or retaliation by keeping his or her identify confidential.