Corporate Anti-corruption Policy

1. Purpose

The Corporate Anti-corruption Policy ("this Policy") has been developed to specify Huawei's anti-corruption and anti-bribery requirements and regulations. 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's subsidiaries around the globe must also comply with local laws and regulations and respect local religious customs. In the event of any inconsistency between this Policy and local laws and regulations, the stricter requirements shall prevail.

2. Applicability

This Policy is applicable to Huawei Investment & Holding Co., Ltd. and all wholly-owned subsidiaries under its direct or indirect control worldwide ("Huawei" or "the company"), as well as partners who conduct business on behalf of Huawei.

3. Management Requirements

Huawei complies with local legal frameworks for fair competition, anti-corruption, and anti-bribery in the countries where it operates. Huawei places its commitment to anti-corruption and anti-bribery above its business interests, and operates with fairness, integrity, and transparency.

Through continued investment, Huawei is committed to establishing an effective compliance management system, and incorporating compliance management into end-to-end business activities and processes.

Huawei will continue cultivating a culture of integrity and requires all employees to comply with the company's anti-corruption and anti-bribery policies and Employee Business Conduct Guidelines. Huawei also requires partners who conduct business on behalf of Huawei to comply with these policies, as well as other relevant policies and business conduct guidelines applicable to partners.

Huawei prohibits its employees from offering or promising to offer money or anything of value, driven by corrupt intent, to public officials, customers, partners, or any other stakeholders who can exert influence over a transaction for the purpose of obtaining or retaining business, or securing any improper advantage. Huawei also forbids its employees from taking bribes or directly or indirectly soliciting gifts or other benefits.

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.

3.1 Cash and cash equivalents

Huawei prohibits, under any circumstances, the transfer of benefits to public officials, customers, partners, or any other stakeholders who can exert influence over a transaction, through the payment or promise of payment in cash or cash equivalents. Soliciting cash or cash equivalents from any such parties is also prohibited.

3.2 Gifts and hospitality

Under no circumstances shall Huawei employees, motivated by corrupt intent, be allowed to directly or indirectly offer gifts or hospitality to public officials, customers, partners, or any other stakeholders who can exert influence over a transaction, or solicit gifts or hospitality from any such parties. Laws vary widely from country to country. Different customers also have very different regulations. Huawei employees must always bear in mind the company's anti-corruption policy and evaluate whether the company's reputation will be adversely affected when offering or accepting gifts and hospitality.

Offering or accepting gifts and hospitality must follow these principles:

• Legitimate purpose: The purpose should be to establish and maintain a good business relationship. Gifts and hospitality should not be used to obtain or retain business, secure any improper advantage, or influence general business processes or decisions.
• Right timing: Avoid offering or accepting gifts and hospitality during sensitive periods, such as during a bidding process or before an important decision is to be made, as this may unfairly influence decision making.
• Reasonable value: Comply with common business practices and do not offer or accept excessively generous gifts or overly lavish hospitality.
• Compliance with laws and regulations: Offer or accept gifts and hospitality openly and transparently in compliance with applicable laws and the anti-corruption regulations of the other party.

3.3 Sponsorships and donations

• Huawei has always pursued balanced growth and has been committed to fulfilling its social responsibilities rather than blindly maximizing commercial interests.
• Huawei prohibits sponsorships and donations driven by corrupt intent and requires effective measures to ensure such activities are transparent and legitimate.
• Huawei does not directly or indirectly participate in the political activities of any political party, nor does Huawei sponsor or donate to local political parties, their candidates, associated persons, or affiliates.

3.4 Employment

Huawei adheres to legitimate employment practices and must not, with any corrupt intent, offer any form of employment or promotion opportunities to public officials, customers, or partners who can exert influence over project decision making, or any other stakeholders who can exert influence over a transaction, nor to their close relatives or other closely associated persons.

3.5 Third-party management

Third parties include suppliers, service providers, subcontractors, distributors, agents, consultants, ecosystem partners, and other partners. Huawei's cooperation with third parties must be authentic and legitimate, and all such third parties are required to comply with Huawei's partner policies and conduct guidelines.

• Huawei believes that due diligence, complete agreement clauses, and corresponding legitimate oversight and control procedures are key to ensuring that third parties comply with this Policy.
• Huawei prohibits instigating or suggesting third parties to engage in bribery or knowingly failing to stop them from engaging in bribery.
• Huawei requires that, when acting on behalf of or in cooperation with Huawei, third parties must not engage in any form of bribery or corruption, including bribery of public officials, customers, or any other stakeholders who can exert influence over a transaction, as well as Huawei employees.

3.6 Books and records

• At Huawei, appropriate documents should be provided in a transparent and honest manner to support business decisions and be archived as required.
• Huawei requires that authentic, complete, and accurate books and financial records be maintained for each asset disposal and financial expenditure in accordance with document retention policies, to facilitate future inspection.
• It is prohibited to set up off-the-record funds.

3.7 Consultation and reporting

• If you have any questions about whether a behavior or activity complies with this Policy, you can consult the compliance organization at the appropriate level.
• If you know of or suspect a violation of this Policy, please report it 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.

4. Accountability and Handling

Employees who violate this Policy will be disciplined. Disciplinary measures may include termination of their employment contract, and they may be held legally liable for violations of laws.

Huawei will likewise restrict and in some cases terminate its partnership with partners that violate this Policy. In addition, Huawei reserves the right to claim damages for any losses caused.