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

Huawei requires all of its Partners, including suppliers, service providers, subcontractors, distributors, agents, consultants, ecosystem partners, and other partners, to comply with all applicable anti-corruption laws and regulations, generally-accepted business ethics, and requirements arising from the Anti-Corruption Policy for Huawei Partners ("this Policy"). Specifically, when Partners are providing services to Huawei and fulfilling their contractual obligations, or providing services to Huawei customers or other third parties and fulfilling their contractual obligations on behalf of Huawei, they shall comply with and uphold the following requirements.

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

·  Partners are forbidden from offering bribes to Public Officials, counterparty stakeholders, or stakeholders that can exert influence over a transaction, with money or anything of value of any form received from Huawei, or for the purpose of helping Huawei obtain or retain business.

"Bribe or Bribery" in this Policy refers to the act of offering money or anything of value of any form with a corrupt intent. Such bribes may include cash, cash equivalents (such as gift cards and precious metals), inappropriate gifts, tourism arrangements and hospitality, improper charitable contributions and donations.

The "Public Officials" in this Policy include individuals who perform duties on behalf of government entities; employees of government agencies, state-owned or state-controlled enterprises, or international organizations; members or candidates of political parties; and other personnel who perform public services according to law. When engaging with Public Officials, Huawei Partners must be mindful of adhering to applicable laws, the honesty and integrity requirements for Public Officials, and this Policy.

·  Any Huawei employee is forbidden from receiving bribes or offering bribes (See Corporate Anti-bribery Policy for details). If any Huawei employee attempts to utilize, aid, abet, induce or conspire with 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.

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

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

4.   Partners shall establish an effective compliance management system, and implement anti-corruption requirements into 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 on Huawei's anti-corruption requirements to their employees and partners, and regularly review the implementation of these requirements.

5.   Partners shall coordinate with Huawei. To ensure that our Partners always abide by the law, ethics, and Huawei's anti-corruption requirements, Huawei shall have the right to conduct proper due diligence of its partners, and implement corresponding 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.

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.

If you have any questions about this Policy, or if you know of or suspect a violation of applicable anti-corruption 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 his or her identify confidential to the extent possible.

In the event there is any inconsistency between this Policy and local laws and regulations, whichever has stricter requirements shall prevail.