Anti-corruption Policy for Huawei Partners

1. Purpose

The Anti-corruption Policy for Huawei Partners ("this Policy") has been developed to specify Huawei's anti-corruption and anti-bribery requirements for all partners.

2. Applicability

This Policy is applicable to all partners of Huawei Investment & Holding Co., Ltd. and all wholly-owned subsidiaries under its direct or indirect control worldwide ("Huawei" or "the company"), including suppliers, service providers, subcontractors, distributors, agents, consultants, ecosystem partners, and other partners.

3. Definition

Bribe or bribery in this Policy refers to the act of offering or promising to offer money or anything of value in any form with corrupt intent. Such bribes may include but are not limited to cash, cash equivalents, inappropriate gifts, hospitality, and travel, and improper sponsorships and donations.

The public officials mentioned above include individuals who perform public services according to law, as well as employees of government agencies, other personnel who perform duties on behalf of government entities; state-owned or state-controlled enterprises, candidates of political parties; and personnel of international organizations. Stricter management requirements apply to engagement with public officials.

4. Management Requirements

Huawei upholds the principles of conducting business with integrity, maintaining a strong sense of business ethics, and complying with applicable laws and regulations. Huawei applies a "zero-tolerance" approach towards corruption and bribery.

Huawei requires all partners to comply with applicable anti-corruption and anti-bribery laws and regulations, industry ethical standards, and the requirements of this Policy. When acting on behalf of or in cooperation with Huawei, partners shall adhere to the requirements below.

4.1 Partners are forbidden from engaging in any form of corruption or bribery, including but not limited to:

• Partners are forbidden from offering bribes to public officials, customers, or any other stakeholders who can exert influence over a transaction, with money or anything of value received from Huawei, or for the purpose of helping Huawei obtain or retain business.
• Any Huawei employee is forbidden from offering or receiving bribes (See Corporate Anti-corruption Policy for details). If any Huawei employee attempts to instigate or suggest a Huawei partner to engage in bribery, the partner shall explicitly refuse to participate in this act and voluntarily report it to Huawei.
• Partners are forbidden from bribing Huawei employees by any means.

4.2 Partners shall avoid taking any improper action that may lead to joint and several liability of Huawei, and shall prevent their partners from taking any improper action that may lead to joint and several liability of Huawei.

4.3 Partners shall keep books and records in an authentic, accurate, and complete manner. False, inaccurate, incomplete, or misleading entries in books and records are prohibited. No undisclosed or unrecorded accounts may be established or used.

4.4 Partners shall establish an effective compliance management system, and implement anti-corruption requirements within their business activities and processes from end to end. To ensure better compliance with applicable laws and regulations, and Huawei's anti-corruption requirements, partners shall pass Huawei's anti-corruption requirements on to their employees and partners, and regularly review the implementation of these requirements.

4.5 Partners shall coordinate with Huawei. To ensure that partners abide by Huawei's anti-corruption requirements, Huawei shall have the right to conduct proper due diligence of its partners, and implement corresponding legitimate oversight and control procedures. Partners shall provide authentic, complete, legitimate, and valid documents, and shall not hide any information that may negatively impact Huawei's legitimate interests.

5. Violation Handling

If any partner violates this Policy, or makes any false or fraudulent statement, representation, or warranty, or Huawei has reasonable grounds to believe that the partner has committed such an act, Huawei shall have the right to suspend or terminate its partnership with the partner immediately upon issuing a written notice. Meanwhile, Huawei reserves the right to hold the partner legally liable.

6. Consultation and Reporting

If you have any questions about this Policy, or if you know of or suspect a violation of any applicable anti-corruption and anti-bribery laws and regulations, or of Huawei's anti-corruption policies and requirements, by any partner or Huawei employee, please notify us by writing to BCGComplain@huawei.com. Huawei will launch an investigation, and protect the whistleblower from threats or retaliation by keeping their identity confidential to the greatest extent possible.