Statement on Anti-Corruption

Huawei believes that corruption severely damages fair market competition and is a threat to the development of our society, economy and enterprises. Huawei upholds the principles of conducting business ethically and with integrity, and Huawei complies with all applicable laws and regulations in any country or jurisdiction it operates in. Huawei applies a “Zero-Tolerance” approach towards corruption.

With active and effective measures, Huawei has established a managerial system to deter and detect any acts of corruption. It is our policy that any employee or any other person/entity who acts on behalf of Huawei must not, directly or indirectly, offer bribes to any official or any other person/entity in order to gain business advantages. If, for the same purpose, any supplier, agent, consultant or business partner of Huawei (as "Partners") offer bribes to any Huawei employee, the employee must reject the bribe and report the case to the Company. In our cooperation with Partners, via contractual covenants and our partner monitor procedures and processes, Huawei requires all of its Partners to comply with Huawei’s Anti-corruption Policies and also to restrict their business behaviors to avoid unethical behaviors.

This statement is applicable to Huawei Technologies Co., Ltd and all its subsidiaries and affiliates which are directly or indirectly controlled by Huawei Technologies Co., Ltd.

Huawei Technologies Co., Ltd.

Chief Compliance Officer, Song Liuping