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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 abide by applicable national and international export control laws and regulations including those of China, the United States, the European Union and any other applicable export control laws and regulations; to fulfill the export control obligations and responsibilities; and to sustain Huawei’s corporate commitment to being an honest and responsible enterprise deserving of trust from its customers, suppliers and partners. Huawei believes that compliance with applicable export control laws and regulations enables Huawei to mitigate trade compliance risks, to enhance its competitiveness in international markets, and to guarantee Huawei's continued success. In addition, as an international company, Huawei has always been active in taking up social responsibility and fulfilling its obligations.

Huawei has established and implemented its internal compliance program (ICP) based on a “catch-all” control regime, and prioritizes export control obligations above commercial profit. If Huawei believes that the products, technologies, and services to be exported, whether physical or intangible, may be used for developing or manufacturing weapons of mass destruction, their delivery systems, unauthorized conventional military equipment or any other prohibited end use pursuant to applicable laws and regulations that may jeopardize the national or regional peace or stability or fall into the hands of terrorist organizations, Huawei will, based on the principle of “catch-all” control, implement relevant export control measures and refrain from exporting such products, technologies, and services.

Huawei verifies and screens transaction parties involved in its business operations, including but not limited to customers, suppliers, and partners, so as to comply with applicable export control laws and sanction regulations. Huawei conducts export control classifications for its products and technologies, and obtains export control licenses when necessary. Huawei also establishes and maintains close contacts with government trade compliance regulators, associated non-governmental organizations, and export control legal and compliance professionals, to keep abreast of relevant policy information and seek guidance.

Huawei has set up a Trade and Customs Compliance Committee that comprehensively reviews the policies, systems, organizations, and processes of the company's trade and customs compliance program, and approves or decides on major trade and customs compliance matters and solutions. Huawei has also set up the Trade Compliance Office that is responsible for developing, implementing, and improving Huawei’s export control and relevant sanctions compliance policies, systems, and processes; and driving the execution of these policies, systems, and processes across all applicable business units and corporate functions. To ensure the implementation of trade compliance requirements, Huawei has clearly defined the responsibilities of relevant corporate functions, developed and disseminated relevant guidance documents, built a robust recordkeeping system, strengthened training and development of professional knowledge and export control skills for its employees and the management team, and conducted periodic internal assessments and audits of its internal trade compliance program.

The entire staff of Huawei are required to work toward meeting Huawei's trade compliance requirements and carrying 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 circulate a notice internally and penalize those who violate these policies. Employees who do not abide by applicable laws and regulations shall be held legally responsible.

This statement applies to all departments, branches and subsidiaries of Huawei Technologies Co., Ltd.

The company will routinely review this statement and revise it in accordance with relevant laws and regulations.


Huawei Technologies Co., Ltd.

Chief Compliance Officer, Song Liuping