Anti-bribery Compliance Policy

The Anti-bribery Policy (hereinafter "this Policy") has been developed to make explicit the company's anti-bribery requirements and regulations. 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 to bribery and corruption.

Huawei's subsidiaries around the globe must also comply with local laws and regulations and respect local religious customs. In the event there is any inconsistency between this Policy and local laws and regulations, whichever has stricter requirements shall prevail.

II.  Applicability

All Huawei employees of Huawei Technologies España S.L. (hereinafter "Huawei Spain"), as well as entities and individuals who do business with Huawei, are required to comply with and uphold Huawei's anti-bribery and anti-corruption policies.

III.  Policy requirements

Huawei Spain complies with local legal frameworks of fair competition, anti-bribery, and anti-corruption in the countries where we operate. Huawei places the commitment to anti-bribery and anti-corruption above our business interests, and operates with fairness, integrity, and transparency.

Through continuous investment, Huawei is committed to establishing a compliance management system that aligns with industry best practices, and incorporating compliance management into end-to-end business activities and processes. Huawei will continue cultivating a culture of integrity and asks that all employees adhere to the Employee Business Conduct Guidelines. All Huawei employees, as well as entities and individuals who do business with Huawei, are required to comply with and uphold Huawei's anti-bribery and anti-corruption policies.

Huawei does not allow the provision of money or anything of value, driven by a corrupt intent, to public officials, counterparty stakeholders or stakeholders that can exert influence over a transaction for the purpose of obtaining or retaining business, or securing any other improper advantage. Huawei forbids its employees from taking bribes or soliciting gifts or other benefits directly or indirectly (for details, see Employee Business Conduct Guidelines).

The public officials mentioned above include individuals who perform duties on behalf of government entities; employees of government agencies, state-owned or state-controlled enterprises, or international organizations; candidates of political parties; and other personnel who perform public services according to law. When engaging with public officials, Huawei employees must be mindful of adhering to applicable laws, honesty and integrity requirements for public officials, and Huawei's Anti-bribery Policy.

1.  Gifts and hospitality

Under no circumstances should Huawei employees, motivated by a corrupt intent, be allowed to directly or indirectly offer gifts or hospitality to public officials, customers, or partners, or solicit gifts or hospitality from partners. Laws vary widely from country to country. Different customers also have very different regulations. Huawei employees must always bear in mind the company's anti-bribery policy and evaluate if the company's reputation will be affected when giving or accepting gifts and hospitality.

Make sure the following requirements are met before giving or accepting gifts and hospitality:

- Proper intent: The purpose should be to establish and maintain a good business relationship. Gifts and hospitality should not be used to obtain or retain business, secure any other improper advantage, or influence general business processes or decisions.

- Right timing: Avoid giving or accepting gifts and hospitality during sensitive periods, such as during a bidding process or before an important decision is to be made, as giving or accepting gifts and hospitality at such times may unfairly influence decision making. Reasonable value: Comply with common business practices and do not give or accept excessively generous gifts, cash, or cash equivalents. Do not give or accept other types of prohibited gifts.

- Compliance with laws and regulations: Give or accept gifts and hospitality openly and transparently in compliance with applicable local laws and the anti-bribery regulations of the other party.

2.  Charitable contributions and donations

- Huawei has always pursued balanced growth and committed to fulfilling our social responsibilities rather than blindly maximizing commercial interests and scale.

- It's forbidden to use charitable contributions and donations to disguise corrupt activities. Effective measures must be taken to ensure transparency and legitimacy in making charitable contributions and donations.

- Huawei does not directly or indirectly participate in the political activities of any political party, nor does Huawei sponsor local political parties, their candidates, associated persons, or affiliates.

3.  Facilitation payment

Many countries do not make a distinction between facilitation payments and bribery. Facilitation payments are small payments made directly or indirectly to secure or speed up the performance of a routine action or to avoid bureaucratic delays, for example the issuing of permits by public officials or for goods clearing customs.

Huawei makes no distinction between bribes and so-called ‘facilitation’ payments, which are also prohibited. Huawei is committed to striving to eradicate the payment of facilitation payments, in line with the government’s guidance. Huawei appreciates that in certain sectors and countries it is extremely difficult to conduct business without such payments being requested. Employees are required to assist Huawei in the same by resisting demands for facilitation payments and by building realistic timescales into planning of projects so that shipping importation and delivery schedules allow time for resisting demands for such payments.

If you are requested to pay a facilitation payment then you must report this to your line manager or the Compliance Officer immediately.

4.  Third-party management

Third parties include service providers, suppliers, downstream dealers, agents, consultants, and other partners. Cooperation between Huawei and third parties must be authentic and legitimate. Huawei requires its partners to comply with Huawei Supplier Social Responsibility Code of Conduct, their own codes of conduct, the principles of honesty and integrity, and this Policy.

- Huawei believes that due diligence, complete agreement clauses, and corresponding control procedures are key to ensuring that third parties comply with Huawei's Anti-bribery Policy.

- It's forbidden to utilize, aid, abet or conspire with a third party to engage in bribery.

- Third parties are forbidden from paying bribes on behalf of Huawei or when working with Huawei in any capacity. This prohibition includes bribes in the form of gifts or hospitality offered to Huawei employees, when the gift or hospitality offered does not comply with common business practices.

5.  Books and Records

- At Huawei, appropriate documents should be provided in a transparent and honest manner to support business decisions and archived as required.

- It is required that all financial expenditures and assets disposed of be recorded in account books and financial records in an authentic, complete, and accurate manner in line with the document retention policy, to facilitate future inspection.

- It is prohibited to set up off-the-record funds (See Requirements for Prohibiting Off-the-record Funds for more details).

6.  Consultation and report

- If you have any questions about this Policy, please consult your immediate supervisor. If they cannot answer your questions, then consult the compliance officer of your department or country. If you still have unanswered questions, you can contact the Business Inspection Dept.

- If you know of or suspect a violation of this Policy, please notify us by writing to Alertahuaweisp@huawei.com.

- Huawei will remain confidential and launch investigations and protect the whistleblower from threats or retaliation by keeping his or her identify secret.

IV.  Accountability

Employees who infringe this Policy will be disciplined. Disciplinary measures may include termination of their employment contract, and they may be held legally liable for violations of laws. Huawei will likewise restrict and in some cases terminate its partnership with third parties that infringe this Policy. In addition, Huawei reserves the right to claim damages for any losses caused.