Statement of Compliance with Export Control Regulations
One of the fundamental policies adopted by Huawei Technologies Co., Ltd. (Hereinafter referred to as "Huawei") is to observe strictly the national and international export control regulations including the relevant United States' laws, fulfill the export control obligations and responsibilities, and build a corporate image as an honest and responsible enterprise to win trust from the international partners and customers. Meanwhile, Huawei is convinced that compliance with national and the relevant international export control regulations will enable Huawei to evade and mitigate trade risks, to increase its competitiveness in the international markets, and to entrench Huawei's long-term development.
Given its insight into the export control regulations, Huawei hereby promises that it will abide by all the export control regulations and international export management regulations related to its business activities, and honor the international commitments made by the Chinese government, including international obligations binding upon the Chinese government, as a member of the United Nations (UN) Security Council. In addition, as an international company, Huawei is committed to observing export control regulations, addressing the requirements for globalization related to the company's business operations, and fulfilling its obligations.
Huawei will establish and implement its internal export control rules with a view to full control, and place export control obligations above its commercial profit. If Huawei believes that the products, technologies, and services to be exported, whether physically or intangibly, might be used by its customers or end-users for developing or manufacturing weapons of mass destruction, delivery mechanisms, or unauthorized conventional military equipment that may jeopardize the national or regional peace or stability, or fall into the hands of terrorist organizations, Huawei will, based on the full control principles, implement strict export control and refrain from exporting related products, technologies, and services. In accordance with the principle of "deemed" export control, Huawei will also carefully monitor and regulate the internal access of its employees to sensitive technology or information that some individuals or organizations might wish to use for malicious purposes.
Huawei will also verify that any intermediaries, such as customs brokers, freight forwarders, or shippers, that it might use in the course of its business operations do not represent a potential proliferation diversion risk. Huawei will refrain from engaging in business with such companies or individuals。As an international and hi-tech enterprise, Huawei is well aware that, to identify sensitive customers and to distinguish product codes and ultimate product use in line with international and national standards, Huawei must establish and maintain closer contact with related Chinese government departments, non-governmental organizations, and export control experts, to obtain relevant technical information, expert guidance and advice.
To ensure the effective implementation of its self-discipline mechanism, Huawei has established a Trade Compliance Committee, led by the Chief Legal Officer, and a Trade Compliance Office, led by the Head of the Legal Office. The Trade Compliance Committee is empowered to veto questionable transactions. Huawei has also established export control regulations, standard procedures for export auditing, archived related documents, launched promotion and training regarding export control rules and regulations, strengthened internal auditing, and clearly defined the responsibilities of the departments involved in export control. Based on the existing information management system, Huawei is planning to establish databases for sensitive products and customers according to international common practice and to perform daily export control through digital means.
The entire staff of Huawei must work toward meeting Huawei's export control targets and strictly carry out related corporate policies. Huawei has established a reward and punishment system to reward staff members who successfully follow Huawei's export control policies, and to penalize strictly those who violate these policies. Employees who violate laws and regulations shall be legally accountable.
This statement applies to all Huawei departments, subsidiaries, and branches.
To keep in line with the Chinese government's latest laws and regulations as well as the applicable international commitments regarding export control, Huawei will review and revise the statement annually according to related laws and regulations.
Huawei Technologies Co., Ltd.