Anti-Corruption and Anti-Bribery Compliance

Huawei has a zero-tolerance policy towards corruption and bribery. In every country where 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 across all business scenarios, and optimize and oversee the implementation of related policies and processes.
• Huawei works hard to create a culture of integrity and enhance its compliance capabilities. 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. For example, besides general training for all employees and targeted training for those in high-risk positions, enhanced training is provided to specialists in the compliance team and to employees playing key roles in business processes. Training content is distributed in many ways, including video, forums, and dedicated online training channels. 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 Policy 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 person lodging the complaint 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 the "Policies" section at: https://www.huawei.com/en/sustainability/sustainability-report